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Internal Audit and Counter Fraud Summary of Activities

Argyll and Bute Council · 16 March 2023
Back to Audit and Scrutiny Committee — 16 March 2023 and its agenda

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ARGYLL AND BUTE COUNCIL  AUDIT & SCRUTINY COMMITTEE   
FINANCIAL SERVICES  16 MARCH 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
four of 2022/23.  
1.2 Core activities together with a progress update statement are shown below: 
 2022/23 Audit Plan progress: On track subject to available resources being in
place for the full period of the approved plan and that one review is postponed
until 2023-24 for organisational reasons and the second review relating to car
parking is not now required as a departmental review has been undertaken. 
 Individual Audits undertaken: Four audits have been completed during the
period. Three audits have been assessed as providing high assurance, none as
substantial assurance, none reasonable assurance and one as limited
assurance. (Where HSCP Audits are included these are provided for
information only). 
 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 Four audits have been completed since the previous Committee in December
2022. One audit is currently in progress and will be to follow. 
Audits Completed 
 Procurement
 Events Management
 Client Funds

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 Customer Service Centre   
Audits in Planning / in Progress
reported to a future meeting of the Committee 
 Purchasing Cards
 Building Standards
 Cyber Security
 Management of Debt & Debt Recovery
 Burial Records
 Counselling in Schools
 Equality and Socio-Economic Impact Assessment
 Payroll  
3.2 In addition to those already in progress indicative audits planned for Quarter 4
2022/23 are:  
3.3 2022/23 Audit Plan 
 No further outstanding items to be progress on the amended plan.  
3.4 The audit of Learning and Physical Disability Care Packages has been postponed
until April 2023, this review will be now cover a much wider remit and include
governance and management and will be included in the 2023-24 internal audit
plan. This approach has been deemed appropriate by the relevant service and
internal audit. In addition, it was deemed that due to an internal review of parking
this would not require to be covered by internal audit. These remain the
amendments to the original plan approved by the Committee.   
Scrutiny  
3.5 Scrutiny topics agreed for the 2022/23 plan were consultations and a follow-up
review of Fly Tipping.  A Terms of Reference has been produced for the
Consultations review and a team identified, two meetings have taken place and
attended by senior officers supporting the Panel. This report will be submitted to a
future meeting of the Committee once it has been completed.  Progress and follow
up work on the ‘Fly Tipping’ review has been postponed until data becomes
available to the Panel. It is now likely that this will be in the summer of 2023 but we
will keep the Panel updated so this can commence as soon as possible.     
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 they 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. The team have recently visited Oban which has
resulted in the rebilling of a number of accounts.  A revisit to Bute and Dunoon is
due within February and work is planned in other areas which include Helensburgh
and the Islands early in the new financial year.

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The new NFI exercise for 2022/23 has just been released after some technical
delays from Cabinet Office.  This exercise will be conducted throughout the year by
officers and matches checked and closed accordingly.  
3.7 The CFT are reviewing the information received from the National Fraud Initiative
(NFI) matching service, work has commenced to follow these up locally.   
Additional Updates from Quarter Three  
3.8 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.  
3.9 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, Argyll and Bute Council
has been scheduled for review in September 2022 by East Dunbartonshire
Council.  This review has now been completed and a report forms part of the
March papers to the Committee.     
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 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 
3.11 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.     
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

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planned as a result of the report.  Table 2 details the national reports issued during
quarter four 2022/23.  
Table 3: National Reports 
National
Report
Issued
To
Detail Management response/ Action
taken
No new
reports   
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
carried out.  A reminder process is in place to ensure that matches are reviewed
on a timely basis.  
3.14 All required datasets for the 2022-23 exercise have now been uploaded to the NFI
application and some matches were released for review on 29 January 2023 –
there was a delay in Cabinet Office releasing all the data.  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.  As of 17 February, most of the NFI exercise data has now
been released, and initial work has started.   
Table 4: National Fraud Initiative Progress at 12/02/2023 
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 5 0 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

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pensions to ensure employee is
not receiving additional income.
Blue
Badges
238 204 0 0 Blue badge records to DWP data
to identify deceased claimant with
valid badge.
Housing
Waiting list
200 182 0 0 Housing waiting list records to
other organisations HBCTR and
tenant data to identify
undisclosed changes in circs or
false info.
Council
Tax
Reduction
259 138 0 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 0 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 0 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. 
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 
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: 
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.
Work
commenced on
the review of
the  AGS
August
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 March 2023

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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 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, these
will be tested
Q1 2023
report.
June 2023 
3.16 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.  
Table 6: Internal Audit Team Scorecard  
Internal Audit Team Scorecard 2022– 23 – FQ3 22/23 (as at December 2022)
BO115 We Are Efficient And Cost Effective    
Internal Audit Level of Satisfaction
Actual  95% 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 2022/23 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

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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
16 March 2023