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Internal Audit and Counter Fraud Summary of Activities

Argyll and Bute Council · 14 March 2024
Back to Audit and Scrutiny Committee — 14 March 2024 and its agenda

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ARGYLL AND BUTE COUNCIL  AUDIT & SCRUTINY COMMITTEE   
FINANCIAL SERVICES  14 MARCH 2024  
INTERNAL AUDIT  AND COUNTER FRAUD SUMMARY OF ACTIVITIES 
1. SUMMARY  
1.1 The objective of the report is to provide the Audit and Scrutiny Committee (the
Committee) with a summary of Internal Audit activity and progress during quarter
four of 2023/24.  
1.2 Core activities together with a progress update statement are shown below: 
• 2023/24 Audit Plan progress: The plan is on track subject to available
resources being in place for the full period of the approved plan. One review
relating to Building Cleaning has been postponed at the request of the service
department due to resources, together with a review within the Education
Service due to staff sickness and ongoing external inspections. 
• 2023/24 Individual Audits undertaken: three audits have been completed
during the period, 0 have been assessed as providing high assurance, 2
substantial assurance and 1 reasonable assurance. (Where HSCP and
LiveArgyll Audits are included these are provided for information only). 
• Scrutiny: Planned work for 2023/24 in relation to ‘Fly Tipping’ has been
completed following a meeting of the Scrutiny Panel in February 2024. 
• Counter Fraud: The Counter Fraud Team (CFT) is continuing to rebill council
tax accounts and recovery of funds is underway.  All other aspects and referrals
are being considered, investigated and evaluated and the Counter Fraud Team
remain vigilant to protect our public purse. The established CFT team member
is on secondment to Housing for career and personal development for a two
year period.  The CFT have obtained a member of staff, again on secondment
for the same time period. The team lead is currently progressing through year
2 of a Master in Accountancy course.   
• Continuous Monitoring Programme Testing: A number of auditable units are
subject to continuous testing. There has been one new issue which we have
identified this quarter. 
• Performance indicators: Current status is green / on track. 
2. RECOMMENDATIONS  
2.1 To review and endorse the Summary of Activities report.

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3. DETAIL  
3.1 Three audits have been completed since the previous Committee in December
2023. 
Audits Completed 
• Piers and Harbours
• Pupil and Public Transport
• Human Resources – Casual Workers 
Audits in Planning / in Progress
reported to a future meeting of the Committee 
• Client Funds – work in progress
• Learning and Disability Care Packages – Awaiting management comments
• Financial Ledger – field work completed -  draft report being prepared
• Scottish Social Services Council (SSSC) Registration – work in progress
• Freedom of Information Requests – work in progress
• Cloud Based Computer Services – Terms of Reference issued  
3.2 In addition to those already in progress, indicative audits planned for 2023/24 are: 
• Stores – year-end 
3.3 2023/24 Audit Plan 
• Work is progressing on the approved plan and outlined in paragraphs 3.1 –
3.2.
• A request has been made by senior management to postpone the planned
review on Building Cleaning and similarly a review within the Education
service due to staff sickness and external inspections which are ongoing. We
will consider these areas in future plans and would note this as an amendment
to the current Plan for 2023/24.   
Scrutiny  
3.4 It was agreed in June 2023 that scrutiny work for 2023/24 will focus on the
outstanding review concerning ‘Fly Tipping’. Work had previously been postponed
until data became available to the Panel. Discussions have been ongoing with staff
within the Council to ensure data was made available in January for further
analysis and consideration at a meeting of the Panel to conclude on this review. In
February 2024 the Scrutiny Panel met, along with staff responsible for this area of
activity within the Council. An updated and final report has been prepared for
consideration by the Audit and Scrutiny Committee.

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Counter Fraud  
3.5 The CFT is progressing well with both team members fully CIPFA accredited fraud
investigators. The current investigator has taken on a 2 year secondment to empty
homes for further skills development.  The investigators post was filled again on a
secondment basis.  The new member of staff will undertake the above CIPFA
accreditation and is booked onto this course commencing in the latter half of 2024. 
Both team members will revert to substantive post circa sept 2025. 
Continued routine work is still progressing to accurately track the full income
recovered from the team’s work, however, based on the amount of additional
billing, even accounting for a degree of non-recovery, the indications are that the
team are still exceeding their target. In addition, the team are raising awareness of
the Council’s zero tolerance to fraud and this will help act as a deterrent to fraud
being perpetrated in the first place. 
The team aimed to visit Mull, however, due to the cross over with staff this has yet
to take place.  The proactive aim is to gather any new evidence or any further
investigative requirements and will be diarised for a visit during 2024. In addition,
the lead investigator has been out to Tarbert and the team lead out to
Tighnabruiach recently. 
A large review of the Helensburgh area is underway and due to the size of the
area, this review is ongoing and continues to be labour intensive and will continue
in summer 2024 due to other operational demands. 
The team now have an established referral system in place from council tax teams
and the CFT have already liaised with this team going forward into 2024 for the
review of the second and holiday home tax changes.  The information already
shared in the short space of time has resulted in rebilling and adjustments of
accounts.  Together we aim to keep accurate records and update accounts where
error or missing information is held. This approach will continue as the method of
collaborative and interdepartmental working has been helpful. 
The CFT continue to work closely with the empty homes team to support each
other in our remits.  Work and communication between each department is key in
identifying and finding appropriate solutions to enable empty homes to return to
residency or open market. 
The NFI exercise continues to be a routine work area for the CFT. New data from
HMRC has been uploaded and teams have been requested to match this data.
The team lead will progress this into 2024 and have this whole exercise closed in
due course. 
Since the inception of the CFT a total of £1,039,939 has been rebilled and
£777,453 has been recovered. A recovery percentage of 74.7% has been
achieved at the last review of the figures.

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Additional Updates from Quarter Four  
3.6 Staff continue to work from home or on a hybrid approach and this has proved to
be successful, where on-site visits have been required due to the specific nature of
the audit work to be undertaken, these visits have occurred in accordance with any
guidance that was in place, including lone worker best practice.  
3.7 Work has been completed in the preparation of the draft Internal Audit Plan for
2024/25.  The draft plan has been considered by the relevant Department
Management Teams (DMT) and approved. We have also engaged with the
Audit and Scrutiny Committee as part of this process and have been able to
include one of the suggestions based on ‘risk’ and corporate alignment into the
draft plan and offered our appointed External Auditors the opportunity to
comment on the draft plan. This draft plan will be presented to the Audit and
scrutiny Committee in March for its consideration.  
3.8 As part of our work for the HSCP, audit plans for 2024/25 and indicative plans
covering 2025/26 and 2026/27 have also been prepared for presentation to the
Audit and Risk Committee of the HSCP. We have again, consulted with senior
managers of the HSCP in the preparation of this plan and have been approved so
these will be in place before the start of the new financial year.  
3.9 Internal Audit have been liaising with our colleagues in IT where we have been
closely monitoring the cyber incident at Comhairle nan Eilean Siar (Western Isles
Council) in order to glean any areas for learning or consideration. This incident has
had a significant effect on the Western Isles Council including, as reported,
unavailability to access their ‘back-up’ data. It also highlight the threats and
potential effects such incidents can have on public bodies and will continue to
monitor this incident for any learning and/or risk mitigation purposes.   
Continuous Monitoring  
3.10 Our continuous monitoring programme is generally focused on transactional type
activity. Standard audit tests are applied which are relevant to each auditable unit.
Control design tests look at whether the controls in place adequately address the
potential risk event. There has been one new finding within the quarter that require
to be reported. 
Table 2: Continuous Monitoring Findings 
Auditable
Area
Areas Tested Issues Identified Management comment /
action
Travel
Expenses 
VAT Receipts VAT invoices or
receipts were not
attached to claims in
two instances.  
Management will ensure that
an appropriate invoice or
receipt is attached in future. 
3.11 A follow up process is in place whereby management are advised of continuous
monitoring findings and, where appropriate, requested to take remedial action. 
There are currently no outstanding follow-up points arising from previous testing. 
Due to the volume of continuous monitoring tests carried out the decision was
made to report by exception only.

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National Reports  
3.12 A follow up process for national reports is in place whereby management are
advised of national reports published and asked to confirm what, if any, action is
planned as a result of the report.  Table 2 details the national reports issued during
quarter three/four 2023/24 and due to be reported in quarter four 2023/24.  
Table 3: National Reports 
National
Report
Issued
To
Detail Management response/ Action
taken
Adult Mental
Health
IJB Chief
Officer &
Head of
Acute and
Complex
Care
Accessing adult mental
health services in
Scotland remains slow
and complicated for
many people.  In
particular, ethnic
minority groups, people
living in rural areas and
those in poverty all face
additional barriers.
This report raises a number of
challenges for which an action
plan has been prepared.
Local
Government
in Scotland –
Financial
bulletin
2022/23
Executive
Director
Kirsty
Flanagan
Financial pressures
push councils to make
hard decisions about
service cuts.
Frank discussions are
needed with local
communities about the
future of council
services. Difficult
decisions will need to
be made. While
councils received more
money in total (from the
Scottish Government,
Council Tax and other
sources) in 2022/23
than in the previous
year, councils had less
money to spend in real
terms.
No specific actions arising from
this report. 
National Fraud Initiative (NFI)  
3.13 NFI data matching involves comparing computer records held by one body against
other computer records held by the same or another body to identify potentially
fraudulent claims and payments to be identified.  Note though that the inclusion of
personal data within a data matching exercise does not mean that any specific
individual is under suspicion. Where a match is found it indicates that there may be
an inconsistency which requires further investigation. No assumption can be made
as to whether there is fraud, error or other explanation until an investigation is

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carried out.  A reminder process is in place to ensure that matches are reviewed
on a timely basis.  NFI have provided new data throughout 2023/24 and these
have been matched and closed.  
3.14 The current NFI exercise has been released after some technical delays from the
Cabinet Office.  This exercise is conducted throughout the year by officers and
matches checked and closed accordingly.  NFI provided additional data releases
over the course of the exercise and matches are addressed when these become
available.  The current NFI matches are detailed below. The CFT are reviewing the
information received from the NFI matching service, work has commenced to
follow these up locally.  Existing users have been reviewed and new users added
where requested, all users have been informed that matches are available for
review and progress will be monitored monthly by the Counter Fraud team and
reported quarterly to the Audit and Scrutiny Committee.
New HMRC data has been uploaded and released back to us, and teams have
been contacted to start matching this data.   
Table 4: National Fraud Initiative Progress at 11/02/2024
Operation
al Area
Total
Matches
Recommende
d/Very High /
High/Medium
Risk Matches
Matches
Complete 
*
WIP
Match Description
CT to Elect
Register 
2155 0 2155 0 CT records to Electoral Register/
other data sets to ensure discount
awarded to only those living alone
aged over 18, taking into account
disregarded occupants.  (CT to
other Datasets will not be
progressed further due to poor
quality data)
CT rising
18s 
402 0 402 0
Housing
Benefits
21  15 19 0 HB records to records in other
authorities / other datasets
including student loans, payroll
and pensions to identify
undeclared income and capital.
Payroll 143 2 2 0 Payroll records to other datasets
including other payrolls and
pensions to ensure employee is
not receiving additional income.
Blue
Badges
238 205 227 0 Blue badge records to DWP data
to identify deceased claimant with
valid badge.
Housing
Waiting list
233 214 206 1 Housing waiting list records to
other organisations HBCTR and
tenant data to identify
undisclosed changes in circs or
false info.
Council
Tax
Reduction
307 233 278 0 CTR records with records in other
authorities / other datasets
including; student loans, payroll
and pensions to identify
undeclared income and capital
Creditors 589 0 26 0 Analyses Creditors data to
identify possible duplicate
vendors and payments, VAT

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errors or fraud and multiple
vendors sharing a bank account.
Procureme
nt
38 0 36 0 Payroll records to Companies
House and creditors’ data to
identify employees who appear to
have a personal interest in a
company that the authority has
traded with. 
* Work in Progress 
Overall Summary of Matches 
Matches
Complete
Work In
Progress
Cleared Frauds Errors Total
Value 
£
Recovering Recovering
Value 
£ 
3351  1 3258 0 93 0 0 0 
Internal Audit Development  
3.15 The table below details progress against the action points in our Internal Audit
development plan.  
Table 5: Internal Audit Development Key Actions: updated 15/02/24 
Area For
Improvement
Agreed Action Progress
Update
Timescale
Review Continuous
Monitoring
Programme
Continuous monitoring tests will be
reviewed following audit of Debt
recovery to assess value of existing
tests carried out. 
Consider adding test to review date
taken to process invoices from date of
receipt within the Council (not at
Creditors)
In progress June 2024
Update Internal Audit
Manual in include
evaluation of internal
audit reports against
the Local Government
(Scotland) Act 1973
exemption criteria.
Add paragraph to the IA Manual to
evaluate whether reports being
submitted to committee should be
considered for exemption under the
Local Government (Scotland) Act
1973.  
Completed and
included in
update report
to Audit and
Scrutiny
Committee in
March 2024.
March 2024 
3.16 Internal Audit scorecard data provided below are aligned to those for internal audit
in the Financial Services service plan.  All indicators are shown as currently being
on track.

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Table 6: Internal Audit Team Scorecard  
Internal Audit Team Scorecard 2023– 24 – FQ3 23/24 (as at December 2023)
BO115 We Are Efficient And Cost Effective    
Internal Audit Level of Satisfaction
Actual  92% G 
Target 80%
Review of Strategic Risk register
Status On Track G 
Target On Track
Percentage of audit plan completed
Status 100% G 
Target 100%
Percentage of audit recommendations accepted by
management
Actual  100%
G
Target 100% 
4 CONCLUSION  
4.1 The 2023/24 audit plan is on track and the Counter Fraud Team is continuing with
visits and pro-active work throughout Argyll and Bute.  
5 IMPLICATIONS
5.1 Policy – Internal Audit continues to adopt a risk based approach to activity
5.2 Financial –None
5.3 Legal –None
5.4 HR – None
5.5 Fairer Scotland Duty – None
5.5.1 Equalities – protected characteristics – None
5.5.2 Socio-Economic Duty – None
5.5.3 Islands – None
5.6 Climate Change – None 
5.7 Risk – None
5.8 Customer Service – None
5.9 The Rights of the Child (UNCRC) – None 
For further information please contact Internal Audit (01546 604108)
Paul Macaskill
Chief Internal Auditor
14 March 2024