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202223_InternalAudit_PrivateSectorGrantsAndHousingAdaptations_Report FINAL

Argyll and Bute Council · 20 December 2022
Back to Audit and Scrutiny Committee — 20 December 2022 and its agenda

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Argyll and Bute Council
Internal Audit Report
December 2022
FINAL 
High Medium Low VFM
Number of
Findings
0 1 2 0 
Private Sector Grants and
Housing Adaptations
Title of Audit
Audit Opinion: Substantial

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Argyll and Bute Council – Internal Audit Report – Private Sector Housing Grants and Adaptations
December 2022 
Contents 
1. Executive Summary .............................................................................................................. 3
Introduction................................................................................................................................. 3
Background.................................................................................................................................. 3
Scope........................................................................................................................................... 4
Risks ............................................................................................................................................ 4
Audit Opinion .............................................................................................................................. 5
Recommendations ....................................................................................................................... 5
2. Objectives and Summary Assessment.................................................................................... 5
3. Detailed Findings .................................................................................................................. 7
Appendix 1 – Action Plan............................................................................................................ 11
Appendix 2 – Audit Opinion........................................................................................................ 13 
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 – Private Sector Housing Grants and Adaptations
December 2022
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 Private Sector Housing Grants (PSHG) and Housing
Adaptations.
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. Section 72 of the Housing (Scotland) Act 2006 (the Act) requires local authorities to prepare and
make publicly available a Scheme of Assistance outlining the circumstances in which they offer
assistance for private sector housing.   
5. The Scottish Government have issued accompanying guidance - the Implementing the Housing
(Scotland) Act 2006 advisory guidance for Local Authorities, to aid the preparation and delivery
of their duties under the Act. 
6. The Scheme of Assistance is the Council’s plan on how to improve the quality and suitability of
private sector housing across Argyll and Bute by offering the following support;  
 Advice and Information (along with key partners in their relevant areas of expertise) -
on home repairs, maintenance, improvements, adaptations, home energy efficiency and
fuel poverty.
 Practical Assistance - relating to the repair and maintenance of homes
 Financial Assistance:
i. Adaptations – 3 Types of Grant available, one is mandatory and 2 discretionary
ii. Repairs – 7 Types of Grant available, 6 are discretionary and the other is the
Home Energy Efficiency Scheme (HEEPs). 
7. The Public Bodies (Joint Working) (Scotland) Act 2014 (the Act) requires Health Boards and Local
Authorities to integrate planning for, and delivery of, certain adult health and social care
services. This legislation means that from 1st April 2016 the Integrated Health and Social Care
Body has responsibility for disabled adaptations. To reflect this the Council’s Scheme of
Assistance document outlines application criteria detail in 2 Parts:-

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Argyll and Bute Council – Internal Audit Report – Private Sector Housing Grants and Adaptations
December 2022
 Part 1 – Those sections of the legislation relating to grants for adaptations. 
To meet the assessed needs of people with long term life limiting conditions, who are
living in the private sector and require adaptations to allow them to live in their homes
as independently as possible for as long as they choose to do so. 
Incorporated within Part 1 is the management of the contract for Argyll and Bute Care
and Repair Services relating to adaptations. 
 Part 2 – All other grant funding for private sector housing including, repair,
improvement, energy efficiency and empty homes grants. 
To address disrepair in private sector homes by encouraging home owners to recognise
that they have the primary responsibility for maintaining their properties. Limited
resources will be targeted at properties where there are common repair responsibilities
and empty homes. 
8. Argyll and Bute Council’s Housing Service will deliver both Parts 1 and 2 of the Scheme. It is
accountable to the Health and Social Care Integrated Joint Board for Part 1 and to the Council for
Part 2. 
9. Local Authorities receive Private Sector Housing Grant (PSHG) enables the Council to deliver
statutory disabled adaptations to private owners and also enables the Council to fulfill other
statutory functions in relation to common repairs as outlined within the Council’s Scheme of
Assistance. The amount of capital resources allocated to PSHG from 2016-17 to 2021-22 has
been £1.033m per annum, as per the General Capital Grant award however the 2021- 22
settlement reduced this to £0.941m. The Council, at its budget meeting on 24th February agreed
to fund the gap of £0.092m through borrowing for 2022-2025. 
10. The use of the PSHG is detailed in the table below: 
Scope 
11. The scope of the audit was to assess compliance with policies and procedures as outlined in the
Terms of Reference agreed with the Development Policy and Housing Strategy Manager on 21
September 2022.
Risks
12.  The risks considered throughout the audit were:
 SRR03: Financial Sustainability – Insufficient resource to meet current and future service
requirement. Budget not aligned/does not support business outcomes.
2016/17 2017/18 2018/19 2019/20 2020/21 2021/22
Advice and Prevention Cases Recorded 254 259 214 189 166 153
No of Grants Approved 243 181 219 232 138 208
Grant Approvals (£)k £1.192m £0.862m £1.048m £1.002m £687k £884k
New Applications Registered 239 189 240 234 131 218
Value of Payments  (£)k £1.454m £1.054m £0.980m £1.152m £0.421m £0.552m
Disabled Adaptations Grant Spend 
(DAG) £849k £640k £701k £764k £332k £503k
Common Repairs Spend £605k £414k £279k £388k £89k £49k
TOTAL £1.454m £1.054m £0.980m £1.152m £0.421m £0.552m

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Argyll and Bute Council – Internal Audit Report – Private Sector Housing Grants and Adaptations
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 ORR52: Housing Services Adaptation – various risks due to impact of Covid and materials
availability and price increases. 
 Audit Risk 1: Failure to deliver statutory functions
 Audit Risk 2: Failure to comply with established processes and procedures
Audit Opinion
13. 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.
14. Our overall audit opinion for this audit is that we can take a substantial level of assurance.  This
means that 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.
Recommendations
15. We have highlighted one medium priority recommendations and two low priority
recommendations where we believe there is scope to strengthen the control and governance
environment. These are summarised below:
 Procedure notes do not specify timescales for requests to record the Council’s interest
on beneficiaries’ title deeds nor the associated fees, which are to be processed after
final payment of grant. Procedure notes should include timescales and journals for
income should be credited to Legal Services and not via PSHG income code.
 The Scheme of Assistance does not contain up to date information and should be
updated after the outcome of the national policy review.
 Procedures and shared Documents should be updated to reflect current working
practices, which have evolved due to hybrid working arrangements and the digitalisation
of records. Consideration should be given to creating a checklist to promote consistency. 
16. 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
17. 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 The Council has a
Scheme of
Assistance that is
aligned to legislative
requirements, is up
Audit Risk 1 
SRR03
Unsatisfactory The Council has a Scheme of
Assistance that is aligned to legislative
requirements, which is publicly
available but is not up to date. 
The Council has volunteered to
participate in a review of the Scheme

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Argyll and Bute Council – Internal Audit Report – Private Sector Housing Grants and Adaptations
December 2022
to date and
publically available.
of Assistance, together Scottish
Government, Scottish Housing
Network (SHN) and other
stakeholders. On completion of this
review the Councils’ Scheme of
Assistance will be updated
An action with a target date of 2023,
is contained in the Local Housing
Strategy (LHS) 2022-2027, progress
toward this is reported annually to
Area Committees.
2 Applications and
referrals for
assistance are
assessed, processed
and recorded in line
with
procedures/guidance
Audit Risk 2 Unsatisfactory The Council has procedures and a
range of shared documents for staff in
relation to the PSHG. While the vast
majority of requirements are included
there would be benefit to updating
these to reflect current working
practices, which have evolved due to
hybrid working arrangements and the
digitalisation of records. 
Grant conditions require the Council’s
interest be recorded on beneficiary’s
title deeds. The procedure notes do
not currently specify a timescale for
requests to be passed to Legal
Services. There is evidence of delays
which creates a potential risk of loss
of ability to recover grant funds
should properties be sold or
conditions of grant breached.
Journals for the recording fees are
currently credited to a holding PSHG
income account code, not Legal
Services. 
Staff within the team are experienced
and so do not always refer to the
procedure notes. Consideration
should be given to creating a checklist
to act as an aide memoire and ensure
consistent application of processes. 
3 Grants, claims and
disbursements are
processed in line
with
procedures/guidance
and adequate
evidence of
expenditure is
ORR52
Audit Risk 2
Satisfactory There is clear evidence of separation
of duties at each stage of the process
with staff communicating and
working well together to confirm
tasks relating to the processing of
grants applications and payments are
dealt with timeously.
There are good record retention
processes.

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Argyll and Bute Council – Internal Audit Report – Private Sector Housing Grants and Adaptations
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provided and
retained.
There are some minor housekeeping
issues mainly related to either
procedure notes requiring to be
updated or location of documents,
this is covered in CO2 above. 
4 The PSHG funds are
appropriately
monitored and
reported to ensure
sufficient resources
are available to
those with needs. 
SRR03
ORR52
Satisfactory There is extensive monitoring and
reporting of the PSHG funds including
performance relating to those helped. 
The Council has a statutory duty to
produce a Local Housing Strategy
Annual update and to submit the
Housing Statistics Annual return.
Reports are provided to Full Council,
Area Committees, Strategic Housing
Forum and HSCP Strategic Planning
Group.
Internally, within Housing Services
there is evidence of meetings with all
levels of staff and budget monitoring
meetings with senior Financial
Services staff. 
18. Further details of our conclusions against each control objective can be found in Section 3 of this
report.  
3. Detailed Findings
The Council has a Scheme of Assistance that is aligned to legislative requirements, is up to date
and publically available.
19. The Council has a Scheme of Assistance that is aligned to legislative requirements, which is
publicly available but which does not contain up to date information. Together with Scottish
Government, Scottish Housing Network (SHN) and other stakeholders the Council has
volunteered to participate in a review of the Scheme of Assistance. In its Local Housing Strategy
(LHS) 2022-2027 action plan, the Council has published its commitment that the Scheme of
Assistance will be updated in 2023 following the national review.
Action Plan 2
20. The Councils Scheme of Assistance (SoA) which was introduced under the duties and powers set
out in the Housing (Scotland) Act 2006, and sets out the strategy of support for owners to
address properties which are Below Tolerable Standard (BTS) and in disrepair. Housing
Improvement Officers work with closely with private owners, landlords and relevant partners, to
address issues of poor property condition, common repair works, factoring, and, where
applicable, the use of enforcement powers. 
21. Assistance, advertised on the Council’s website, ranges from provision of advice and
information; to financial support to undertake disabled adaptations, common repair works, and
bring empty homes back into use. The SoA provides a platform to take a practical approach to
encourage and help owners to carry out repair and improvement works to their homes.

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Argyll and Bute Council – Internal Audit Report – Private Sector Housing Grants and Adaptations
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22. The Council has a statutory duty to provide a Housing Contribution Statement (HCS) for the
Health and Social Care Partnership (HSCP). The HSC has been included in the HSCP joint strategic
plan for 2022-2025 which was launched in June 2022.
23. The HSCP have lead responsibility for disabled adaptations and they provide information on
various types of Help at Home and in your community on their website. The majority of
applications for disabled adaptation grants are initiated by referrals from GPs to Occupational
Therapists (OT) who assess what adaptations are required to enable applicants to remain in their
own homes and prioritises these needs based on the Prioritisation of Needs Framework. The OT
then passes the referral and recommendations to Argyll and Bute Care and Repair (ABCR) who
generally act as agents for applicants during the grant application and works processes.  
24. Council Housing Services Officers who form the PSHG team hold team meetings to monitor all
aspects of the fund, including OT referrals and applications received from ABCR.  Minutes
provide evidence that there is an ongoing issue with recruiting OTs and that locums have been
used in some areas to gain coverage of service, which has led to an uplift in referrals. In order to
accurately monitor timescales between the various stages, Council officers have revised the OT
referral form to gather this information and assist in tracking the time between key dates.
25. We note the reduction in capital resources allocated from the General Capital Grant for Private
Sector Housing Grant (PSHG) and acknowledge the Council’s decision to fund the gap of
£0.092m through borrowing for 2022-2025.
Applications and referrals for assistance are assessed, processed and recorded in line with
procedures/guidance.
26. The Council has procedure notes for staff detailing the requirements at each stage of the
journey from referrals to applications for assistance to closure of files including records
retention. While the vast majority of requirements are included there would be benefit to
updating these to reflect current working practices, which have evolved due to hybrid working
arrangements and the digitalisation of records. 
27. Procedure notes state that staff should make folders and store information on their desktops.
The information is not accessible by other staff and this does not reflect Council policy that
information should be stored in the relevant drive/server on a Council maintained system. Team
Leaders have now made arrangements that documents are now stored on the relevant drive. 
28. There is a requirement to note the Council’s interest and specific conditions on beneficiaries’
title deeds in the land register upon completion of works. Requests should be sent to Legal
Services department to record the Notice of Payments (RNOP). The procedure note does not set
a specific timescale for these to be sent. Testing of grants found requests were not sent to Legal
Services at final payment, instead they ranged from 6 weeks up to 22 weeks. This creates a
potential financial risk of loss of ability to recover grant funds should properties be sold or
conditions of grant breached.

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Argyll and Bute Council – Internal Audit Report – Private Sector Housing Grants and Adaptations
December 2022
29. The fee for recording the Council’s interest on the title deeds is currently £80 and becomes due
on final payment of the grant. These fees are initially credited to a PSHG income account and not
directly to Legal Services cost centre. The amounts involved are not material in relation to the
PSHG budget, however, this may lead to reconciliation delays of PSHG budgets and forecasting
issues.
Action Plan 1 
30. The ABRITAS system is used to record all requests for information, advice given and practical
assistance grants provided. Post Covid, grant applications and supporting documentation are
now received by email, however this is not retained and sometimes documents are renamed
prior to uploading onto the ABRITAS system. A record preserving the email showing the original
grant application and supporting documents should be retained for the avoidance of doubt. 
31. A selection of 30 grants with a total value of £194, 000, representing 19% of the approved
budget allocation, were selected for testing. The receipt of electronic files has allowed staff in
different locations to process grant applications and approvals quickly once the correct
supporting documents have been supplied. When signing the application form, owners are
required to sign a declaration consenting to be bound by the conditions of the grant. 
32. Accurate decision notices were issued to all applicants within the sample reviewed and all
awards were appropriately authorised by relevant service staff. Minor issues that have been
classed as housekeeping issues have been shared with the team, these include inconsistent
application of what constitutes a valid application and the adding of notes/ documents to the
system. This is in part due to the fact the Council has to pay for document storage on ABRITAS so
some documents are stored elsewhere. Officers advised that they are in discussion with IT
regarding finding the most appropriate Document Management system. 
33. Staff within the team are experienced and so do not always follow the procedure notes when
completing tasks. When updating the procedure notes, consideration should be given to creating
a checklist to act as an aide memoire and promote consistent application of processes. 
Action Plan 3
34. Applicants or their agents receive two formal communications from the Council:
 An acknowledgement email confirming receipt of their application
 An Approval of application for grant assistance which is valid for 12 months from issue. 
35. Housing Improvement officers, for each area, monitor and follow up their own caseload getting
in touch with applicants and ABCR as necessary and provide updates at team meetings. 
Grants, claims and disbursements are processed in line with procedures/guidance and adequate
evidence of expenditure is provided and retained.
36. Grants awarded are based on the lowest estimate or quote supplied during a tender exercise.
The grant award letters issued state “The Council has decided to pay a grant of …” and restates
the conditions of the grant but there is no reference to this value being a percentage of the costs
nor does it state that the value awarded is dependent on actual costs. There is no requirement
for the applicant to acknowledge this.

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Argyll and Bute Council – Internal Audit Report – Private Sector Housing Grants and Adaptations
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37. All grant payments were made following either submission of an invoice from contractors or an
internal recharge to CARS. Payments were either made by single payment following completion
of work or by instalments at agreed project stages. Payment certificates evidenced that the sums
of the instalment(s) paid did not exceed the value of works carried out at time of payment. As
noted previously minor housekeeping issues relating to shared documents have been noted and
shared with staff. Officers have advised that shared documents will be updated as part of the
review of procedures. 
38. The payments are currently being treated as Zero rated for VAT purposes but based on advice
from the Council’s VAT team, the categorisation should be Out with Scope. Officers have advised
that procedures and payment certificates will be updated to reflect this. 
39. There is clear evidence of separation of duties at each stage of the process with staff
communicating and working well together to ensure tasks are dealt with timeously. 
40. Due to the grant conditions requiring that documents are retained for 10 years there are good
record retention processes. 
41. The Council does not carry out formal inspections and quality assessments of the work prior to
payment. In the case of Disabled Adaptation grants these are carried out by ABCR as part of their
contract with the Council, prior to them submitting the final request for payment. For all other
works reliance is normally placed on the beneficiary’s declaration that the works have been
carried out to their satisfaction. The note fields within the ABRITAS system is not consistently
updated to reflect this.  
Action Plan 3
42. End users are not currently asked to provide feedback on the grant process nor is there a
process requiring this. Officers advised that moving forward Satisfaction Surveys will be
incorporated into the Housing Communication Strategy.
The PSHG funds are appropriately monitored and reported to ensure sufficient resources are
available to those with needs. 
43.  The lead in time associated with grant works sometimes means that payments are made in
more than one financial year. As the PSHG is a capital budget there is an automatic carry-
forward in to the next financial year. Minutes of PSHG, Housing Management and Budget Holder
Engagement meetings were provided to demonstrate the active monitoring of the PSHG funds. 
44. There is extensive monitoring and reporting of the PSHG funds and performance towards LSH
outcomes, with reports provided to Full Council, Area Committees, Strategic Housing Forum and
HSCP Strategic Planning Group.  Additionally the PSHG contribution towards Conservation Area
Regeneration Schemes (CARS) funding has been presented to DMT and Policy and Resources
Committees. 
45. The Council has complied with its statutory duty to produce a Local Housing Strategy Annual
update and to submit the Housing Statistics Annual return.

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Appendix 1 – Action Plan 
No Finding Risk Agreed Action Responsibility / Due Date
Medium
2 Recording the Notice of Payments and associated fees 
There is a requirement to note the Council’s interest and
specific conditions on beneficiaries’ title deeds in the land
register. The procedure note does not set a specific
timescale for the request to be sent Legal Services to
record of the Notice of Payments (RNOP). 
The journal processing the recording fees should go
straight to Legal Services and not via a PSHG income code. 
Potential risk of loss of
ability to recover grant
funds.
Income not credited
directly to Legal
Services dept may lead
to reconciliation of
PSHG budgets and
forecasting issues
Procedure notes will be
reviewed and updated
and specific timescales
will be introduced for
requests and income
from recording fees to
be sent to Legal Services 
Team Lead  - Housing
operations 
31 March 2023
Low 
The Scheme of Assistance 
The Councils Scheme of Assistance (SoA) which was
introduced under the duties and powers set out in the
Housing (Scotland) Act 2006, and sets out the strategy of
support for owners to address properties which are Below
Tolerable Standard (BTS) and in disrepair does not contain
up to date information and should be updated after the
outcome of the national policy review. 
The public may not be
aware of the Councils
current Plans and
Strategies of support for
owners to address
properties which are
Below Tolerable
Standard (BTS) and in
disrepair. 
As per Local Housing
Strategy 2022-2027
Action Plan: 
The Scheme of
Assistance, will be
revised in 2023, after
the outcome of national
policy review on
adaptations.
Team Lead - Housing
Strategy 
31 December 2023 
Low
3 Procedure Notes and Shared Documents 
While the vast majority of requirements are included
there would be benefit to updating these to reflect current
working practices, which have evolved due to hybrid
working arrangements and the digitalisation of records.
Consideration should be given to creating a checklist to
ensure consistent application of processes. 
Processes may be
applied inconsistently. 
Procedures and
documents will be
reviewed and updated.
Checklists to be drawn
up and introduced
when updating the
procedures
Team Lead  - Housing
operations 
31 March 2023

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Argyll and Bute Council – Internal Audit Report – Private Sector Housing Grants and Adaptations December 2022
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 – Private Sector Housing Grants and Adaptations December 2022
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.