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2022_23_Internal Audit_ManagementOfDebt_Debt RecoveryProcedures_ FINALReport

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
Internal Audit Report
April 2023
Final 
High Medium Low VFM
Number of
Findings
0 4 3 1 
Management of Debt/
Debt Recovery
Audit Opinion: Reasonable

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Argyll and Bute Council – Internal Audit Report – Management of Debt/Debt Recovery, April 2023
Contents 
1. Executive Summary ........................................................................................................................ 3
Introduction ............................................................................................................................................ 3
Background ............................................................................................................................................. 3
Audit Scope ............................................................................................................................................. 4
Risks ........................................................................................................................................................ 4
Audit Opinion ......................................................................................................................................... 4
Recommendations ................................................................................................................................. 5
2. Objectives and Summary Assessment ........................................................................................... 5
3. Detailed Findings ............................................................................................................................ 7
Appendix 1 – Action Plan ..................................................................................................................... 13
Appendix 2 – Audit Opinion ................................................................................................................. 23 
Contact Details 
Internal Auditor: Annemarie McLean
Telephone:  01700 501354 
E-mail:   annemarie.mclean@argyll-bute.gov.uk 
www.argyll-bute.gov.uk

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Argyll and Bute Council – Internal Audit Report – Management of Debt/Debt Recovery, April 2023
1. Executive Summary
Introduction
1. As part of the 2022/23 internal audit plan, approved by the Audit & Scrutiny Committee in
March 2022, we have undertaken an audit of Argyll and Bute Council’s (the Council) system of
internal control and governance in relation to the Management of Debt/Debt Recovery.
2. The audit was conducted in accordance with the Public Sector Internal Audit Standards (PSIAS)
with our conclusions based on discussions with council officers and the information available at
the time the fieldwork was performed. The findings outlined in this report are only those which
have come to our attention during the course of our normal audit work and are not necessarily
all the issues which may exist. Appendix 1 to this report includes agreed actions to strengthen
internal control however it is the responsibility of management to determine the extent of the
internal control system appropriate to the Council.
3. The contents of this report have been agreed with the appropriate council officers to confirm
factual accuracy and appreciation is due for the cooperation and assistance received from all
officers over the course of the audit.
Background
4. Argyll and Bute Council (the Council) has a legal duty to ensure cost effective billing, collection
and recovery of all sums due, through raising charges for a wide range of services provided, as
well as collecting local taxes.  A corporate debt policy is in place providing general principles to
be applied consistently within all Council Services in relation to debt recovery.
5. The Council’s ability to continue in the delivery of services within our communities depends
heavily on its success in collecting revenues, however, this needs to be balanced in the approach
taken and the ability to pay when undertaking debt recovery. The approach to recovery must be
sensitive to individual circumstances and take into account all debts owed to the council,
namely; Council Tax, Housing Benefit overpayments, Non-Domestic Rates and Sundry Debtor
Accounts.
6. The key objectives of the Corporate Debt Policy are as follows:
 to seek to address debt issues as early as possible with a strong emphasis on arrears
prevention in order to minimise overall indebtedness and improve collection rates across all
debt categories;
 to ensure that customers have a clear understanding of their responsibility to pay and the
associated consequences of deliberate non-payment especially when they are able to pay;
 to operate in a fair and equal way when recovering debt; 
 to work in partnership with customers and their representatives to agree realistic payments
based on their circumstances;
 to ensure that all council staff and council appointed debt collection agents and sheriff
officers work together efficiently and effectively and provide a single co-ordinated approach
in dealing with council debtors;
 to support debtors in becoming reliable payers in the future through referral to appropriate
advice agencies;

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Argyll and Bute Council – Internal Audit Report – Management of Debt/Debt Recovery, April 2023
 to ensure that all debtor accounts are issued as accurately as possible and are updated for
any relevant changes in circumstances in accordance with the timescales within the
Council’s Customer Charter;
 debtors are advised of all relevant benefit entitlements and assistance is provided in
accessing these benefits.
7. Last year,  Argyll and Bute Council has written off the following value of debts:
Source 2019-20
£000
2020-21
£000
2021-22
£000
Council Tax 317.5 137 800
Non-Domestic Rates 213.5 85 338
Sundry Debtors 150 75 101
Housing Benefit Overpayments 0 0 134
TOTALS 681 297 1,373
Audit Scope 
8. The scope of the audit was to assess the controls in place for the management of debt and
assess compliance with procedures as outlined in the Terms of Reference agreed with the
Revenue and Benefits Manager 29 June 2022.
Risks
9.  The risks considered throughout the audit were:
 0RR08:  Failure to achieve budgeted income from local taxes and / or other income
 Audit Risk 1: Council systems and processes are not effective in maximising debt
recovery
Audit Opinion
10. We provide an overall audit opinion for all the audits we conduct. This is based on our
judgement on the level of assurance which we can take over the established internal controls,
governance and management of risk as evidenced by our audit work.  Full details of the five
possible categories of audit opinion is provided in Appendix 2 to this report.
11. Our overall audit opinion for this audit is that we can take a reasonable level of assurance.  This
means that internal control, governance and the management of risk are broadly reliable.
However, whilst not displaying a general trend, there are areas of concern which have been
identified where elements of residual risk or weakness may put some of the system objectives at
risk.
12. This review covered the management and recovery of debt over four areas – Council Tax, Non
Domestic Rates, Housing Benefit Over Payments and Sundry Debtors, which are invoices raised
by Services. We found no significant issues in relation to processes and procedures for Council
Tax, Non Domestic Rates and Housing Benefit Over Payments, most of which are covered by
legislation and are working well. The contents of this report largely covers findings regarding the
management and recovery of Sundry Debtors.

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Argyll and Bute Council – Internal Audit Report – Management of Debt/Debt Recovery, April 2023
Recommendations
13. We have highlighted five medium priority recommendations, three low priority
recommendations and one value for money recommendation, where we believe there is scope
to strengthen the control and governance environment. These are summarised below:
 The Corporate Debt Policy requires to be updated to reflect the Councils organisational
structure and current working practices.
 The Debtors Procedure Manual is not up to date and does not reflect current working
practices. A full review of the processes and procedures for Sundry Debtors relating to
the management, arrears, follow-ups and bad debt write offs should be carried out,
prior to updating the manual.
 There are only two templates for the issuing of invoices and reminders, Argyll General
and Argyll CS, but there are seven different recovery routes. In consultation with Legal
Services a review should be undertaken to ensure the stated terms and conditions
match the recovery routes.
 Performance monitoring and reporting measures set out in the Corporate Debt Policy
are not currently in place. These should be re-introduced and consideration given to
which committees and meetings should receive reports regarding the management and
recovery of Sundry Debtors.
 Non Domestic Rates information on the Council’s website and leaflets should be
updated to provide details of the consequences for non-payment, the timescales and
steps that the Council will take to recover amounts due, and any charges for these. 
 The current review of the Housing Benefit procedures should be completed.
 Concerns have been raised regarding a lack of resilience within staff involved in the
management and recovery of debt. This is a known issue which will be addressed during
the Business Process Review and restructuring of the Revenues and Benefits Service.
 Consideration should be given to whether it is possible to issues text message reminders
for Non Domestic Rates missed payments as is available within other systems. 
14. Full details of the audit findings, recommendations and management responses can be found in
Section 3 of this report and in the action plan at Appendix 1.
2. Objectives and Summary Assessment
15. Exhibit 1 sets out the control objectives identified during the planning phase of the audit and our
assessment against each objective.  
Exhibit 1 – Summary Assessment of Control Objectives 
Control Objective Link to Risk Assessment Summary Conclusion
1 A debt recovery
procedure been
established which
specifies the types
of action to be
taken and
timescales for
such
ORR08
Audit Risk 1
Reasonable  The Corporate Debt Policy and the
Debtors Procedure Manuals have not
been updated since 2017 and do not
reflect the current Council
organisational structure nor current
working practices. 
 Procedures for Council Tax and Non
Domestic Rates are in place and up to
date.

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Argyll and Bute Council – Internal Audit Report – Management of Debt/Debt Recovery, April 2023
 The Housing Benefits Procedures are in
the process of being updated to reflect
current working practices. 
 Information published on the website
would benefit from being updated.
 A Business Process Review (BPR) is
currently being undertaken, this includes
a review of debt management and
recovery policies and procedures.
2 Debt
management,
arrears follow-up
procedures and
bad debt write
offs are properly
controlled
ORR08
Audit Risk 1
Reasonable  Debt management, arrears follow-up
procedures and bad debt write offs are
properly controlled for Council Tax, Non
Domestic Rates and Housing Benefit
over Payments.
 Our overall conclusion is that debt
management and arrears follow-up
procedures relating Sundry Debtor
invoices are not carried out in
accordance with procedures. 
 Testing identified a number issues which
are detailed in the body of report. 
 A full review of the processes and
procedures for Sundry Debtors relating
to the management, arrears, follow-ups
and bad debt write offs should be
carried out.
3 There is
appropriate
monitoring and
reporting of debts
and write offs
ORR08
Audit Risk 1
Reasonable  Performance measures are in place to
monitor the collection rates for Council
Tax and Non Domestic Rates.
 Performance Measures are in place to
monitor the maximisation of helping
people to access benefits.
 There are no performance measures in
place to monitor recovery of Sundry
debt. 
 Quarterly meetings with Legal Services
to discuss recovery of Sundry Debtors
were postponed during the pandemic,
these have not been re-instated.
 The value of debt being actively
managed is not easily quantifiable.
 Management information relating to
Sundry Debtors is not made widely
available; 
- Outstanding Debt reports are issued on
the 1st of the month to the Health and
Social Care Partnership, Finance,
Housing, Development and
Infrastructure Services, Legal Services
and Live Argyll, aged debtors reports are
sent to Services who ask;

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Argyll and Bute Council – Internal Audit Report – Management of Debt/Debt Recovery, April 2023
- Reporting is only to the Financial
Services Management Team via
Highlight Reports.
 Provisions for Bad Debt are set in
accordance with procedures.
16. Further details of our conclusions against each control objective can be found in Section 3 of this
report.  
3. Detailed Findings
A debt recovery procedure been established which specifies the types of action to be taken and
timescales for such
17. Argyll and Bute Council’s (the Council’s) Corporate Debt Policy (the Policy) links to the Council’s
corporate priorities and outcomes and is governed by and takes cognisance of the Council’s
Financial and Security Regulations. It is an over- arching document which provides a framework
to collect council debt from debtors effectively and efficiently but with due sensitivity to the
circumstances of individuals. Specific recovery procedures for each individual debt type are
contained in separate manuals and procedures notes. It outlines roles and responsibilities of
council officers and management that naturally provide for segregation of duties. It also
emphasises the need for good customer service, communications, payment and recovery
options.
18. The Policy is published on the Council’s website but has not been reviewed since 2017 and does
not reflect the Council’s current organisational structure, nor current working practices. In
particular the Performance and Monitoring requirements outlined in the Policy, refers to targets
no longer in place and reporting of Sundry Debtors, that has not been fully implemented and
meetings that have been reinstated since the pandemic halted recovery actions.
19. The Revenues and Benefits Manager is currently undertaking a Business Process Review (BPR) of
the Revenues and Benefits Service. As part of this, a working group, led by the Head of Legal and
Regulatory Services, will be reviewing the Council’s Corporate Debt Policy, processes and
procedures relating to the management and recovery of debt.  
Action Plan 1 
20. There are currently three main systems used in the management and recovery of Debt;
 Council Tax and Housing Benefit Over Payments are collected and administered using
the OpenRevs system;
 NDR is collected and administered using the Northgate NDR system; and
 Services use the Debtors Civica Financial System to raise invoices.
21. There are manuals in place providing staff with clear step by step instructions on how to use the
systems and there are separate procedural manuals detailing the processes, tasks and actions
required for the management and recovery of the four types of debt. The processes relating to
Council Tax, NDR and Housing Benefit Over-Payments are primarily set out in legislation. The
Council Tax and NDR processes are comprehensive and robust and have contributed to the
consistently high levels of collection levels of 96.25% for Council Tax and 96.52% for NDR for the
financial year 2021 -2022.

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Argyll and Bute Council – Internal Audit Report – Management of Debt/Debt Recovery, April 2023
22. The Housing Benefit procedures, while comprehensive, are being updated by the Corporate
Debt Recovery Team Leader to reflect the revised working practices which have resulted in the
excellent recovery rate of 149% of Housing Benefit Over Payments for the year 2021-2022.  This
process has not been prioritised due to staffing issues.
Action Plan 6
23.  The Sundry Debtors processes are set out in the Debtors Procedure Manual using the
framework of the Corporate Debt Policy. This document has not been reviewed since 2017 and
does not reflect the current Council organisational structure or current working practices. While
some of the issues raised can be classed as housekeeping issues, we acknowledge that the
manual will be reviewed as part of the Business Process Review. However, there are references
to key processes which are not being carried out, in particular;
 There are no targets for the recovery of Sundry Debt;
 Reporting of performance is limited to discussions at Financial Services Team Meetings
via highlight reports;
 Management information, in the form of outstanding invoices, should be provided on a
monthly basis to a Single Point of Contact in each Service. This is not happening,
currently only those Services who request the information are being sent the reports.
 Quarterly meetings with Legal Services to discuss issues regarding the recovery of debt
were postponed during the pandemic as all recovery procedures were put on hold,
these have not resumed. 
 There are currently seven separate recovery routes to meet with specific Service
requirements, the manual only refers to two.
Action Plan 4 and 2
24. During the time taken to carry out the review there were staff absences in different areas, for a
variety of reasons including, illness, maternity cover, holidays and staff required to cover other
deadlines. It was noticed that this has had an effect, in part, on the timely progress of the
review, and to find information. Conversations with the Revenues and Benefits and Legal
Services Managers and with officers involved in the recovery and management of debt have
raised concerns over a lack of resilience in this area. Although there is cover for key tasks, any
reduction in staffing levels has had a noticeable impact upon the workload for other staff within
the teams.  While this is a known issue, which will be addressed during the Business Process
Review and restructuring of the Revenues and Benefits Service, this represents a potential
business continuity risk.
Action Plan 7
Debt management, arrears follow-up procedures and bad debt write offs are properly controlled 
25. To establish whether debt management and arrears follow-up procedures are carried out in
accordance with Council Tax and NDR procedures, a sample of 30 records each, were selected
from Petitions to Sherriff Courts for testing. For both of these, recovery up to this Sherriff stage,
is built into the systems which generate reminders to issue by post, as required by legislation. 
Processes up to this stage are handled with by the respective teams, while processes from
Sherriff Officer onwards are dealt with by the Corporate Debt Recovery Team.
26. The Council, via its website, provides information to the public regarding its Corporate Debt
Policy and how it collects and recovers Council Tax and Non Domestic Rates income. The Council
Tax web page details how to pay and what help is available to those finding it difficult to pay.
This is open and transparent and clearly sets out what happens if you don’t pay your Council Tax,

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Argyll and Bute Council – Internal Audit Report – Management of Debt/Debt Recovery, April 2023
detailing the steps that the Council will take to recover the amounts due and the timescales,
listed on the Recovery Timetable, and charges for these. 
27. To aide recovery, where the Council has a customer mobile phone number, a text reminder is
issued 3 days prior to the dates that the letters must be issued. This had proved successful as it
prompted customers to pay. All 30 records were found to follow these procedures and
timescales, with notes added to evidence help provided to customers during the processes.
Action Plan 8
28. In April 2022, there was a significant change to the collection of Non Domestic Rates (NDR), with
a move from paying the annual amount over two payments in a year, to collection monthly over
10 payments. This information is published on the Business Rates webpage which provided
details of how to pay, what reliefs, discounts and help are available. There is no information on
the consequences of not paying nor any details of the steps that the Council will take to recover
the amounts due and the timescales and charges for these. A review of the information leaflets
sent out with annual bills found no mention of the NDR recovery process although it is detailed
on the back of reminders issued when an instalment is missed. 
Action Plan 5
29. Testing of the NDR records found that all 30 records were processed in line with procedures.
30. Sundry Debtors testing was carried out using a sample of 47 records selected from the Aged
Debtors reports and covering the seven recovery routes, 44 of the invoices were raised during
the current financial year. The recovery process is built into the system with invoices
automatically progressing to the next stage in line with the timeframes detailed in the recovery
routes and reminder notices generated by the system using a standard template which details
when payment is due, the consequences for non-payment and the timescales. The arrears
process is administered by the Sundry Debtors team up until the recovery stage of ‘Passed to
Legal’ at which point the invoices are passed to Legal Services to start formal recovery processes. 
31. Our overall conclusion is that debt management and arrears follow-up procedures relating
Sundry Debtor invoices are not carried out in accordance with procedures. A number of issues
were identified during testing, these included:
 One invoice raised inappropriately for the drawdown of grant monies;
 Three invoices raised with the incorrect recovery route.
 There are only two standard templates for the issuing of Council invoices in relation to
Sundry Debtors. This is used for all invoices regardless of the recovery routes. The issue
arising from this is the recovery route timescales built into the system does not always
match that detailed on invoices, reminders and final reminders.  
 Five of the invoices are outstanding but have not been passed to Legal Services because
the specific recovery route used means that debt management and follow up should be
handled by the Services. We found no notes or evidence on the Debtors system that
demonstrates any Service involvement or proactive steps being taken to recovery these
monies. 
Action Plan 3
32. The Debtors system automatically produces a daily report with a list of invoices which have
reached the ‘Passed to Legal’ timescales, this is emailed to Legal Services on a daily basis. Legal

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Argyll and Bute Council – Internal Audit Report – Management of Debt/Debt Recovery, April 2023
Services have a flow chart depicting their debt management process using the ‘Iken system’
which does not interface with the Debtors system. 
33. Currently Legal Services have approximately a three month backlog and are working on reports
sent to them in December 2022.  This primarily stems from staff secondment to duties relating
to the Council’s Covid Pandemic Response due to the suspension of debt recovery.  
34. When invoices are passed to Legal Services, recovery may be hampered due to lack of customer
telephone and email contact details being entered when the Debtors records are created by
Services. A check on these fields does not form part of the spot checks carried out by the Sundry
Debtors team. However, it should be mandatory to complete these fields. 
Action Plan 3
35. The value of debt currently being managed by Legal Services is not accurately quantifiable for a
number of reasons:
 Invoices are raised using the Debtors system which does not interface with the Iken
System used by Legal Services;
 The ‘Passed to Legal’ is the final stage on the Debtors system but not all invoices are
moved to this stage e.g. Community Services invoices;
 Not all debtors are managed by Legal Services (e.g. Commercial Waste issued and
managed by Roads and Infrastructure Business Support Team and the Income
Maximisation Team in Finance)
Action Plan 4
36. The Corporate Debt Recovery Team are responsible for writing off debt for Council Tax, Non-
Domestic Rates and Housing Benefit over Payments (HBOP). Testing undertaken on 10 records,
for each of the three types of debt, selected from the accounts written off this current financial
year established that all 30 cases complied with the write off processes. There is evidence of
supervisory checks on all recommendations passed for consideration for write off and good back
up evidence retained to support the decision. Authorisation of the accounts and amounts to be
written off was granted as per the Council’s Financial Standing Orders prior to the team
actioning the write off. 
37. While observing staff keying the HBOP write off on the system, it was noticed that there is only
one spreadsheet for each category used throughout the whole process, from gathering
information to gaining authorisation then keying. Given the time taken to receive authorisation
there are occasions where the actual amounts written off are lower than authorised as a
payment may have been received. Where this occurs the amount on the spreadsheet is altered
to the lower value and actual total amount written off is annotated on the front of the signed
authorisation sheet. This means that the original data is not preserved. Staff were made aware
of the need to retain original data and immediately added additional amount keyed column to
spreadsheets. 
Action Plan 7
38. For Sundry Debtors, the current working practice for write offs does not match the Debtors
Procedure Manual. Currently, on a quarterly basis, the Sundry Debtors team run an Aged Debt
Report and account that fit the criteria of Prescribed Debt or Deceased Customers, are selected
for possible write off. This report is then checked to see if there are any recent payments being
made before it is then passed to Legal Services to check, as in some cases it may be deemed not
financially viable to recover the sums. Where Legal Services believe recovery is still possible they

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Argyll and Bute Council – Internal Audit Report – Management of Debt/Debt Recovery, April 2023
remove the accounts from the list. The report is then passed to the appropriate signatories as
detailed in the Council’s Financial Standing Orders for approval and authorisation, and passed
back to the Sundry Debtors Team for keying. 
39. A reconciliation and check was undertaken on the Sundry Debtor accounts written off for three
of the quarters in this current financial year. We found that overall, Sundry Debtors write off is
not carried out in accordance with procedures. We identified a number of issues including: 
 For all four quarters, Sundry Debtors accounts have been keyed as written off on the
system before authorisation has been received.
 In some cases the write off has been created by the NDR and Income Manager and
approved by lower graded staff. 
 There is insufficient evidence to determine whether all Services receive details of the
invoices and amounts being written off;
 Insufficient evidence to conclude whether appropriate  supporting back up evidence of
what is being written off is retained, leading to concerns that full records may not be
retained;
 While there is a ‘pdf’ version showing the authorisation and the spreadsheets containing
the individual invoices, there are concerns that different sources of data are being used
during the write off process as there is more than one version of the write off
spreadsheet which increases the risk of error. 
 The Debtors Procedure manual states that the Revenues and Benefits Manager will have
oversight of the accounts to be written off, this is not the current working practice. 
Action Plan 2
40. During our discussions with the Revenues and Benefits Manager, we were advised that the
practice of writing off debt in the Debtors System before authorisation had been received has
now been rectified with immediate effect. It is understood that the team who carried out the
action were trying to streamline the process for departments by providing reports that
contained, debt deemed recoverable information only, there was no malicious intent.
Furthermore, the reason some debt was recently entered as written off by a Manager and
approved by a more junior member of staff was due to the pressures arising from Non-Domestic
Rates (NDR) annual billing and the need to prepare the NDR database as part of yearend
procedures. We have been assured by the Revenues and Benefits Manager that it is imperative
that strict adherence to the Council’s Financial Standing Orders in respect of the write-off
process is maintained at all times and this has already been made clear to the team
There is appropriate monitoring and reporting of debts and write offs
41. The Debtors Procedure Manual does not mention that the keying of the Sundry Debtors Write
Offs has two separate stages - first is the creating and approving of invoices as written off on the
Debtors system and second is the manual journals to be processed to account for the VAT
element of the invoices written off. The journal processed in February 2023 did not contain all of
the invoices that had been written off. This caused a difference in the debtors’ element of the
VAT return. While this was small in value it raises concerns as to whether there is appropriate
processes in place to ensure monitoring and oversight of the balancing of the write off, back to
the authorised invoices and values.

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Argyll and Bute Council – Internal Audit Report – Management of Debt/Debt Recovery, April 2023
42. As noted in paragraph 22 in the report above, process detailed within the Debtors Procedure
Manual relating to the reporting are not being carried out and there is insufficient reporting and
monitoring of Sundry Debtors. While we are aware that these processes will be reviewed as part
of the Business Process Review, we recommend that the undernoted be re-instated;
 The provision of reports to Services providing details of the invoices outstanding;
 Meetings between Senior Managers and staff involved in the debt management and
recovery process to discuss issues arising;
 Appropriate performance measures for the recovery of Sundry Debtors. 
Action Plan 4 
43. Discussions with the Revenues and Benefits Manager confirms that the annual process for the
setting of Bad Debt Provisions is carried out in accordance with the procedures.

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Appendix 1 – Action Plan 
No Finding Risk Agreed Action Responsibility /
Due Date
Medium
1 Corporate Debt Policy 
The Document has not been updated since 2017 and does not
reflect the current Council Organisational Structure nor current
working practices. 
Policies are not up
to date and do not
reflect current
working practices.
The Revenues and Benefits Manager
will review the Corporate Debt
Recovery Policy and submit it to a
working group led by the Head of
Legal Services reviewing the Sundry
Debt process for consultation. The
final document will proceed to
October P&R via the Head of
Financial Services and Executive
Director Kirsty Flanagan’s DMT. 
Revenues and
Benefits Manager 
31 December 2023 
Medium
2 Debtors Procedure Manual and Processes
Finding:
The Debtors Procedure Manual has not been reviewed since 2017
and does not reflect the current Council Organisational Structure or
current working practices. 
Recommendation: 
A full review of the processes and procedures for Sundry Debtors
relating to the management, arrears, follow-ups and bad debt write
offs should be carried out., then the Debtors Procedure Manual
should be updated . 
Procedures are not
up to date and do
not reflect current
working practices. 
And 
Council systems
and processes may
not be effective in
maximising debt
recovery
A working group (“the working
group”), led by the Head of Legal and
Regulatory Services, will review the
Sundry Debt Procedure Manual,
processes and procedures relating to
the management and recovery of
Sundry debt. 
This document will progress through
the Council’s DMT to SMT/ELT in a
similar timescale to the Corporate
Debt Recovery Policy going to P&R
(see action 1 above). 
This working group review of Sundry
Debt will include the key issue of
reporting, this aspect of the process
will be vastly improved in the future.
A suite of reports will be developed,
the identification departmental debt
Revenues and
Benefits Manager 
31 December 2023

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Argyll and Bute Council – Internal Audit Report – Management of Debt/Debt Recovery, April 2023 
No Finding Risk Agreed Action Responsibility /
Due Date
Finding:
Management information, detailing outstanding invoices, should be
provided on a monthly basis to a Single Point of Contact in each
Service. This is not happening, currently only those Services who
request the information are being sent the reports. 
Recommendation: 
Reports should be provided to all Services. 
Finding:
There are now seven separate recovery routes to meet with specific
Service requirements, the manual only refers to two. 
Recommendation:
The manual should be updated. 
Finding:
For all four quarters, Sundry Debtors accounts have been keyed as
written off on the system before authorisation has been received. 
Recommendation:
This should never happen, authorisation must always be received
prior to keying. 
Finding:
In some cases the write off has been created by the NDR & Income
Manager and approved by lower graded staff. 
champions reinstated and quarterly
meetings setup for all relevant
stakeholders. 
All recovery routes to be reviewed as
part of working group duties and be
rationalised as far as it is possible to
do so. Each remaining recovery
route will have an end that ensures
that formal action is being taken on
any debt that is not recovered where
this is Council debt. 
Agreed, already actioned 
Agreed, already actioned 
Agreed, already actioned 
Suite of reports,
September 2023 
Revs and Bens
Manager/ Legal
Manager
Meetings with
services/identified
stakeholders by 31
March 2024 
Revs and Bens
Manager
31 March 2024

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Argyll and Bute Council – Internal Audit Report – Management of Debt/Debt Recovery, April 2023 
No Finding Risk Agreed Action Responsibility /
Due Date
Recommendation:
To avoid the risk of imposition the approver should be a higher or
equal grade than the creator. 
Finding:
The Debtors Procedure manual states that the Revenues and
Benefits Manager will have oversight of the accounts to be written
off, this is not current working practice 
Recommendation:
Consideration should be given to introducing this overview. 
Finding:
There is insufficient evidence to determine whether all Services
receive details of invoices being written off. 
Recommendation:
Services should be sent this information. 
Agreed, already actioned 
A thorough review of Sundry Debt
write-off procedure to be carried out
by the working group as part of the
overall update of the Sundry Debt
Procedures.
Reporting and communication with
stakeholders is being reviewed by
the working group. It is anticipated
that reports of debt written off will
be sent to departments as part of a
standard suite of reporting for
discussions at quarterly meetings
this will be confirmed within the
reviewed Sundry Debt Procedure
Manual. 
Back up evidence re write-off should
be retained, the write-off lists and
any backup documentation held
together in MS Teams group for
example.  This could be further
enhanced if we can use EDMS for
storage of the information. If we can
move this onto Civica’s Electronic
Document Management System
Revs and Bens
Manager 
20 April 2023 
Revs and Bens
Manager 
31 December 2023 
Revs and Bens
Manager 
31 December 2023 
Civica EDMS
System Admin
Discussion with
Supplier May 2023

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Argyll and Bute Council – Internal Audit Report – Management of Debt/Debt Recovery, April 2023 
No Finding Risk Agreed Action Responsibility /
Due Date 
Finding
Insufficient evidence to conclude whether supporting back up
evidence of invoices being written off is retained, leading to
concerns that full records may not be retained. 
Recommendations:
Checks should be carried out to ensure that appropriate back up is
retained. 
Finding:
While there is a pdf version of the authorisation and the
spreadsheets containing the individual invoices, there are concerns
that different sources of data are used during the write off process
as there is more than one version of the write off spreadsheet. 
Recommendation:
Checks should be carried out to ensure that Original Data is retained
with records kept of any alteration to the Source Data. 
(EDMS) Comino this will make
collation of information, document
retention and disposal so much
easier and more efficient. Discuss
with Civica, re the use of the
Electronic Document Management
System for these purposes and
overall case management. Improve
the file structure within the network
with the supporting documentation. 
There must only be one version of
the write-off spreadsheet. This can
be shared between Finance and
Legal Services on MS Teams.
Changes can be made to the
document by Legal or Finance before
it is presented to senior
management for final consideration. 
Revs and Bens
Manager
Evaluation of
options July 2023
Revs and Bens
Manager
Development and
Implementation of
Solution March
2024
NDR and Income
Manager to review
the file structure
on the network. 
Revs and Bens
Manager 
31 December 2023

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Argyll and Bute Council – Internal Audit Report – Management of Debt/Debt Recovery, April 2023 
No Finding Risk Agreed Action Responsibility /
Due Date
Finding:
The Debtors Procedure Manual does not mention that the keying of
the Sundry Debtors Write Offs has two separate stages - first is the
creating and approving of invoices as written off on the Debtors
system and second is the manual journals to be processed to
account for the VAT element of the invoices written off. The journal
processed in February did not contain all of the invoices that had
been written off. This caused a difference in the debtors’ element of
the VAT return. While this was a small value it raises concerns as to
whether there is appropriate monitoring and oversight of the
balancing of the write off, back to the authorised invoices and
values. 
Recommendation:
Checks should be carried to ensure that there is appropriate
monitoring and oversight of the balancing of the write off, back to
the authorised invoices and values.
The Debtors Procedure Manual should be updated to reflect all
stages of the write off. 
This can be added to the revision of
the procedure manual which will be
finalised in December 2023. NDR and
Income Manager will ensure the
write-offs in the Debtors system are
fully reconciled with the general
ledger position each quarter. 
Revs and Bens
Manager 
31 December 2023 
Medium
3 Raising of invoices and Recovery Routes 
Finding:
Invoice inappropriately raised for the drawdown of grant monies.
Legal Services confirm this is not a one off. 
Recommendation:
Services should be reminded that Debtors invoices should not be
raised for the drawdown of grant monies nor to recover income 
These examples should be collated
and used to support some internal
training that will be delivered to
launch the new Sundry Debt
Procedure Manual. Training will be
delivered by Finance and Legal
Services to all users of the Sundry
Debt System. Consideration will be
given to the format of the training,
ie:- mandatory e-training for all
current users and new users or
something delivered via MS Teams. 
Revs and Bens
Manager/Legal
Manager
30 June 2024

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Argyll and Bute Council – Internal Audit Report – Management of Debt/Debt Recovery, April 2023 
No Finding Risk Agreed Action Responsibility /
Due Date 
Finding: 
There are only two templates for the issuing of invoices and
reminders, Argyll General and Argyll CS, but there are seven
different recovery routes. This is used for all invoices regardless of
the recovery routes. The issue with this is that the recovery route
timescales built into the system do not always match that detailed
on the standard templates for invoices, reminders and final
reminders. 
Recommendation: 
In consultation with Legal Services a review should be undertaken
to ensure the stated terms and conditions match the recovery
routes and reflecting the appropriate consequences for not paying. 
Finding: 
Legal Services recovery is hampered due to lack of customer
telephone and email contact details being entered when the
Debtors records are created by Services. 
Recommendation: 
Phone number and email fields should be mandatory 
Training to be delivered to all users
by June 2024. 
Recovery Routes to be reviewed by
working group. Rationalised where
possible. A process will be put in
place whereby new recovery routes
should be signed off by senior
officers in Finance and in Legal
Services in the future.   
Speak to System supplier about
making these fields mandatory for
users to complete if raising a debtor
account. 
NDR and Income
Manager 
31 October 2023 
NDR and Income
Manager 
30 June 2023 
Medium
4 Performance Monitoring and Reporting  
Findings
 There are no performance measures in place to monitor
recovery of Sundry debt 
 Quarterly meetings with Legal Services to discuss recovery of
Sundry Debtors were postponed during the pandemic, these
have not been re-instated.
Council systems
and processes may
not be effective in
maximising debt
recovery 
And
Performance monitoring and
reporting will be a key part of the
Sundry Debt review undertaken by
the working group led by the Head
of Legal Services. 
It is anticipated that proposals for
quarterly meetings and the reporting
Revenue and
Benefit Manager 
31 March 2024

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Argyll and Bute Council – Internal Audit Report – Management of Debt/Debt Recovery, April 2023 
No Finding Risk Agreed Action Responsibility /
Due Date
 Management information relating to Sundry Debtors is not
made widely available; 
o Aged debtors reports are only sent to  Services who ask;
o Reporting is only to the Financial Services Management
Team via Highlight Reports. 
Recommendations:
Appropriate performance measures should be put in place to
monitor recovery of Sundry Debt.
The meetings with Legal Services should be re-instated and
consideration given to which committees and meetings should
receive reports regarding the management and recovery of Sundry
Debtors. 
Finding:
The value of debt currently being managed by Legal Services is not
accurately quantifiable.
 The Passed to Legal is the final stage on the Debtors system but
not all invoices are moved to this stage e.g. Community Services
Invoices 
 Not all debtors are managed by Legal Services (e.g. Commercial
Waste issued and managed by Roads and Infrastructure
Business Support Team and the Income Maximisation Team in
Finance) 
 Invoices are raised using Civica Debtors system which does not
interface with the Iken System used by Legal Services 
Recommendation:
Consideration should be given to whether it is practical/ cost
effective to add other stages to the Debtors system e.g. Legal Letter
1 or Passed to Sherriff etc
Debt management,
arrears follow-up
procedures and
bad debt write offs
may not be
properly monitored
and reported.
suite will be developed and
implemented by March 2024 
The process for the raising of and
the recovery Commercial Waste
debt and Residential Care debt will
be considered as part of the Review
of Sundry Debt. 
There was efforts made previously
by staff in D&I and Finance to
integrate Commercial Waste onto
the Sundry Debt system but it failed 
The ongoing work of the working
group will examine the possibilities
of adding legal recovery stages to
the Sundry Debt system. 
Head of Legal and
Regulatory
Services 
31 March 2024 
NDR and Income
Manager to
implement new
recovery stages, 
31 December 2023

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Argyll and Bute Council – Internal Audit Report – Management of Debt/Debt Recovery, April 2023 
No Finding Risk Agreed Action Responsibility /
Due Date
Low
5 Non Domestic Rates Recovery  
Finding:
Information published on the website and sent out in the NDR
information leaflets does not detail the consequences for non-
payment nor details of the steps that the Council will take to
recover the amounts due and the timescales and charges for these. 
Recommendation:
The website and information leaflets should be updated 
Customers’
expectations are
not managed which
may lead to failure
to achieve
budgeted income
from local taxes
Website to be updated alongside the
leaflet issued annually to ratepayers. 
NDR and Income
Manager 
30 September
2023
Low
6 Housing Benefits Procedures  
Findings:
The Housing Benefit procedures, while comprehensive, are being
updated by the Corporate Debt Recovery Team Leader to reflect the
revised working practices. This process has not been prioritised due
to staffing issues. 
Recommendation:
Complete the revision of the Housing Benefits Procedures 
Finding:
The HBOP write off original data is not maintained. 
Recommendation:
Either the original spreadsheet is printed to pdf when being passed
for authorisation or the original data tab be copied to a new tab
titled Keyed. 
Revision of HBOP recovery
procedures to be updated and the
write-off procedure updated to
reflect the fact that if there is
movement in the amount of debt to
be written off during the period that
the write-off is being considered by
senior management the these
individual debts will be removed
from the current write-off process,
have their circumstances reviewed
and be reconsidered for write-off in
a future quarter. However if the
reason for the change is that a
debtor has started to pay then the
expectation is that the debt will not
be presented for write-off in the
near future. If the reason for the
change is a backdated adjustment to
benefit entitlement then this could
possibly be represented to the
Executive Director in future write-off
Corporate Debt
Recovery Team
Leader 
31 December 2023

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Argyll and Bute Council – Internal Audit Report – Management of Debt/Debt Recovery, April 2023 
No Finding Risk Agreed Action Responsibility /
Due Date
if the reason for the write-off action
remains unchanged. Whatever the
circumstances the individual debt
will be removed from the existing
write-off exercise and reviewed
before the appropriate course of
action is taken. 
Low
7 Resilience 
Although there is cover for key tasks, any reduction in staffing levels
has a noticeable impact upon the workload for other staff within
the teams.  This is a known issue, which will be addressed during
the Business Process Review and restructuring of the Revenues and
Benefits Service
Potential business
continuity risk
Issue of resilience continues to be
reviewed as part of the overall Revs
and Bens BPR. 1 FTE has been added
to the team permanently, the rest of
the roles are currently under review. 
Revenues and
Benefits Manager 
31 March 2024
VFM
8 Sharing of good practice
Consideration should be given to whether it is possible to issues
text message reminders for Non Domestic Rates missed payments. 
No risk – this has
proved successful
at prompting
Council Tax
customers to pay. 
The service would like to look at the
possibility of E-billing and text
reminders for NDR in the future.
There will be a cost to this, given
that NDR income is pooled by the
government it has never been our
highest priority. That being said it
would introduce improvements for
our businesses. We will approach
the systems supplier, Northgate
(Orbis) and get quotes for this work. 
At that point a business case will
need to be considered before any
other progress can be made. 
NDR and Income
Manager 
Quote to be
requested by June
2023.

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Argyll and Bute Council – Internal Audit Report – Management of Debt/Debt Recovery, April 2023
In order to assist management in using our reports a system of grading audit findings has been adopted to allow the significance of findings to be ascertained. 
The definitions of each classification are as follows: 
Grading    Definition
High  A major observation on high level controls and other important internal controls or a significant matter relating to the critical success of the
objectives of the system.  The weakness may therefore give rise to loss or error. 
Medium 
Observations on less significant internal controls and/or improvements to the efficiency and effectiveness of controls which will assist in meeting
the objectives of the system.  The weakness is not necessarily substantial however the risk of error would be significantly reduced if corrective
action was taken.  
Low  Minor recommendations to improve the efficiency and effectiveness of controls or an isolated issue subsequently corrected.  The weakness does
not appear to significantly affect the ability of the system to meet its objectives. 
VFM  An observation which does not highlight an issue relating to internal controls but represents a possible opportunity for the council to achieve
better value for money (VFM).

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Argyll and Bute Council – Internal Audit Report – Management of Debt/Debt Recovery, April 2023
Appendix 2 – Audit Opinion 
Level of Assurance  Definition 
High 
Internal control, governance and the management of risk are at a high standard. Only marginal elements of residual risk have
been identified with these either being accepted or dealt with. A sound system of control designed to achieve the system
objectives is in place and being applied consistently. 
Substantial 
Internal control, governance and the management of risk is sound. However, there are minor areas of weakness which put some
system objectives at risk and specific elements of residual risk that are slightly above an acceptable level and need to be
addressed within a reasonable timescale. 
Reasonable 
Internal control, governance and the management of risk are broadly reliable. However, whilst not displaying a general trend,
there are areas of concern which have been identified where elements of residual risk or weakness may put some of the system
objectives at risk. 
Limited 
Internal control, governance and the management of risk are displaying a general trend of unacceptable residual risk above an
acceptable level and placing system objectives are at risk. Weakness must be addressed with a reasonable timescale with
management allocating appropriate resources to the issues raised. 
No Assurance 
Internal control, governance and the management of risk is poor. Significant residual risk and/or significant non-compliance with
basic controls exists leaving the system open to error, loss or abuse. Residual risk must be addressed immediately with
management allocating appropriate resources to the issues.