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Internal Audit and Counter Fraud Summary of Activities

Argyll and Bute Council · 20 June 2023
Back to Audit and Scrutiny Committee — 20 June 2023 and its agenda

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ARGYLL AND BUTE COUNCIL  AUDIT & SCRUTINY COMMITTEE   
FINANCIAL SERVICES  20 JUNE 2023  
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
one of 2023/24.  
1.2 Core activities together with a progress update statement are shown below: 
 2023/24 Audit Plan progress: On track subject to available resources being in
place for the full period of the approved plan. 
 2022/23 Individual Audits undertaken: Ten audits have been completed
during the period. Three audits have been assessed as providing high
assurance, three as substantial assurance, four reasonable assurance and
none as limited assurance. This completes this audit plan. (Where HSCP and
LiveArgyll Audits are included these are provided for information only). 
 Scrutiny: Planned work for 2022/23 in relation to Consultations has been
completed and forms part of the June agenda. 
 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. 
 Continuous Monitoring Programme Testing: A number of auditable units are
subject to continuous testing. No new issues have been identified this quarter
and management have responded to previous quarter notifications. 
 Performance indicators: Current status is green / on track. 
2. RECOMMENDATIONS  
2.1 To review and endorse the Summary of Activities report.  
3. DETAIL  
3.1 Ten audits have been completed since the previous Committee in March 2023. 
Audits Completed 
 Purchasing Cards
 Building Standards
 Cyber Security

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 Management of Debt & Debt Recovery
 Burial Records
 Counselling in Schools
 Equality and Socio-Economic Impact Assessment
 Payroll
 LiveArgyll – Lochgilphead Community Centre
 LiveArgyll – Mid Argyll Sports Centre 
Audits in Planning / in Progress
reported to a future meeting of the Committee 
 Risk Management
 Learning Disability Care Packages 
3.2 In addition to those already in progress, indicative audits planned for Quarter 2
2023/24 are: 
 Education Maintenance Allowance
 HSCP – Risk Management
 LGBF – Verification Audit
 SPT – Annual Claim Verification  
3.3 2022/23 Audit Plan 
 The plan is now completed and there are no items outstanding.  
3.4 2023/24 Audit Plan 
 Work has commenced on the approved plan and with work ongoing
outlined in paragraph 3.2.   
Scrutiny  
3.5 A significant piece of work has taken place in relation to the scrutiny topic agreed
for the 2022/23 plan relating to consultations. This work was completed in May
2023 and forms part of this agenda for consideration by the Committee.  A report
on the scrutiny subject for 2023/24 will also be considered at this Committee and
will relate to the outstanding working concerning ‘Fly Tipping’. Work had previously
been postponed until data became available to the Panel. It is now likely that this
will be in the autumn/winter of 2023 but we will keep the Panel updated. 
Counter Fraud  
3.6 “The CFT is progressing well with both team members fully CIPFA accredited
fraud investigators. Continued routine work is required to be able 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 they are easily exceeding target. In addition the team are
raising awareness of the Council’s zero tolerance to fraud and this will act as a
deterrent to fraud being perpetrated in the first place.

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The team visited Oban in the early part of the year which has resulted in the
rebilling of a number of accounts, as well as a revisit to Bute and Dunoon in late
February, and has provided some additional billing of due income after extended
investigations. In April 2023 the team made a visit to Islay and in the middle of May
2023 also visited Tiree, both these visits proved very fruitful and rebilling and
adjustments to accounts have already taken place.   
The team aim to visit Mull in the coming months, in addition, a large scale review
will take place in the summer months and will aim to visit Helensburgh, Cardross
and Rhu. 
The CFT have also been assisting with ‘Aged Debt’ and how best to recover these
funds and this work is ongoing in order to provide support to teams from
Infrastructure and Legal.   
Additional Updates from Quarter One  
3.7 Staff continue to work from home 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.  
3.8 The Public Sector Internal Audit Standards (PSIAS) require the Council’s Chief
Internal Auditor (CIA) to develop a Quality Assurance and Improvement
Programme (QAIP). The purpose of the QAIP is to enable the evaluation of
internal audit’s conformance to the PSIAS. The QAIP must include annual
internal self-assessments with a five yearly external assessment, carried out by
an independent assessor.  A programme of five yearly reviews has been
prepared by the Scottish Local Authorities Chief Internal Auditors Group
(SLACIAG) and these will be conducted by peer review. This review has been
completed and the findings were reported to the March 2023 meeting of the
Committee.  The Self-Assessment against the PSIAS for 2023 will be reported to
the September meeting of the Committee.   
Continuous Monitoring  
3.9 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 have been no new findings within the quarter that
require to be reported. 
Table 2: Continuous Monitoring Findings 
Auditable
Area
Areas Tested Issues Identified Management comment /
action  
None identified 
3.10 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.

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Due to the volume of continuous monitoring tests carried out the decision was
made to report by exception only.     
National Reports  
3.11 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 four 2022/23 and due to be reported in quarter 1 2023/24.  
Table 3: National Reports 
National
Report
Issued
To
Detail Management response/ Action
taken
Resourcing
the benefit
service
Chief
Executive
Many people are
waiting longer for
housing benefit claims
to be processed as
services across
Scotland’s councils
face rising workloads,
fewer staff and high
sickness absence
levels.
This report largely supports the
conclusions of a recent Business
Process Re-engineering exercise
for our Benefits and Revenue
team of which are currently being
implemented and therefore note
the national report and no further
action.
Public sector
gender pay
gap reporting
Executive
Director
Kirsty
Flanagan
Analysis of public
sector reporting
highlighting areas of
good practice, common
pitfalls, findings and
areas for improvement.
A gender pay gap report is being
prepared in order to meet our
public sector equality duty
reporting, the content of the
national report will be of
assistance in this process.  The
gender pay gap report was
submitted to the May meeting of
the Policy and Resources
Committee. 
National Fraud Initiative (NFI)  
3.12 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
carried out.  A reminder process is in place to ensure that matches are reviewed
on a timely basis.  
3.13 The new NFI exercise has been released after some technical delays from the
Cabinet Office.  This exercise will be conducted throughout the year by officers and
matches checked and closed accordingly.  NFI have announced more data
releases in the coming month and any matches will be addressed when these
become available.  The current NFI matches are below in the NFI section of his
report. The CFT are reviewing the information received from the National Fraud

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Initiative (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.   
Table 4: National Fraud Initiative Progress at 30/04/2023
Operation
al Area
Total
Matches
Recommende
d/Very High /
High Risk
Matches
Matches
Complete 
*
WIP
Match Description
CT to Elect
Register 
1155 0 1155 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 
208 0 208 0
Housing
Benefits
11 11 11 0 HB records to records in other
authorities / other datasets
including student loans, payroll
and pensions to identify
undeclared income and capital.
Payroll 141 0 0 0 Payroll records to other datasets
including other payrolls and
pensions to ensure employee is
not receiving additional income.
Blue
Badges
238 204 152 0 Blue badge records to DWP data
to identify deceased claimant with
valid badge.
Housing
Waiting list
232 214 1 0 Housing waiting list records to
other organisations HBCTR and
tenant data to identify
undisclosed changes in circs or
false info.
Council
Tax
Reduction
270 138 51 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 19 0 Analyses Creditors data to
identify possible duplicate
vendors and payments, VAT
errors or fraud and multiple
vendors sharing a bank account.
Procureme
nt
38 0 10 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 
£ 
1,363 0 1,363 0 0 0 0 0

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Internal Audit Development  
3.14 The table below details progress against the action points in our Internal Audit
development plan.  
Table 5: Internal Audit Development Key Actions: 
Area For
Improvement
Agreed Action Progress
Update
Timescale
Clearer referencing of
findings referred to in
the Annual Audit
Report and that within
the Annual
Governance
Statement (AGS) and
Vice Versa
Once the AGS has been reviewed,
work will then commence on updating
the Internal Audit Annual Report so
that clearer referencing can be
accommodated between both
documents for ease of use.
Draft AGS has
been prepared
and Internal
Audit Annual
Report with
cross linking of
each
document. 
Completed
June 2023
Create SharePoint list
to track audit actions.
Information recorded on the Access
DB will be transferred to a new
SharePoint list allowing officers to
update progress themselves.  New
actions will be added to this list when
audit reports are published.
Complete Completed
March 2023
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 August
2023
Update format of
template for quarterly
reporting of progress
in implementing audit
actions.
Data extracted from the new
SharePoint list will be exported to
Excel and manipulated into a format
that can be copied to the cover report
template on word.  
Template and
formulae
updated and
will form part of
the June
agenda.
June 2023
Completed 
3.15 Internal Audit scorecard data is available on pyramid. The indicators reported 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 2022– 23 – FQ4 22/23 (as at March 2023)
BO115 We Are Efficient And Cost Effective    
Internal Audit Level of Satisfaction
Actual  96% G 
Target 80%
Review of Strategic Risk register
Status Complete G 
Target Complete
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 – None
5.5.2 Socio-Economic Duty – None
5.5.3 Islands Duty – None
5.6 Climate Change – None 
5.7 Risk – None
5.8 Customer Service – None 
For further information please contact Internal Audit (01546 604108)
Paul Macaskill
Chief Internal Auditor
20 June 2023