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

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Page 1

Argyll and Bute Council 
Comhairle Earra-Ghàidheal Agus Bhòid 
Executive Director:  Douglas Hendry 
Kilmory, Lochgilphead, PA31 8RT
Tel:  01546 602127  Fax:  01546 604435
DX 599700 LOCHGILPHEAD
12 December 2022 
NOTICE OF MEETING 
A meeting of the AUDIT AND SCRUTINY COMMITTEE will be held BY MICROSOFT TEAMS on
TUESDAY, 20 DECEMBER 2022 at 10:30 AM, which you are requested to attend. 
Douglas Hendry
Executive Director 
BUSINESS 
1. APOLOGIES 
2. DECLARATIONS OF INTEREST 
3. MINUTES 
(a) Minute of previous meeting held on 15 September 2022 (Pages 3 - 8)  
(b) Minute of the Special Meeting held on 22 November 2022 (Pages 9 - 12) 
AUDIT ITEMS 
4. INTERNAL AUDIT AND COUNTER FRAUD SUMMARY OF ACTIVITIES (Pages 13
- 20)  
Report by Chief Internal Auditor 
5. INTERNAL AND EXTERNAL AUDIT REPORT FOLLOW UP 2022-23 (Pages 21 -
50)  
Report by Chief Internal Auditor 
6. INTERNAL AUDIT REPORTS TO AUDIT AND SCRUTINY COMMITTEE 2022/23
(Pages 51 - 162)  
Report by Chief Internal Auditor   
 Externally Funded Projects 
 Heritage Assets
 Early Years
 Private Sector Grants and Housing Adaptations 
 Oban Airport 
 Live Argyll – Campbeltown Aqualibrium
Public Document Pack

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 Performance Management – HSCP
 Directions/Covid Inspection – HSCP 
 Commissioning - HSCP 
SCRUTINY ITEMS 
7. VERBAL UPDATE BY CHAIR(S) OF THE SCRUTINY PANEL(S) 
Verbal update by Martin Caldwell and Councillor Jim Lynch 
8. COUNCIL 6-MONTH PERFORMANCE REPORT - APRIL TO SEPTEMBER 2022
(Pages 163 - 178)  
Report by Executive Director with responsibility for Customer Support Services 
9. WORKPLAN (Pages 179 - 182)  
For noting and updating 
Audit and Scrutiny Committee 
Martin Caldwell (Chair) Councillor Daniel Hampsey
Councillor Graham Hardie Councillor Mark Irvine
Councillor Reeni Kennedy-Boyle Councillor Jim Lynch (Vice-Chair)
Councillor Andrew Vennard   
Shona Barton, Governance Manager 
Contact: Lynsey Innis, Senior Committee Assistant; Tel:  01546 604338

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MINUTES of MEETING of AUDIT AND SCRUTINY COMMITTEE held BY MICROSOFT TEAMS 
on THURSDAY, 15 SEPTEMBER 2022 
Present: Martin Caldwell (Chair) 
Councillor Daniel Hampsey
Councillor Graham Hardie
Councillor Mark Irvine 
Councillor Reeni Kennedy-Boyle
Councillor Jim Lynch
Councillor Andrew Vennard 
Attending: Anne Blue, Head of Financial Services
Jim Smith, Head of Roads and Infrastructure Services
Paul MacAskill, Chief Internal Auditor
Shona Barton, Committee Manager
Iain Jackson, Governance and Risk Manager 
Mhairi Weldon, Senior Accounting Assistant
Kyle McAulay, Audit Scotland 
1. APOLOGIES 
The Chair welcomed everyone to the meeting and took the opportunity to acknowledge
the death of Her Majesty, Queen Elizabeth II on Thursday, 8 September 2022.  The
Committee took a short pause for a moment of remembrance.   
There were no apologies for absence intimated.   
2. DECLARATIONS OF INTEREST 
There were no declarations of interest intimated.   
3. MINUTE OF PREVIOUS MEETING HELD ON 23 JUNE 2022 
The Minute of the previous meeting of the Audit and Scrutiny Committee, held on 23 June
2022 was approved as a correct record.   
4. INTERNAL AUDIT AND COUNTER FRAUD SUMMARY OF ACTIVITIES 
The Committee gave consideration to a report providing a summary of Internal Audit
activity and progress during quarter 2 of 2022/23 against the following areas: 
Audits Completed 
 Education Maintenance Allowance (EMA)
 Workforce Planning (HSCP) 
Audits in Progress 
 Early Years
 Heritage Assets
 Performance Management (HSCP) 
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 Externally Funded Projects
 Management of Debt and Debt Recovery
 Private Sector Gains and Housing Adaptations
 Performance Management (HSCP)
 Directions (HSCP) 
The report also included information on the work carried out by the Counter Fraud Team
(CFT) and provided an update on total billing to date as a direct consequence of their
work.   
Decision 
The Audit and Scrutiny Committee agreed to note and endorse the Summary of Activities
report.   
(Reference:  Report by Chief Internal Auditor, dated 15 September 2022, submitted) 
5. INTERNAL AND EXTERNAL AUDIT REPORT FOLLOW UP 2022-23 
The Committee gave consideration to a report providing an update on all open actions as
at 30 June 2022, including information on actions where the agreed implementation date
had been rescheduled. 
Decision 
The Audit and Scrutiny Committee agreed to endorse the contents of the report.   
(Reference:  Report by Chief Internal Auditor, dated 15 September 2022, submitted)   
6. INTERNAL AUDIT REPORTS TO AUDIT AND SCRUTINY COMMITTEE 2022/23 
The Committee gave consideration to a report containing the action plans in relation to the
following 2 audits:- 
 Education Maintenance Allowance (EMA)
 Workforce Planning - HSCP 
Decision 
The Audit and Scrutiny Committee agreed to note and endorse the summary report and
detail within each individual report. 
(Reference:  Report by Chief Internal Auditor, dated 15 September 2022, submitted) 
Councillor Daniel Hampsey joined the meeting at 10:51am during consideration of Agenda
item 6 (Internal Audit Reports to Audit and Scrutiny Committee 2022/2023). 
Having recognised the service and commitment of David Sullivan, Internal Auditor, the
Chair, on behalf of the Committee, took the opportunity to wish him a long and happy
retirement.  These sentiments were echoed by the Chief Internal Auditor, who wanted to
record his thanks to David for his help and assistance over the last few months.  
.
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7. EXTERNAL AUDIT UPDATE 
Consideration was given to a verbal update from Audit Scotland which outlined the
ongoing work in relation to the preparation of the Annual Accounts for both the Council
and Charitable Trusts, together with the process for the finalisation of the draft Annual
Audit Report.  An update was also provided on the process for the handover to Mazars,
who would be in place as the new Auditors from the year 2022/23, with it being noted that
Audit Scotland would work closely with them to ensure a well-managed transition and
smooth handover.   
Decision 
The Audit and Scrutiny Committee agreed to note the verbal update provided. 
(Reference:  Verbal Update by Audit Scotland) 
8. AUDIT AND SCRUTINY COMMITTEE ANNUAL REPORT 2021/22 
Consideration was given to a report providing the Chair of the Audit and Scrutiny
Committee’s annual overview of the Committee’s activity during the financial year 2021/22
and a summary of key developments since the commencement of 2022/23.  The report
also set out how the Committee had fulfilled its remit and provided assurances to the
Council.   
Decision 
The Audit and Scrutiny Committee:- 
1. Noted and endorsed the Chair’s Annual Report; and 
2. Agreed that the Chair present the report to the Council at its meeting on 25 November
2022.   
(Reference:  Report by Chair of the Audit and Scrutiny Committee, dated 15 September
2022, submitted)   
9. COUNTER FRAUD TEAM (CFT) ANNUAL REPORT AND UPDATE 2022 
Consideration was given to a report that provided an update on the progress of the two
year pilot Counter Fraud Team (CFT) established in September 2020.   
Decision 
The Audit and Scrutiny Committee:- 
1. Endorsed the contents of the Annual Report and progress of the Counter Fraud Team
since its inception in September 2020; 
2. Noted that the Executive Leadership Team (ELT) have agreed to make the posts
permanent; and 
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3. Noted that the future annual reporting relating to counter fraud will be included within
the Internal Audit Annual Report.   
(Reference:  Report by Chief Internal Auditor, dated 15 September 2022, submitted) 
10. STRATEGIC RISK ASSURANCE MAPPING 
Consideration was given to a report which set out Internal Audit’s assessment of the
sources of assurance for the Committee on the management of the Council’s strategic
risks.   
Decision 
The Audit and Scrutiny Committee:- 
1. Noted the risk assurance map at appendix 1 of the report; 
2. Considered the implications for audit and scrutiny coverage in the respective audit and
scrutiny annual plans, in particular the potential scrutiny review focusing on waste
management in 2023/24.   
(Reference:  Report by Chief Internal Auditor, dated 15 September 2022, submitted) 
As a result of technical difficulties, the Committee Manager advised that a short break
would be taken from 11:20am.  The meeting reconvened at 11:30am, with all those
present as per the sederunt.   
.
11. STRATEGIC RISK REGISTER 
Consideration was given to a report which provided an update on the Council’s Strategic
Risk Register (SRR). 
Decision 
The Audit and Scrutiny Committee agreed to endorse the updated Strategic Risk Register
(SRR), at appendix 1 to the report. 
(Reference:  Report by Chief Executive, dated 15 September 2022, submitted) 
12. CORPORATE COMPLAINTS ANNUAL REPORT 2021/22 
The Committee gave consideration to a report which provided information on how the
Council has dealt with complaints during the period between 1 April 2021 and 31 March
2022 and performed against the statutory indicators, which have been agreed between
the Scottish Public Services Ombudsman (SPSO) and the Local Authorities Complaint
Handlers Network.   
Decision 
The Audit and Scrutiny Committee considered and noted the content of this report. 
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(Reference:  Report by Executive Director with responsibility for Legal and Regulatory
Support, dated 15 September 2022, submitted)   
13. FREEDOM OF INFORMATION - ANNUAL REPORT 2021-22 
Consideration was given to a report which provided an update on the position regarding
the recording, responding to, monitoring and reporting of requests for information under
the Freedom of Information (Scotland) Act 2002 (FOISA) and the Environmental
Information (Scotland) Regulations 2004 (EIR’s) for the period between 1 April 2021 and
31 March 2022. 
Decision 
The Audit and Scrutiny Committee considered and noted the terms of the report. 
(Reference:  Report by Executive Director with responsibility for Legal and Regulatory
Support, dated 15 September 2022, submitted)   
14. SCRUTINY - IDENTIFICATION AND ASSESSMENT OF TOPICS 2022-23 
Consideration was given to a report which provided a summary of potential areas/topics
identified by Members in context of the Scrutiny Manual and Framework in order to take
forward as part of the Committee’s scrutiny role for 2022-23. 
Decision 
The Audit and Scrutiny Committee:- 
1. Considered the suggested topics identified in accordance with the agreed process of
assessment which is detailed in the Scrutiny Framework and Manual; 
2. Approved the commencement of a Scrutiny Review Panel in relation to Public
Consultations, to be led by the Chair, Martin Caldwell and the re-commencement of a
Scrutiny Review Panel to further consider Fly Tipping, to be led by Councillor Lynch; 
3. Agreed that Members should confirm to the Chief Internal Auditor within two weeks,
their preferences in relation to participation on the Scrutiny Review Panels identified;   
4. Agreed to obtain a further update in 2023/24 in relation to Waste Management to
ascertain how discussions and planned responses to risk have been taken forward by
the Council as discussions progress at a national level; and 
5. Noted that the Chief Internal Auditor would assist in finalising a ‘scope’ for the topics
with the Members leading the review once further discussion with relevant Senior
Managers takes place in order that resources be focused efficiently and effectively. 
(Reference:  Report by Chief Internal Auditor, dated 15 September 2022, submitted) 
15. WORKPLAN 
In order to facilitate forward planning of reports to the Audit and Scrutiny Committee,
Members considered the outline Audit and Scrutiny Committee workplan.   
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Decision 
The Audit and Scrutiny Committee agreed to note the outline workplan.   
(Reference:  Audit and Scrutiny Committee workplan, dated 15 September 2022,
submitted) 
.
The Committee resolved in terms of Section 50(A)(4) of the Local Government (Scotland)
Act 1973 to exclude the press and public for the following item of business on the grounds
that it was likely to involve the disclosure of exempt information as defined in Paragraph 6
of Part 1 of Schedule 7A to the Local Government (Scotland) Act 1973. 
.  
16. WASTE STRATEGY UPDATE 
The Committee gave consideration to a report which provided an update on the work
relating to the Waste PPP contract and the progress on the options appraisal workstreams
being taken forward by Caledonian Economics.  The report also set out updates on Barr
Environmental Limited, Renewi, the Scottish Deposit Scheme (DRS), the Scottish
Government’s Circular Economy Proposals and the Scottish Government’s Energy from
Waste Review. 
Decision 
The Audit and Scrutiny Committee:- 
1. Noted and considered the report and the approach being taken to determine the most
appropriate option for the Council regarding waste disposal; 
2. Noted the good progress being made in relation to the options appraisal; 
3. Noted that a further report detailing the full appraisal and proposed next steps will
come forward to the December EDI Committee, providing information on the preferred
option and outlining any capital and revenue cost implications.   
(Reference:  Report by Executive Director with responsibility for Roads and Infrastructure
Services, dated 15 September 2022, submitted) 
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MINUTES of the SPECIAL MEETING of the AUDIT AND SCRUTINY COMMITTEE held BY
MICROSOFT TEAMS 
on TUESDAY, 22 NOVEMBER 2022 
Present: Martin Caldwell (Chair) 
Councillor Daniel Hampsey
Councillor Graham Hardie
Councillor Mark Irvine 
Councillor Reeni Kennedy-Boyle
Councillor Jim Lynch
Councillor Andrew Vennard 
Attending: Kirsty Flanagan, Section 95 Officer/Executive Director
Anne Blue, Head of Finance
Paul MacAskill, Chief Internal Auditor
Shona Barton, Governance Manager
Mhairi Weldon, Senior Audit Assistant
Pauline Gillen, Audit Director, Audit Scotland
Kyle McAulay, Senior Audit Manager, Audit Scotland 
1. APOLOGIES FOR ABSENCE 
There were no apologies for absence intimated.   
2. DECLARATIONS OF INTEREST 
There were no declarations of interest intimated.   
3. 2021-22 PROPOSED INDEPENDENT AUDITORS REPORT 
The Committee gave consideration to a report outlining the unqualified opinion of the
External Auditors, Audit Scotland, on the audit of the financial statements.   
The Chair took the opportunity to thank Audit Scotland for their help and support over
recent years. 
Decision 
The Audit and Scrutiny Committee agreed to note the findings of the report.   
(Reference:  Report by Audit Scotland, dated 22 November 2022, submitted) 
4. 2021-22 ARGYLL AND BUTE COUNCIL - ISA 580 LETTER OF
REPRESENTATION 
Consideration was given to the ISA 580 letter of representation on the audit of the annual
accounts of Argyll and Bute Council for the year ended 31 March 2022.   
Decision 
The Audit and Scrutiny Committee:- 
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1. noted the contents of the ISA 580 letter of representation; and 
2. agreed to recommend to Council that the ISA 580 letter of representation be approved
for signing.   
(Reference:  ISA 580 Letter of Representation by Section 95 Officer, dated 24 November
2022, submitted) 
5. 2021-22 ARGYLL AND BUTE COUNCIL TRUST FUNDS - ISA 580 LETTER OF
REPRESENTATION 
The Committee gave consideration to the ISA 580 letter of representation in respect of the
registered charitable trusts, named below, for the year ended 31 March 2022.   
 McCaig Trust
 Marquess of Bute Silver Wedding Dowry
 Baillie Gillies Bequest
 Kidston Park Trust
 Miss Annie Dickson Bequest
 Logie Baird Prize Fund
 County of Argyll Educational Trust Scheme 1960
 Oban Common Good Fund 
Decision 
The Audit and Scrutiny Committee:- 
1. noted the contents of the ISA 580 letter of representation in respect of the registered
charitable trusts; and 
2. agreed to recommend to Council that the ISA 580 letter of representation in respect of
the registered charitable trusts be approved for signing.   
(Reference:  ISA 580 Letter of Representation in relation to Registered Charitable Trusts
by Section 95 Officer, dated 24 November 2022, submitted) 
6. 2021-22 AUDITED ANNUAL ACCOUNTS 
The Committee gave consideration to a report presenting the Audited Annual Accounts of
the Council and Charitable Trusts for the year to 31 March 2022. 
The Head of Financial Services provided an update in relation to the need for a slight
adjustment to the figures reported for the Oban Common Good Fund and outlined a
number of presentational adjustments that had been made, specifically in relation to the
Statement of Movement in Reserves.  Discussion was had in respect of the need to
incorporate the rate of inflation into the budget outlook specifically in relation to insurance
costs.     
The Chair took the opportunity to thank the Finance team for the provision of highly
informative management commentary and for their continued hard work in the provision of
the annual accounts. 
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Decision 
The Audit and Scrutiny Committee agreed to recommend to Council that the Audited
Annual Accounts of the Council and Charitable Trusts for the year to 31 March 2022 are
approved.   
(Reference:  Report by Section 95 Officer, dated 22 November 2022, submitted) 
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ARGYLL AND BUTE COUNCIL  AUDIT & SCRUTINY COMMITTEE   
FINANCIAL SERVICES  20 DECEMBER 2022  
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 three 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 two reviews
are postponed until 2023-24 for organisational reasons. 
 Individual Audits undertaken: Nine audits have been completed during
the period. Two audit has been assessed as providing high assurance,
seven as substantial assurance, none reasonable assurance and none as
limited assurance. (HSCP Audits provided for information only). 
 Counter Fraud: The Counter Fraud team 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. Two issues have been identified in quarter
two 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 Nine audits have been completed since the previous Committee in
September 2022. Three audits are currently in progress and will be to follow. 
Audits Completed 
 Performance Management (HSCP) – For Information Only
 Directions (HSCP) - For Information Only
 Commissioning (HSCP) - For Information Only
 Heritage Assets
 Externally Funded Projects
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 Early Years – Covid Funding
 Private Sector Grants & Housing Adaptations
 Oban Airport
 Campbeltown Aqualibrium   
Audits in Progress
reported to a future meeting of the Committee 
 Procurement
 Events Management
 Management of Debt & Debt Recovery
 Client Funds  
3.2 In addition to those already in progress indicative audits planned for Quarter 4
2022/23 are:  
3.3 2022/23 Audit Plan 
 Customer Service Centre
 Payroll
 Building Standards
 Cyber Security
 Burial Records
 Counselling in Schools
 Equality and Socio-Economic Impact Assessment  
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.   
Scrutiny  
3.5 Work has been completed on the 2021/22 scrutiny plan.  Scrutiny topics for the
2022/23 plan will cover consultations and a draft Terms of Reference has been
produced and the review team identified, the first meeting has been scheduled
in order to progress the review. This report will be reported back to a future
meeting of the Committee once it has been completed. Progress will also
shortly commence on residual follow up on the previous review on ‘Fly
Tipping’.     
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. Crucially, if no Counter
Fraud team had been in place then the reported instances of fraud would still
be taking place at a cost to the Council and public purse.
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3.7 The CFT have spent time on preparing ‘data uploads’ from the Council which
feed into the National Fraud Initiative (NFI) matching service, it is anticipated
that any matches will be provided to the team in January 2023 to allow work to
commence on following these up locally.   
Additional Updates from Quarter Two  
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 commenced and a
report will be submitted to a future meeting of this committee.  The annual
self-assessment is not required due to the external assessment taking place
and will resume in 2023 with a report submitted to this committee in
September 2023.     
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 two new findings
within the quarter that require to be reported. 
Table 2: Continuous Monitoring Findings 
Auditable
Area
Areas Tested Issues Identified Management
comment / action
Payroll
Expenses
Expenses are
appropriately
supported by
receipts
Claims are still being
approved without the
appropriate paperwork. 
This has been
highlighted to Creditors
and HR who have then
passed onto Payroll.
Payroll
Expenses
Claims for
expenses
incurred
greater than 6
months are
authorised by
Executive
Director
Claims over 6 months
old are still being
approved without
appropriate
authorisation.
As above 
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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 planned as a result of the report.  Table 2 details the national reports issued
during quarter one 2022/23.  
Table 3: National Reports 
National
Report
Issued
To
Detail Management response/ Action
taken
The
National
Fraud
Initiative in
Scotland
2022
Counter
Fraud
Team
The overall level of
identified public sector
fraud and error in
Scotland has fallen
slightly, according to
the results of a
national counter-fraud
exercise.
The Council continues to
demonstrate commitment to
counter fraud including investment
of time and effort into the NFI by
participating in the 2023/24
exercise.  High-risk matches will
continue to be prioritised in
accordance with the guidance
provided, however, matches
provided as a result of the NFI
exercise have often been identified
and resolved by officers prior to
being made available for review on
the NFI application. 
The Audit and Scrutiny Committee
continue to be updated on counter
fraud activities including progress
with the NFI exercise by way of
quarterly reports and an annual
report.  The self-appraisal checklist
has been completed and is
submitted as a separate paper to
this Committee for review.   
The Council’s Counter Fraud
Team have had a very successful
first two years and as a result no
specific areas for improvement
have been identified by local
auditors.
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Best Value
Assurance
Report
Shetland
Islands
Council
Chief
Executive
Shetland Islands’
leaders need to
increase their pace
and focus to deliver
urgent change.  The
Accounts Commission
is not confident the
Council is able to
show it is financially
sustainable.
This report was considered by
SMT 27 September where it was
agreed that no actions are
required.
Scotland’s
councils’
approach
to
addressing
climate
change
Executive
Director
Douglas
Hendry
Scotland’s councils
must put tackling
climate change at the
heart of decision-
making.
Councils have a
critical role in helping
Scotland achieve its
national climate
change goals, in
particular reducing
CO2 emissions and
adapting and
transforming services. 
Climate change must
be central and integral
to all council activity.
This report will be considered, in
the first instance, by the Climate
Change Board (CCB).  The CCB
will identify any steps which
require to be taken by the
Council.
Tackling
child
poverty
Chief
Officer
HSCP
Longer-term joint
planning is needed to
address child poverty
in Scotland, which has
increased since
targets were set in
2017.
Actions to tackle child poverty are
ongoing and co-ordinated via the
Argyll & Bute Child Poverty Action
Group. 
A report will be prepared to
provide information on local
actions and the Child Poverty
Action Plan Review 2021-22.
Best Value
Assurance
Report
Comhairle
nan Eilean
Siar
Chief
Executive
Councillors at
Comhairle nan Eilean
Siar must provide
leadership and clear
priorities if the
organisation is to
improve public
services and address
significant financial
and workforce
challenges.
This report was considered by
SMT in October where it was
agreed that the content was
useful but no actions are required. 
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National Fraud Initiative (NFI)  
3.14 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.  
3.15 The most recent cycle of NFI activity has now been concluded with the new
data set due to be available in January 2023. Therefore the usual table update
on matches progressed has been removed as there has been limited activity
since the last committee.  The table updating the committee on matches
progressed will be reinstated from the March 2023 meeting of the Committee
onwards.   
Internal Audit Development  
3.16 The table below details progress against the action points in our Internal Audit
development plan.  All items have been addressed and no additional items
have been added in quarter one.  
Table 4: Internal Audit Development Key Actions: 
Area For
Improvement
Agreed Action Progress
Update
Timescale 
Nothing outstanding.   
3.17 Internal Audit scorecard data is available on pyramid. The indicators reported
are aligned to those for internal audit in the Financial Services service plan.  All
indicators are shown as currently being on track.  
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Table 5: Internal Audit Team Scorecard  
Internal Audit Team Scorecard 2022– 23 – FQ2 22/23 (as at September 2022)
BO115 We Are Efficient And Cost Effective    
Internal Audit Level of Satisfaction
Actual  97% 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
5.5.3 Islands Duty – None
5.6 Climate Change – None 
5.7 Risk – None
5.8 Customer Service – None 
For further information please contact Internal Audit (01546 604108)
Paul Macaskill
Chief Internal Auditor
20 December 2022
Page 19

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Page 21

ARGYLL AND BUTE COUNCIL  AUDIT AND SCRUTINY COMMITTEE                                                            
FINANCIAL SERVICES  20 DECEMBER 2022 
INTERNAL AND EXTERNAL AUDIT REPORT FOLLOW UP 2022-23 
1.0 INTRODUCTION 
1.1 Internal and external audit reports include an action plan with a
management response establishing the agreed action, timescale and
responsible officer. Internal Audit record these in a database and, on a
monthly basis, follow them up to ensure they are being progressed. 
1.2 This report updates the committee on all open actions as at 30 September
2022 including information on actions where the agreed implementation
date has been rescheduled.   
2.0 RECOMMENDATIONS 
2.1 To endorse the contents of the report. 
3.0 DETAIL 
3.1 The two tables below provide a numerical summary of open audit actions
with a split between actions due by and due after 30 September 2022. 
Table 1 - Actions Due by 30 September 2022 
SMT/Service Complete Delayed/
Rescheduled
No
Response
Evidence
Required
Total
Internal Audit
CE – Financial
Services  
2 2 0 0 4
DH – Commercial
Services
2 1 0 0 3
DH – Legal &
Regulatory 
1 0 0 0 1
DH – Learning &
Teaching
0 1 0 0 1
DH – Lifelong
Learning &
Support
2 2 0 0 4
KF – Customer
Support Services
2 1 0 0 3
KF – Development 1 0 0 0 1
Page 21 Agenda Item 5

Page 22

& Economic
Growth
KF – Roads &
Infrastructure
Services
4 5 0 0 9
H&SCP (IJB) –
Adult Services
(Older Adults &
Community
Hospitals)
0 3 0 0 3
H&SCP (IJB) –
Finance &
Transformation
0 1 0 0 1
H&SCP (SW) –
Adult Services
(Mental Health
Learning Disability,
Addictions &
Lifelong
Conditions)
0 1 0 0 1
External Audit
Nil     
TOTAL 14 17 0 0 31 
Table 2 - Actions due after 30 September 2022 
SMT/Service Complete Delayed/
Rescheduled
No
Response
On
Course
Evidence
Required  Total
Internal Audit
CE – Financial
Services  
0 5 0 0 0 5
DH –
Commercial
Services
0 0 0 3 0 3
DH – Legal &
Regulatory 
0 0 0 4 0 4
DH – Learning
& Teaching
0 0 0 2 0 2
DH – Lifelong
Learning &
Support
0 0 0 1 0 1
KF – Customer
Support
Services
0 1 0 3 0 4
KF –
Development
& Economic
Growth
0 0 0 1 0 1
KF – Roads & 0 1 0 1 0 2
Page 22

Page 23

Infrastructure
Services
H&SCP (IJB) –
Adult Services
(Older Adults
& Community
Hospitals)
0 1 0 0 0 1
H&SCP (IJB) –
Strategic
Planning &
Performance
0 0 0 2 0 2
H&SCP (SW)
– Adult
Services
(Mental Health
Learning
Disability,
Addictions &
Lifelong
Conditions)
0 1 0 0 0 1
External Audit
Nil      
TOTAL 0 9 0 17 0 26 
3.2 Appendix 1 provides further detail on actions that have either been delayed
and rescheduled or for which Internal Audit have received no response
from the service to inform this follow up.
4.0 CONCLUSION 
4.1 Satisfactory progress continues to be made implementing audit actions
and we are pleased to note that we received responses from all those
contacted. 
5.0 IMPLICATIONS 
5.1 Policy - None
5.2 Financial - None
5.3 Legal - None
5.4 HR - None
5.5 Fairer Scotland Duty - None
5.5.1 Equalities – None
5.5.2 Socio-Economic Duty – None
5.5.3 Islands Duty - None
5.6 Risk –None 
5.7 Customer Service – None 
Page 23

Page 24

Paul MacAskill
Chief Internal Auditor
20 December 2022                                                  
For further information contact: Paul MacAskill, 01546 604108
Paul.macaskill@argyll-bute.gov.uk 
APPENDICES
Appendix 1 – Action Plan Points Delayed & Rescheduled or with No Response
Page 24

Page 25

Appendix 1 - Action Plan Points Delayed & Rescheduled or with No Response 
No Response 
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer 
Nil       
Action Plan Points Due by 30 September 2022 – Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer 
Financial Services
– Capital
Monitoring
Capital Programme
Training 
There is no training
programme to
support officers
involved in the
management of the
Council’s capital
programme. It
would be beneficial
to engage with
project managers
to identify training
needs and address
these through the
development of a
training programme
to help ensure a
consistent and
Medium Training
documentation to be
created that project
managers can refer
to. Refresher
training to be
provided for existing
Project Managers
and a plan put in
place for training for
any new staff that
have capital budget
monitoring
responsibilities.
30 June 2022 
30 September
2022
31 March 2023
While ongoing
training and support
has been provided
to project managers,
the creation of a
procedure manual
and upload of
training to LEON has
not yet happened
due to staff absence.
This outstanding
element of the action
will be progressed
over the coming
months. 
Delayed and
Rescheduled
Finance Manager Page 25

Page 26

Action Plan Points Due by 30 September 2022 – Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer 
robust approach to
capital project
management. In
particular this
should include
training on capital
project profiling.
Financial Services
– Systems
Interfaces &
Reconciliations
General Ledger
Reconciliations
There is no
reconciliation
performed between
the source system
and the general
ledger for
ResourceLink.
Medium Reconciliations will
be performed
following
consideration of data
and technical
requirements.
31 March 2021
31 December
2021
30 June 2022
30 September
2022
31 October 2022
Further work to be
completed to
produce a report
from Resource Link
and the new Oracle
Fusion system so
that the two systems
can be reconciled. 
Delayed and
Rescheduled
ResourceLink –
Pensions & Payroll
Officer
Commercial
Services –
Contract
Management –
Property Services
Concerto 
In order to present
cost KPI data the
Contract Manager
needs to extract
data from Concerto
and manipulate it in
Excel using pivot
tables. There
would be merit in
investigating
whether the
required KPIs can
VFM Investigate and
develop functionality
of Concerto as
necessary to
minimise data
manipulation and
therefore officer
time.
30 September 21
31 March 22 
30 September 22
31 December 22 
Delivery has been
materially affected
by property services
restructure as there
has been a
resignation and 2x
posts have been
changed who would
have delivered this. 
New post holders
appointed in late
summer 2022 and
investigation work
now underway to
Property
Maintenance
Manager
Page 26

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Action Plan Points Due by 30 September 2022 – Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer 
be generated via a
standard reporting
package rather
than through data
manipulation
although we
acknowledge there
may be a cost
involved in this
which would need
to be considered.
complete task.  New
timescale added. 
Delayed and
Rescheduled
Learning &
Teaching – ICT
Remote Working
Education
Management
Circular 1.18 – Use
of Internet and
Glow The circular
requires parental
consent for pupils
to access the
internet and
GLOW, however,
this form is no
longer required.
Low Education
Management
Circular 1.18 will be
updated to reflect
current
requirements.
31 August 22
31 October 22
There was a delay
due to change in
Education Manager.
Updated procedure
being presented to
Education
Management Team
on 18th October
2022 and will be
updated on website
by 31st October. 
Delayed and
Rescheduled 
Digital Lead –
Education
Lifelong Learning
& Support – Early
Learning &
Childcare Parental
Satisfaction
Parental
Engagement and
Home Family
Learning Strategy.
The overarching
Parental
Low Education staff will
undertake a review
of establishments to
confirm which have
a formal written
Parental
30 September 22
30 December 22
As part of the Early
Years Quality
Assurance visits, the
Early Years team
are undertaking
these checks. This is
(Acting) Education 
Manager 
Page 27

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Action Plan Points Due by 30 September 2022 – Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer 
Engagement
Strategy requires
that all ELC
establishments
develop and
publish their own
Parental
Engagement and
Home Family
Learning Strategy. 
Three of the four
establishments
reviewed were
unable to  provide
a copy of their
Parental
Engagement and
Home Family
Learning Strategy
Engagement and
Home Family
Learning Strategy in
place and support
development of one
if not in place.
to avoid additional
workload whilst
supporting settings
through
recovery. Each area
will update and
record this
information within
our EY drive. 
Delayed and
Rescheduled 
Lifelong Learning
& Support – Pupil
Work Placements
Reporting 
There are no
periodic
management
reports on pupil
work placements.
These would form
an important
understanding of
the success and
challenges of work
placements and
VFM Identify and agree
meaningful KPIs for
new service plan,
monitoring and
reporting. Implement
new KPI data
collection in schools.
Establish robust
reporting framework
including EMT and
CSC.
30 June 22
31 December 22
The precise means
of reporting to CSC -
whether as an
addition to an
existing report or as
a short separate
report - has still to
be finalised. Regular
reporting to EMT on
all aspects of
Developing the
Young Workforce,
including work
Head of Education -
Support & Lifelong
Learning
Page 28

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Action Plan Points Due by 30 September 2022 – Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer 
facilitate
discussions about
how to overcome
some of the
barriers which are
resulting in a
decreasing pool of
employers signing
up to the scheme. 
placements, is in
place. Consultation
with schools on KPIs
is in process and
also will be
complete, and KPIs
in place, before
Christmas. 
Delayed and
Rescheduled
Customer Support
Services –
Workforce
Planning
Monitoring
Strategic
Workforce Plan
Actions 
There is no
consolidated
process for
monitoring and
tracking the actions
agreed in the
Strategic
Workforce Plan
meaning it is
difficult to assess
progress toward
delivering it or its
impact. As the Plan
is due to be
refreshed in 2022 it
is not deemed a
Medium Include milestones
for progress
reporting in the
revised Workforce
Plan.
30 September 22
31 January 23
The HROD Manager
has been working
closely on the CEO's
Change Programme
and is now adapting
the draft SWFP to
reflect the agreed
priorities of the
Change Programme,
building on the
previous draft SWFP
that was considered
by ELT in July 2022.
This will be brought
forward to ELT in
November 2022 with
a final version now
targeted for
completion by Jan
2023. 
HROD Manager Page 29

Page 30

Action Plan Points Due by 30 September 2022 – Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer 
valuable use of
resource to
implement a
monitoring process
for the current
iteration of it
however this
should be
considered to
support the revised
plan.
Delayed and
Rescheduled 
Roads &
Infrastructure –
Street Cleaning
Partnership
Agreement 
Oban Business
Improvement
District (BID) has
agreed to fund an
additional seasonal
street sweeper
employed by the
Council. The street
sweeper has been
appointed through
the Council’s
recruitment
process, however
no formal
agreement is in
place and income
from BID has not
been received.
High Formalise
arrangements with
Oban BID for the
funding of the
seasonal street
sweeper
30 April 22
30 September 22
31 December 22
The partnership
continues to work
with the BIDS group
funding additional
street sweeping
services in Oban. 
Discussions are
ongoing with
colleagues in Legal
Services to establish
a partnership
agreement. 
Delayed and
Rescheduled 
Operations
Manager, Roads &
Infrastructure
Services 
Page 30

Page 31

Action Plan Points Due by 30 September 2022 – Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer 
Roads &
Infrastructure –
Street Cleaning
Updating of ELM 
Local Environment
Teams (LETs) are
not currently using
tablet devices to
indicate that work
allocated has been
completed.
Supervisors are
updating the
system in some
areas but this is not
consistent across
the Council.
Low Reintroduce use of
handheld devices
subject to ongoing
Covid restrictions
etc. to allow efficient
updates to ELM.
31 July 22
31 December 22 
We are experiencing
some hardware
problems and
access issues. 
Refresher training
has been arranged
and will take place
during the month of
October. 
Delayed and
Rescheduled 
Operations
Manager, Roads &
Infrastructure
Services 
Roads &
Infrastructure –
Street Cleaning
Recharging for
sweeping of
Council car parks 
The Council’s
income generating
car parks are
recharged for
street sweeping
according to
information
retained in work
schedules rather
than actual work
taking place,
additionally the
Council’s non-
VFM Ensure that timely
and accurate
recharges are
carried out and a
system in place to
ensure that this is
regularly taking
place.
31 March 22
30 June 22
30 September 22
31 December 22
A proposed
specification has
been forwarded to N
& S colleagues for
approval this
proposal makes the
necessary
amendments for the
service to be
delivered within
budget. 
Delayed and
Rescheduled 
Operations
Manager, Roads &
Infrastructure
Services
Page 31

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Action Plan Points Due by 30 September 2022 – Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer 
income generating
car parks are not
recharged for
sweeping.
Roads &
Infrastructure
Services – Warden
Services
Second Bin
Service Verification 
Wardens are
expected to verify
the veracity of
applications from
customers for a
second domestic
bin service. This
requires the
warden to confirm
that information
provided by the
customer is
accurate and
meets the defined
criteria. The
information
provided to
substantiate an
application can be
very personal and
sometimes of a
sensitive medical
nature. Wardens
have been asked
to provide this
High Review the process
for: 
Review the second
bins that are in place
and the process for
rationalising. This
review to also give
consideration to
composition and
identify opportunity
to increase recycling
and reduce general
waste.
30 September 22
31 December 22
The roads and
amenity
administration staff
have pulled together
the information in
relation to bins that
have been
approved.  We are
now in the process
of identifying those
who have received a
bin for medical
needs these will be
eliminated from the
future assessment of
those applicants
who will be invited to
re-apply.  This is in
line with the advice
received from the
governance team. 
The service are also
in the process of
drafting a new waste
policy to further
increase recycling
and reduce general
waste.
Operations
Manager, Roads &
Infrastructure
Services 
Page 32

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Action Plan Points Due by 30 September 2022 – Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer 
service but have
received no formal
training in how to
ensure a
customer’s dignity
is maintained or to
ensure they are
aware of the
requirements of
General Data
Protection
Regulation (GDPR)
in relation to
personal data for
this specific
process. 
Due to the
sensitivity of this
process, and the
potential risks
associated with
data protection it is
recommended that
the current
verification process
is reconsidered to
determine if it is
appropriate to
maintain it in its
current form. If it is
decided it should 
Delayed and
Rescheduled 
Page 33

Page 34

Action Plan Points Due by 30 September 2022 – Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer 
be retained then
there should be
engagement with
the Council’s
Governance and
Risk Manager to
ensure it is being
carried out in full
compliance with
GDPR.
Roads &
Infrastructure
Services – Fleet
Management
Driving Hours
Compliance 
Fleet drivers not
subject to EU
legislation maintain
manual driving
records which are
handed to
supervisors on a
weekly basis to
check and sign.
This is a resource
intensive process
which is subject to
human error. There
would be clear
process efficiency
gains and less risk
of error if the
Council adopted
the system already
Low The key officer will
ensure that all
drivers hold and use
tachograph cards to
move away from the
paper book records.
31 December 20
31 March 21
30 June 21 
31 March 22
30 June 22
31 August 22
31 March 23
Operation services
continue to use a
combination of
electronic cards and
hand filled forms, the
combination of these
systems ensures
compliance can be
monitored and the
ongoing interim
position pending a
final solution being
put in place. 
Delayed and
Rescheduled 
Procurement/Technical
Officer Page 34

Page 35

Action Plan Points Due by 30 September 2022 – Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer 
in place for fleet
drivers subject to
EU legislation and
rolled out electronic
driver cards to all
fleet drivers.
ADULT SERVICES
(OLDER ADULTS &
COMMUNITY
HOSPITALS) –
HSCP Care
Programme
Approach
CPA Training
There is no
programme of CPA
training available to
relevant HSCP
staff to ensure a
consistent
approach to CPA
service provision
across the HSCP.
High A training
programme will be
developed once key
service staff are
recruited.
30 September 22
28 February 23
A further delay is
required due to a
failure to recruit a
member of staff to
implement the
recommendation. An
offer has now been
made and accepted,
a start date has not
yet been confirmed.
End February 2023
now considered
realistic. 
Delayed and
Rescheduled 
Service Manager
ADULT SERVICES
(OLDER ADULTS &
COMMUNITY
HOSPITALS) –
HSCP Care
Programme
Approach
Client Records 
There is no
consistent agreed
process for
maintaining client
records, including
the recording and
sharing of
High HSCP expect to
transition to new
Eclipse system.
Implementation of
the new system and
associated
processes and
procedures will
address this
30 June 22
30 September 22
31 March 23 
A further delay is
required as the
Eclipse project
implementation has
been delayed. The
roll out of Eclipse is
now due to
commence in
January 2023.
Service Manager/
Eclipse Project
Manager 
Page 35

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Action Plan Points Due by 30 September 2022 – Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer 
information.  recommendation
and the Data Officer
will be involved in
the development of
processes and
procedures. 
Delayed and
Rescheduled 
ADULT SERVICES
(OLDER ADULTS &
COMMUNITY
HOSPITALS) –
HSCP Care
Programme
Approach
Carefirst 
Carefirst does not
have a specific
identifier category
for clients on the
CPA programme.
Carefirst will be
replaced by the
system Eclipse
system in June
2022.
Medium Service is moving to
Eclipse on June
2022, an identifier
category will be
included.
30 June 22
30 September 22
31 March 23 
A further delay is
required due to the
delayed
implementation
schedule for Eclipse.
Roll out Eclipse is
now expected to
commence in
January 2023. 
Delayed and
Rescheduled 
Service Manager/
Eclipse Project
Manager
Finance &
Transformation –
H&SCP –
Complaints
Handling
Training 
Training should be
provided in the
complaints
handling 
procedures for the
IJB
Low Complaints Handling 
Training will be 
incorporated into
staff  training
processes
30 September 22
30 November 22
This is now
complete in respect
of council
employees but still
to be confirmed in
respect of the NHS. 
Delayed and
Rescheduled 
Chief Nurse-NHS
Highland
Page 36

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Action Plan Points Due by 30 September 2022 – Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer 
Adult Services
(Mental Health
Learning Disability,
Addictions &
Lifelong
Conditions/CSWO
– SW – Charging
for Non-Residential
Care Services
Service Uptake
Data 
Records held on
Carefirst do not
allow for an
analysis of the
level of service
uptake compared
to those assessed
as having a need.
If this analysis
could be performed
it would help inform
discussions and
decisions in
relation to service
uptake, charges
and barriers to
uptake. 
It would be
advisable to
progress this issue
in conjunction with
the CareFirst
replacement
programme which
is scheduled to be
complete by April
2022.
VFM Recommendation
accepted. Further
discussion will be
held with supplier to
include service
uptake functionality
and reporting
capabilities on new
system from April
2022.
31 March 22
30 September 22
31 March 23
Further delay
required due to
Eclipse
implementation
being postponed to
Jan 2023. A phased
approach to roll out
of the new system
will be taken. 
Delayed and
Rescheduled 
Deputy Head of
eHealth HSCP 
Page 37

Page 38

Action Plan Points Due After 30 September 2022 - Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer /
Status
Financial Services
– Capital
Monitoring
Capital Programme
Planning &
Management
Guide The
Council’s Capital
Guide has not
been revised since
2018 and requires
a review to ensure
it reflects current
working practices
and provides
appropriate support
to officers involved
in the capital
monitoring
process. The
Council is currently
developing a new
Capital Strategy
which is to be
presented to the
Policy and
Resources
Committee in
August 2021 and
we recognise that a
review of the Guide
should be
conducted after the
Medium Capital Planning and
Management Guide
to be updated once
the Capital Strategy
has been approved
to ensure the two
are aligned and
provide clarity.
31 March 22
30 September 22
31 December 22
31 March 23
Similar to the FTPP
document, this is
dependent on the
completion of the capital
strategy which the Head of
Commercial Services has
advised will not be going
to P&R in October as
intended. Date of this has
been moved to 31st
March, however this will
be dependent on the
completion of the Strategy
in advance of this date to
allow time for this to be
progressed before the
March deadline. 
Delayed and
Rescheduled 
Head of
Commercial
Services/Finan
ce Manager
Page 38

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Action Plan Points Due After 30 September 2022 - Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer /
Status
Strategy has been
finalised to ensure
the two documents
complement each
other and. The
Guide could also
benefit from being
linked to, or
referencing, other
relevant Council
processes, in
particular the
Project
Management
section on the Hub.
Financial Services
– Fixed Asset
Register (AIRS)
Fixed Asset
Register
Reconciliation to
Service Records 
The exercise to
reconcile AIRS to
Concerto
commenced in
2017/18 was not
completed,
additionally, there
has been no
reconciliation to
other council
records to ensure
Medium Work with Property
Services to complete
reconciliation
between AIRS and
Concerto. Look at
other systems within
the Council to
identify any other
opportunities to
verify those assets
not categorised as
Operational Land &
Buildings.
31 December 22
31 March 23
Staff absence meant that
this could not be
progressed so was put on
pause. Work has now
began again with a revised
completion date of 31st
March. 
Delayed and
Rescheduled 
Accountant -
Capital
Page 39

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Action Plan Points Due After 30 September 2022 - Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer /
Status
that all assets held
by Council services
are included on
AIRS or removed
when no longer in
use or held as an
asset.
Financial Services
– Fixed Asset
Register (AIRS)
Asset Record
Maintenance 
There are
inconsistencies in
descriptions when
recording Council
assets across the
various systems
and asset
references are not
always available to
aid cross
referencing. This
results in difficulties
reconciling assets
held in service
records to the fixed
asset system
AIRS.
Medium Work with Property
Services and Fleet
to ensure systems
record the same
assets and refer to
references on other
systems.
31 December 22
31 March 23
Staff absence meant this
had to be put on pause but
work has resumed and will
be completed for 31st
March. 
Delayed and
Rescheduled 
Accountant -
Capital
Financial Services
– Following the
Public Pound
Guidance on
Following the
Public Pound
(FtPP) Although
High Following the Public
Pound guidance will
be drafted to provide
a consistent
30 June 20
31 December 20
30 June 21
31 December 21
Per previous updates, this
cannot be completed until
the Capital Strategy has
been completed.
Head of
Financial
Services
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Page 41

Action Plan Points Due After 30 September 2022 - Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer /
Status
the Council has an
approved process
to manage external
funding requests it
is limited in detail,
is not closely
aligned to the Code
of Guidance on
Funding External
Bodies and
Following the
Public Pound and
there is a general
lack of awareness
amongst officers
that it exists. Audit
testing identified a
number of areas of
good practice
within the Council
and overall
compliance with
the principles of
FtPP however
there were
examples of
inconsistent
practice. A more
comprehensive
guidance
document should
approach to
managing the award
of external funds.
30 September 22
31 December 22
31 March 23
Indications from the Head
of Commercial Services
are that the Strategy will
not be presented to P&R
in October as intended
therefore this has a knock
on effect to the completion
of this document. Date has
been amended to end of
March 2023, however this
again will be dependent on
the capital strategy being
completed. 
Delayed and
Rescheduled 
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Page 42

Action Plan Points Due After 30 September 2022 - Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer /
Status
be established
which provides a
more standardised
and tiered
approach providing
greater clarity over
roles and
responsibilities and
standardised
templates for key
stages in the
process including
funding
assessments and
post award
monitoring and
reporting. The audit
team researched a
number of
examples of FtPP
guidance which
had been created
by other councils
during the planning
phase of the audit
and can make
these available to
inform the creation
of an Argyll and
Bute equivalent.
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Action Plan Points Due After 30 September 2022 - Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer /
Status
Financial Services
– Purchasing
Cards
Inappropriate
authorisation of
transactions The
Support Officer in
the creditors’ team
approves a
considerable
number of pre-
authorised
transactions for
catering staff and
procurement staff.
Furthermore
creditors will also
approve any
outstanding
transactions for
other departments
to ensure that the
bank direct debit is
completed within
agreed timeframes.
Medium The wording of the
current monthly
email to cardholders
and approvers will
be updated to
remind them of their
responsibilities.
Once available, a
one page
procurement guide
will be issued to all
purchase card
holders and
approvers.
30 June 22
31 October 22
31 March 23 
There is a delay with the
changeover of the catering
cards but this issue wholly
lies with Brakes who are
having issues setting up
the change at their end –
as a result we only have
one catering card changed
over when we initially
expected all cards to be
over by Easter and then
summer break.  Brakes
are currently looking into
this at their end therefore
we are still using the
existing credit card system
for all other schools.  Both
the Creditors team and the
bank continue to engage
with Brakes on a regular
basis to try and progress
this as quickly as possible
but it is out with our
control. 
Delayed and
Rescheduled 
Creditors
Supervisor/Cre
ditors Support
Officer
Customer Support
Services –
Sickness Absence
Dedicated HR
Assistants 
VFM HR will review
attendance trends
and survey
30 June 21
31 December 21
31 March 22
Review will now be carried
out with paper to SMT in
December with data re
HR Team
Leader
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Page 44

Action Plan Points Due After 30 September 2022 - Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer /
Status
Development &
Infrastructure and
Education have a
dedicated HR
Assistant for
Attendance who
circulate reports on
a monthly basis to
the Heads of
Service. The HR
assistants provide
analysis and trends
over time on
sickness absence.
As there is no
mechanism in
place to assess the
impact of a
dedicated HR
assistant on levels
of sickness
absence it is not
possible to assess
whether they are
delivering value for
money.
Development &
Infrastructure and
Education services
to assess and report
to SMT on how
effective the
dedicated HR
assistants have
been to their service.
31 July 22
31 December 22 
absence cases supported
and outcomes. 
Delayed and
Rescheduled 
ROADS &
INFRASTRUCTURE
SERVICES – Fleet
Management
Management of
Pool Cars A high
level analysis of
the use of pool
cars suggests the
VFM The pool car module
will be released
through Tranman.
The pool car module
offers a centralised
30 September 20
31 December 20
30 June 21
31 December 21
30 April 22
Delayed and
Rescheduled 
Procurement/T
echnical
Officer
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Action Plan Points Due After 30 September 2022 - Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer /
Status
Council could
generate
considerable
savings through
more efficient use
of pool cars. Fleet
Services should
explore this further
via a more detailed
review which
should consider the
potential benefits
of: · a more
centralised
approach to the
administration and
booking of pool
cars.
approach to
bookings and
visibility. The
Council’s internal
communications
department will be
contacted to
highlight the use of
the pool cars. Work
will be undertaken to
increase usage.
29 July 22
30 September 22
31 December 22
ADULT SERVICES
(OLDER ADULTS &
COMMUNITY
HOSPITALS) –
HSCP Care
Programme
Approach
CPA Procedures 
There are no
agreed CPA written
procedures,
including client
assessment
processes, to
ensure a consistent
approach to CPA
service provision
across the HSCP.
High Processes and
procedures will be
developed across
Argyll & Bute to
improve consistency
and ensure service
provision is
appropriate across
the region. 
This is subject to the
recruitment of key
posts within the
30 June 22
31 December 22
28 February 23
Implementation has been
further delayed due to
inability to recruit a
member of staff to
complete the work. The
post has now been
offered, start date to be
confirmed. End February
2023 now a realistic
implementation date. 
Delayed and
Rescheduled
Consultant
Nurse
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Page 46

Action Plan Points Due After 30 September 2022 - Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer /
Status
service which are
currently vacant. 
ADULT SERVICES
(MENTAL HEALTH
LEARNING
DISABILITY,
ADDICTIONS &
LIFELONG
CONDITIONS/CSW
O) – H&SCP –
Impact of New
Legislation
NMAHP
Implementation
Group reporting 
The NMAHP
Implementation
Group is
accountable to the
NMAHP Workforce
Planning &
Development
Group, which in
turns reports to
NMAHP
Professional
Leadership
Committee and the
Programme Board. 
Risk 
There is a risk that
compliance with
the Staffing Act is
not being
monitored and
reported on with
sufficient
frequency, and
High Recommendation 
The NMAHP
Implementation
Group should
provide a work plan
and update reports
to the NMAHP
Workforce Planning
& Development
Group in accordance
with its Terms of
Reference. Required
actions arising from
the reports should
be clearly recorded
on the NMAHP
Implementation
Group’s action plan. 
Management Action. 
The NMAHP
Implementation
Group has been
disbanded. All
actions will be
picked up by the
NMAHP Oversight
31 May 21
30 June 22
31 December 22
1 April 24
Nursing aspect complete.
AHP aspect with NHS
Highland for consideration.
Legislation now expected
to come into force in April
2024 (link provided below) 
https://www.rcn.org.uk/sco
tland/Influencing-On-Your-
Behalf/SafeStaffingScotlan
d. 
Delayed and
Rescheduled 
Lead Nurse
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Page 47

Action Plan Points Due After 30 September 2022 - Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer /
Status
appropriate actions
are not being taken
where necessary. 
The NMAHP
Implementation
Group’s Terms of
Reference states
that the group will
provide an annual
work plan and bi-
monthly update
reports to the
NMAHP Workforce
planning &
development group
in respect of: 
• Adherence to the
Common Staffing
Methodology 
• Completion of
establishment
reviews (following
SOP for
establishment
reviews) for all
clinical areas with
access to validated
Group. This group
will report on actions
to the IJB to provide
the requisite
assurance.
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Page 48

Action Plan Points Due After 30 September 2022 - Delayed & Rescheduled/Evidence Required
Service / Report Finding Priority Agreed Action Dates Comment Responsible
Officer /
Status
tools by February
2020 
• Develop schedule
for annual tool run
to be implemented
from 2020 
• Development of a
Risk Register 
• Development of
an Issues Log 
• Monitoring
monthly any
change to current
establishments 
However, whilst
some oral updates
have been
provided at
meetings of the
NMAHP Workforce
Planning &
Development
Group, the reports
have not been
provided to the
group.
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Page 51

ARGYLL AND BUTE COUNCIL  AUDIT AND SCRUTINY COMMITTEE 
FINANCIAL SERVICES  20 DECEMBER 2022 
INTERNAL AUDIT REPORTS TO AUDIT AND SCRUTINY COMMITTEE 2022/2023 
1. EXECUTIVE SUMMARY 
1.1 There are Nine audits being reported to the Audit and Scrutiny Committee.     
1.2 The table below provides a summary of the conclusions for the audits performed.
The full reports are included as appendices to this report. 
Audit Name Level of
Assurance
High
Actions
Medium
Actions
Low
Actions
VFM
Actions
Externally Funded
Projects
Substantial 0 2 1 0
Heritage Assets Substantial 0 1 5 0
Early Years High 0 0 0 0
Private Sector Grants &
Housing Adaptations
Substantial 0 1 2 0
Oban Airport High 0 0 0 0
LiveArgyll -
Campbeltown
Aqualibrium
Substantial 0 1 0 0
Performance
Management – HSCP
(Part of the HSCP
Internal Audit Plan and
presented for
information only)
Substantial 0 1 0 0
Directions – HSCP
(Part of the HSCP
Internal Audit Plan and
presented for
information only)
Substantial 0 3 0 0
Commissioning –
HSCP
(Part of the HSCP
Internal Audit Plan and
presented for
information only)
Substantial 0 0 0 0 
1.3 Internal Audit provides a level of assurance upon completion of audit work. A
definition for each assurance level is documented in each audit report. 
2. RECOMMENDATIONS 
2.1 Audit and Scrutiny Committee to review and endorse this summary report and the
detail within each individual report.
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Page 52

3.  DETAIL 
3.1 A high level summary of each completed audit report is noted below: 
Externally Funded Projects-Rothesay Pavilion: This audit has provided a
Substantial level of assurance. This means internal control, governance and the
management of risk is sound, however, there are minor areas of weakness which
put some system objectives at risk. Terms and conditions are in place for all
external funders. Extensive use of external funders was noted. Internal audit
took assurance from an external review of European Union (EU) carried out by
the Scottish Government. A grant claim for £308k is outstanding from European
Regional Development Fund (ERDF) dating back to April 2021. Comprehensive
highlight reports are produced on a regular basis by the project manager which
covers all issues pertinent to the project. Regular meetings are held with external
funders and chaired by the Head of Commercial Services. Updates to Council
committees are provided periodically on the matter of ongoing developments
and financial position relating to the Rothesay Pavilion. 
Heritage Assets: This audit has provided a substantial level of
assurance.  Internal control, governance and the management of risk is sound,
however, there are minor areas of weakness which put some system objectives
at risk.  Asset management documentation is approved annually by Council and
heritage assets values are correctly reflected on the Council’s Annual
Accounts.   Heritage assets are appropriately managed and insured with the
exception of archive documents that are considered to be of value.  Detailed
records of assets are held within each area of responsibility, however, 6
artworks were omitted from the Argyll collection record and 4 of the 11 artworks
and one located at another authority recorded as missing had not been updated
when recovered/located.  Museum exhibits and artworks on display are
available to view during premises opening hours and items in storage areas are
secure, however, in some cases the artworks are inappropriately stacked
against each other.  Civic chains and archive documents are secured in council
accommodation and made available for use by prior arrangement.  Elements of
the collections can be accessed digitally by members of the public from their
personal devices, however there is no access to historical archive records by
this means.  Most of the collections are subject to periodic or ad-hoc
inspections, however, these are not always recorded.  The Argyll Collection is
not currently rotated around schools and is not inspected unless loaned to
external organisations who will check the condition of the artwork.  Heritage
assets are recorded as fixed assets on the Council’s fixed asset management
system, AIRS, however there was no inclusion of the civic chains nor any
archive documents considered to be of value. 
Early Years: This audit has provided a High level of assurance. This means
that 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.   
The Covid recovery funding provided the Early Years team with the ability to
bring forward a future planned project to support effective transitions into
Primary School. Management were able to react quickly by redeploying
resources already within the team to create the 12 month secondment for the
Education Support Officer (ESO) Transitions post, which has assisted them in
developing plans and taking action to embed play-based pedagogy in early
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Page 53

primary and creating the Argyll and Bute Play Pedagogy Network on Google
classroom. This allows teachers to share good practice across the authority and
as mechanism for the ESO to deliver network sessions, post Career-long
Professional Learning (CLPL) webinars and provide participants with up to date
literature / blogs etc. about play. There is good evidence of engaging with staff
and using feedback to tailor materials and help shape training and development
and identify a key Improvement Outcome for future year’s transitions. The
Scottish Government required only minimal reporting which the Council has
complied with. 
Private Sector Grants & Housing Adaptations: This audit has provided a
substantial level of assurance.  Internal control, governance and the
management of risk is sound, however, there are minor areas of weakness
which put some system objectives at risk. The Council has volunteered to
participate in a review of the Scheme of Assistance an action with a target date
of 2023, is contained in the Local Housing Strategy (LHS) 2022-2027.
Applications and referrals for assistance are assessed, processed and recorded
in line with procedures. There would be benefit to updating the procedures to
reflect current working practices, which have evolved due to hybrid working
arrangements and the digitalisation of records. Grants, claims and
disbursements are processed in line with procedures and adequate evidence of
expenditure is provided and retained. 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.
There is extensive monitoring and reporting of the PSHG funds including
performance relating to those helped.   
Oban Airport: This audit has provided a High level of assurance. This means
that 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.   
This audit covered 5 of the 22 operating instructions within the aerodrome
operating manual and all were found to be satisfactory. The Manual is updated
on an annual basis and no audit issues were raised. 
Campbeltown Aqualibrium This audit has provided a substantial level of
assurance. This means that internal control, governance and the management
of risk are satisfactory and any issues identified can be managed through a
programme of works. It was noted during the visit that water ingress was evident
in some areas of the building and although these had been reported and in some
cases repaired to some degree more permanent repairs are required to maintain
functionality in all areas and minimise the risk to staff and customers who use
the facility. Management have outlined that all agreed maintenance protocols
had been adhered too and that water ingress issues have regularly reported and
these will in part be dealt with as part of the Asset Management Plan. 
Performance Management – HSCP (for information only): This audit has
provided a substantial level of assurance. This means internal control,
governance and the management of risk is sound, however, there are minor
areas of weakness which put some system objectives at risk. There has been a
moving theme in the type and approach to performance management this has
been largely due to the Covid pandemic. Performance reporting during the
pandemic focussed on addressing the re-mobilisation of services. This new
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approach was per the guidance from the Scottish Government and was based
upon 6 priority areas. A revised Integrated Performance Management
Framework (IPMF) is currently being prepared and will focus on eliminating long
waits in both inpatient and outpatients services. Performance targets during
COVID were set at 70%-80% of the 2019/20 service activity as at November
2021. Targets were agreed with the Scottish Government. Performance
reporting will be based upon a revised set of targets that reflect priorities going
forward. Performance is regularly reported to the Integrated Joint Board (IJB) at
their bi-monthly meetings. Health and Social Care Partnership (HSCP)
performance information should be made available on the Councils
performance information system. A comprehensive annual report for 2020-21
which includes a summary of performance against targets has been published. 
Directions – HSCP (for information only): This audit has provided a substantial
level of assurance. This means internal control, governance and the
management of risk is sound, however, there are minor areas of weakness which
put some system objectives at risk.  A strategic Commissioning Plan has been
published in accordance with Scottish Government Guidance, however, a
Directions Policy has not yet been prepared.  Directions issued are clearly
aligned to this plan and include all functions delegated to the IJB along with the
allocated financial resources.  Directions are promptly issued and a log is
maintained, however, the log does not indicate the current status/progress in
implementing the content of the directions issued, nor is this progress reported
to the IJB committee as part of the quarterly performance updates.  The budgets
allocated to functions as a result of the budget proposal directions are monitored
via budget monitoring reports. 
Commissioning – HSCP (for information only): This audit has provided 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. Whilst the risks of commissioned providers withdrawing
from the market can never be fully mitigated, working together the HSCP and
the Council’s procurement team have put in place measures to minimise the risk
and impact of commissioned service providers withdrawing from the market. 
Taking a risk based approach, prior commissioning with a provider for services,
numerous checks are undertaken. The Scottish Government and COSLA jointly
published guidance on the Procurement of Care and Support Services, in line
with the guidance, the first HSCP Joint Strategic Commissioning Strategy for
everyone in Argyll and Bute who require health and social care services was
approved in March 2022. In addition, the Council have well established
procurement policies and procedures in place. A Procurement Strategy and The
Procurement Manual are the overarching documents applicable to Council staff
involved in the procurement process. The Council’s procurement staff work
alongside HSCP staff to ensure that ongoing monitoring is undertaken with
regular meetings held with providers, HSCP staff, the Care Inspectorate where
appropriate and Council procurement staff. A review of performance and
assessment of value for money forms part of the process of ongoing regular
meetings with suppliers. Measures are in place to minimise the impact of
commissioned service providers withdrawing from the market. The HSCP
guidance document: “Guidance for Closure of a Care Home”, is guidance for
the closure of a Care Home. The purpose of this document is to provide
guidance for the HSCP to identify and manage any possible risks and ensure
continuity of service provision in the event of a planned or unplanned closure of
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a Care Home. 
4. CONCLUSION 
4.1 Management has accepted each of the reports submitted and have agreed
responses and timescales in the respective action plans. 
5. IMPLICATIONS 
5.1 Policy - None
5.2 Financial - None
5.3 Legal - None
5.4 HR – None
5.5 Fairer Scotland Duty - None
5.5.1 Equalities – None
5.5.2 Socio-Economic Duty – None
5.5.3 Islands Duty – None
5.6 Climate Change – None 
5.7 Risk - None
5.8 Customer Service – None 
Paul Macaskill
Chief Internal Auditor
20 December 2022 
For further information contact: 
Paul Macaskill, Chief Internal Auditor
Tel:  01546 604108
Email: paul.macaskill@argyll-bute.gov.uk 
APPENDICES 
1. Externally Funded Projects
2. Heritage Assets
3. Early Years
4. Private Sector Grants and Housing Adaptations (To follow)
5. Oban Airport 
6. Campbeltown Aqualibrium
7. HSCP – Performance Management
8. HSCP – Directions
9. HSCP - Commissioning 
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Argyll and Bute Council
Internal Audit Report
November 2022
FINAL 
High Medium Low VFM
Number of
Findings
0 2 1 0 
Externally Funded Projects-
Rothesay Pavilion
Audit Opinion: Substantial 
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2 
Argyll and Bute Council – Internal Audit Report – Externally Funded Projects, November 2022 
Contents 
1. Executive Summary ........................................................................................................................ 3
Introduction ............................................................................................................................................ 3
Background ............................................................................................................................................. 3
Scope ....................................................................................................................................................... 4
Risks ........................................................................................................................................................ 4
Audit Opinion ......................................................................................................................................... 4
Recommendations ................................................................................................................................. 4
2. Objectives and Summary Assessment ........................................................................................... 5
3. Detailed Findings ............................................................................................................................ 5
Appendix 1 – Action Plan ..................................................................................................................... 11
Appendix 2 – Audit Opinion ................................................................................................................. 13 
Contact Details 
Internal Auditor: Paul Macaskill 
Telephone:  01546 604108 
e-mail:   paul.macaskill@argyll-bute.gov.uk 
www.argyll-bute.gov.uk
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3 
Argyll and Bute Council – Internal Audit Report – Externally Funded Projects, November 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 Externally Funded Projects-Rothesay Pavilion.
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. The refurbishment of the Rothesay Pavilion is the final project in the Councils’ plans to assist
regeneration and economic development in its 5 waterfront towns namely Campbeltown,
Helensburgh, Oban, Rothesay and Dunoon.  The strategic aim of the project is to bring the
building back into economic use by allowing a mix of new commercial, cultural and community
activities to be provided within it that will stimulate local economic activity and contribute to the
wider regeneration of Rothesay.
5. The contract commenced on site on 29th November 2017 and was initially scheduled for
completion in 87 weeks with a contractual completion date of 31st July 2019.  As a result of
works variations in the contract, this was extended with a proposed final handover in February
2020.  However, due to the administration of the main contractor CBC Glasgow the project is
currently being re-assessed and a completion date has yet to be finalised.
6. The Rothesay Pavilion full business case under section 1.7 emphasised  the requirement for
external funding to enable the project to go ahead and consequently a number of external
funders were identified by the Council namely:
Name Amount
Heritage Lottery fund(HLF) £4,187,500
HLF-Volunteer Input £50,900
European Regional Development Fund (ERDF) £1,055,602
Highland and Islands Enterprise(HIE) £750,000
Regeneration Capital Grant Fund £625,000
Coastal Communities Fund £600,000
Historic Environment Scotland £750,000
West Coast Foundation £116,957
Scottish Landfill Communities Fund £20,000
Total £8,155,959 
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4 
Argyll and Bute Council – Internal Audit Report – Externally Funded Projects, November 2022
7. All external funders provide a grant offer letter to the Council which sets out the terms and
conditions that the Council should meet in order to satisfy the grant requirements.
Scope 
8. The scope of the audit was to assess the Councils compliance with the terms and conditions as
specified by the external Fund providers as outlined in the Terms of Reference agreed with the
Head of Commercial Services on 24th June 2022.
Risks
9.  The risks considered throughout the audit were:
 Audit Risk 1: the council does not have an agreed offer letter in place from external
providers specifying terms and conditions
 Audit Risk 2:the council does not have procedures/processes in place to ensure that
grant requirements are met
 Audit Risk 3: the Council has failed to ensure compliance with the requirements
stipulated within grant letters
 Audit Risk 4: the council does not have reporting arrangements in place to appropriate
Council bodies in order to provide assurance that grant requirements are met  
 Audit Risk 5: Reputational risk to the Council.
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 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
12. We have highlighted two medium priority recommendations and one low priority
recommendations where we believe there is scope to strengthen the control and governance
environment. These are summarised below:
 outstanding grant claims should be followed up timeously;
 action plan should be prepared to determine the extent of completion of project that
can be achieved based on available funding;
 consideration should be given to reviewing extensive use of external contractors
13. 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.
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5 
Argyll and Bute Council – Internal Audit Report – Externally Funded Projects, November 2022
2. Objectives and Summary Assessment
14. 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
CO1 The Council has
procedures/processes
in place to ensure
compliance with
grant letter terms and
conditions
Audit Risk 1
Audit Risk 2 
Reasonable All external funders have issued a
grant letter outlining the terms and
conditions attached to funding.
T&C’s have been agreed by the
Council. Risk registers are in place
that identifies risk in relation to
funders with mitigation actions
specified. Extensive use of external
contractors was noted.
CO2 Procedures/processes 
to ensure compliance
with grant offers
conditions are
applied 
Audit Risk 3 Substantial Internal audit took assurance from
the external review carried out by
the Scottish Government that the
Council were compliant with EU
funding guidelines in regard to
funding from European bodies. A
grant claim submitted to ERDF for
£308k is outstanding dating back to
April 2021. 
CO3 There are appropriate
reporting
arrangements in
place to Council
bodies to provide
assurance that grant
terms and conditions
are met
Audit Risk 4 High Comprehensive highlight reports are
produced on a regular basis by the
project manager which covers all
issues pertinent to the project
including compliance with external
funding requirements. Regular
meetings are held with external
funders and chaired by the head of
commercial services. Updates to
Council committees are provided
periodically. Financial services issue
regular updates on the capital spend
of the project. Action plan to
determine the extent of completion
of project that can be achieved
based on available funding should
be prepared. 
15. Further details of our conclusions against each control objective can be found in Section 3 of this
report.  
3. Detailed Findings
The Council has procedures/processes in place to ensure compliance with grant letter terms and
conditions
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16. The Principal Contractor, Central Building Contractors (Glasgow) Ltd (CBC), was placed in
Administration by its’ Board of Directors, and this was formally notified to the Council on 29
April 2020.  At the Policy and Resources committee dated 9th December 2021 it was decided to
'pause' the Rothesay Pavilion Project due to a forecast of a significant funding shortfall to
complete the works, with various follow on actions agreed for Elected Members and Officers to
progress to try to close the 'gap'.
17. Included within the funding shortfall is the financial risk of circa £6.85M which is the value of
external funding thus far claimed against the capital costs of the project, and which funder’s may
seek to recover if the Rothesay Pavilion project is not satisfactory concluded in regard to funding
requirements.
18. The majority of the capital funding is being provided by the Council (41%) and the Heritage
Lottery Fund (HLF) (30%) respectively.  The capital grant awards include standard and specific
terms and conditions that are required to be met in delivering the project by the Grantee/s (i.e.
Council and the Rothesay Pavilion Charity (RPC)).  The terms and conditions include delivery of
approved purposes and activities, performance reporting and monitoring, governance processes,
and completion/evaluation reports.
19. All External funders have issued a grant letter to Argyll and Bute Council that sets out the terms
and conditions (T&C’s) that the Council should meet.  The standard T&C’s are applicable in the
event of specific circumstances such as :
 the Grantee commits a default;
 the funder considers that any change or departure from the purposes for which the
grant is awarded warrants an alteration to the amount of the grant; 
 failure to carry out the project;
 progress of the project is not satisfactory; 
 fraudulent and/or negligent activity incorrect or misleading information; 
 future of the project is in jeopardy;
 grantee’s change in status i.e. insolvency or winding up
 disposal of asset: subject to prior written consent up to 15 years. Permission is
dependent on: the Grantee pays a share of the net proceeds and the sale must be at full
market value
 the terms and conditions will be applicable from between 6 to 10 years. 
20.  Specific terms and conditions are split between those expected to be met by the Council and
those expected to be met by the Rothesay Pavilion Charity (RPC).  As regards the specific
requirements of the Council each of the funders has a requirement for the Council to deliver
against the specified approved purposes and benefits.  These can be summarised as follows:
 repair of the historic fabric of Rothesay Pavilion;  
 upgrade of main auditorium to support events programme and to create 3 nos. business
units: Café/Bistro. 2 nos. bars and shop/box office; 
 creation of new community facilities including music rehearsal and recording space, a
second venue with independent entrance targeted at young people, function rooms
including new roof top multi-purpose space; 
 new exhibition space with high quality permanent and temporary exhibition space for
changing programmes; 
 heritage interpretation space for display; 
 refurbishment of the Caretaker’s House to provide offices for local SMEs;
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 community Arts projects – Video & Photographic record of interviews; film and creative
skills weekends; 
 creation of a historic archive; 
 marketing and Communications: increased community engagement through
development workshops with Schools and improvement in visitor offer; 
 heritage interpretation space: design & themed content.
21. Both the Highlands and Islands Enterprise Board (HIE) and European Regional Development Fund
(ERDF) have specified a number of defined benefits which are summarised below namely:
 enhanced community venue; 
 one income generating asset; 
 £287k per annum increase in turnover in the social economy;
 14 full time equivalent jobs; 
 30 volunteers engaged with project delivery; 
 40 people accessing training; 
 40 community groups increasing their capacity through engagement with pavilion
activities; 
 2 organisations supported to deliver growth aspirations
22. The project manager prepares a regular ‘Highlight’ report on the ongoing status of the Rothesay
Pavilion Project.  The report includes under section 7 an update on the current risks associated
with the project including the following :
 Identifies the  risk
 assess the likelihood and impact of the risk
 prioritise the risks (red, amber or green)
 How the Council will mitigate and manage the risks identified.
Commercial Services also identified within their overall risk register the risk of “unavailability of
internal capital funding” for all projects including Rothesay Pavilion and prioritises the risk as
“red” with mitigation actions including ensuring resources are available to complete projects.            
23. The project includes a full time project manager as well as support from a variety of internal
Council bodies such as Legal and Planning and administration and external bodies such as design
and conservation architects.  The initial project manager left 5 months into the construction
period in May 2018 and a new project manager was recruited in August 2018.  Strategically the
project was managed internally by the council’s project manager, however, in terms of day to
day activities and implementation there was a heavy reliance on external consultants and
contractors.  Consideration should be given to reviewing the extensive use of outside
contractors as opposed to investing in in-house resources in regard to major capital projects
especially in light of the projected overspend on the project.
Action Plan 3          
Procedures/processes to ensure compliance with grant offers conditions are applied
24. Due to the Scottish Government (SG) being ultimately responsible for ensuring that EU funded
projects are properly administered a review was undertaken by the SG the on behalf of HIE and
ERDF during the 1st Quarter of 2021 i.e. post the administration of the main contractor.  (Note
:EU funding represents 21% of total external funding) The review was termed a “stage 2 on the
spot verification” which included the following :
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Argyll and Bute Council – Internal Audit Report – Externally Funded Projects, November 2022
 the eligibility, status and outcome of participants/businesses (where applicable);
 the expenditure declared and the existence and compliance of the audit trail for a
number of expenditure items (involved checking 23% by value of all claims made by the
Council); 
 the outputs and/or achievements linked to the operation(s);
 the compliance with the relevant eligibility rules, public procurement, state aid
instruments, environmental, financial instruments, horizontal themes and publicity.
The outcome of the audit was that all criteria checked were found to be fully compliant and no
actions by the Council were required. 
25. All claims submitted against each external funder are recorded on a claims summary. A summary
of outstanding balances yet to be claimed as at the time of the audit is shown in the table below.
Funder  Grant-(£) Claimed-(£) Received (£) Balance to be
claimed-(£)
HLF 4,187,500 3,,627,657 3,627,657 559,843
HES 750,000 525,000 525,000 225,000
HES COVID 62,794 62,794 62,794 0
ERDF 1,055,602 929,078 621,171 434,431
HIE 750,000 744,253 744,253 5,747
Total    1,225,021 
26. The balance outstanding in regard to ERDF and HIE is due to the grants being payable on
completion of specified percentages of work done on the project.  The Council has
procedures/processes in place whereby a qualified quantity surveyor who is independent of the
Council and the contractors evaluates and certifies the work completed at each stage to enable
grant claims to be made timeously.  This involves the following :
 External building contractor required to assesses the work completed and materials on
site and applies for payment via the Cost Consultant/QS 
 A&B representative i.e. QS measures and agrees the work completed and materials on
site and assesses the value prior to agreeing the Contractors application for payment;
 the Architect/Contract Administrator then issues a valuation certificate for the monetary
value as advised by the QS;
 once agreed the contractor issues an invoice based on the agreed figure;
 the invoice is checked/matched against the Valuation Certificate and is then approved
for payment by the Project Manager.  This operation has a specific ledger code which is
then applied to the invoice then passed to the DA’s finance department for payment;
 the ledger is checked each month to ensure that all invoices have been correctly coded;
 claim is then submitted. 
All claims against outstanding grant balances funders are currently on hold.
27. A claim of £307,907 was submitted to ERDF in April 2021 and as at August 2022 this claim has
not been paid by ERDF. Verification on the status of the outstanding claim has yet to be
received.       
Action Plan 1
There are appropriate reporting arrangements in place to Council bodies to provide assurance
that grant terms and conditions are met
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28. The project manager produces on a regular basis a ‘highlight report’.  A review of the reports
found them to be comprehensive and included the following :
 Program Summary
 key performance indicators such as cost summaries , cash flow and budgets
 key issues including communications with Funding Partners, grant claims 
 progress against Plan
 budget
 major Issues including compliance with grant requirements from external funders
 major risks i.e. risk log
 4 week horizon
Issues pertinent to addressing grant offer conditions are included within the highlight reports.
The report is forwarded to all appropriate Council committees including Area committees,
Strategic Management Team (SMT) and Policy and Resources Committee.
29. Due to the terms and conditions varying for each of the funders the project manager produces
on a monthly basis a bespoke report for each of the funders that reflects the areas covered
within the highlight reports.  In addition the project manager has arranged for site visits on a
number of occasions when requested by funders.
30. Regular meeting are held with all grant funders and chaired by the Head of Commercial Services.
A review of the attendees confirmed that all funders were present at the meetings.  A review of
minutes subsequent to the administration of the main contractor included the following:
 Update on progress by the project manager including all areas of concern 
 financial update including latest projected cost forecasts 
 implications for Project completion
 feedback from external Funders concerning their concerns
 outline of actions going forward including discussions with Partners over additional
funding 
The project manager has also supplied comprehensive updates to the main funders during the
course of the project. 
31. The Council has extensive reporting arrangements in place to provide assurance to stakeholders
that grant terms and conditions are met.  A summary of the Council bodies who are regularly
updated with issues pertinent to the Rothesay Pavilion Project including funding issues is shown
below:
Body Regularity Issues discussed
Policy and Resources
Committee
Every 2 months Update included where appropriate in agenda
Committee is updated on major developments 
Departmental Team
meetings
Weekly Updated on budgets , current issues
External Funders
meetings
Quarterly  Chaired by Head of Commercial Services
Commercial Services
Team Meetings
6 weekly Updated on budgets , current issues
Rothesay Pavilion
Charity Board
Quarterly Current progress update on Rothesay Pavilion
Re-development
Bute and Cowal Area
Committee
Quarterly Update included where appropriate in agenda 
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32. Financial Services provide a regular update on the capital spend of all projects including
Rothesay Pavilion.  Project managers provide comment on any issues, update the forecast spend
and provide details of any slippage or acceleration of spending.  Financial Services monitor the
return of these spreadsheets and follow up non returns and query those returned with either no
comment or insufficient comment.  Financial Services present the capital monitoring report to
SMT on a monthly basis and as a standard agenda item to each meeting of the Policy and
Resources Committee (except the May meeting).
33. Whilst our review of the reporting arrangements was satisfactory, it nevertheless identified that
there are considerable financial and reputational risks associated with the project.  These risks
need to be addressed in terms of compiling a plan to take forward the funding gaps with funding
partners and determining the extent of completion that can be achieved based on available
funding.          
Action Plan 2
34. During the course of the audit a number of issues were identified that did not fall within the
scope of our review but which nevertheless should be considered.  It may be of benefit that a
review by internal audit on the Rothesay Pavilion Redevelopment project be considered as plans
for the next stages of development are taken forward as funding becomes available.  Discussions
with the project team noted that they would expect a full review /audit of the project to take
place especially if extra funding is required from the SG. 
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Appendix 1 – Action Plan 
No Finding Risk Agreed Action Responsibility / Due Date
Medium
1 Outstanding Claims
A claim of £307,907 was submitted to ERDF in
April 2021 and as at August 2022 this claim has
not been paid by ERDF.  Verification on the
status of the outstanding claim has yet to be
received. 
Failure to follow up status
of outstanding claims
may lead to non-
payment.
Followed up with HIE as Agent for
Scottish the Government.  Due to
the uncertainty the SG confirmed
they are not in a position to settle
the outstanding claim relating to
the Pavilion.
Project Manager 
Completed.
Medium
2 Project Plan
There are considerable financial and
reputational risks associated with the project.
An action plan to take forward the funding gaps
with funding partners and determining the
extent of completion that can be achieved
based on available funding should be prepared. 
Failure to prepare an
action plan to determine
extent of completion
based on available
funding may lead to non-
completion of project.
A revised construction strategy
has been developed with options.
This is a work in progress with a
key output being a report to P&R.
Project Manager 
January 31st 2023
Low
3 Resources
Consideration should be given to reviewing the
extensive use of outside contractors and
consultants as opposed to investing in in-house
resources in regard to major capital projects
especially in light of the projected overspend
on the project.
Failure to address the
Councils use of external
resources may lead to in
house resources not
being efficiently utilised.
As part of the End Project Report,
Lessons Learned, a review of the
decision pertaining to project
resourcing will be undertaken,
and recommendations made to
Head of Service with respect to
the on-going efficient resourcing
of projects.  In developing future
projects the Council will continue
to give consideration to the most
efficient resourcing model. 
Project Manager 
30th June 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:  
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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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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. 
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Argyll and Bute Council
Internal Audit Report
November 2022
FINAL 
High Medium Low VFM
Number of
Findings
0 1 5 0 
Heritage Assets
Audit Opinion: Substantial 
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Argyll and Bute Council – Internal Audit Report – Heritage Assets, August 2022 
Contents 
1. Executive Summary ........................................................................................................................ 1
Introduction ............................................................................................................................................ 1
Background ............................................................................................................................................. 1
Scope ....................................................................................................................................................... 2
Risks ........................................................................................................................................................ 2
Audit Opinion ......................................................................................................................................... 2
Recommendations ................................................................................................................................. 3
2. Objectives and Summary Assessment ........................................................................................... 3
3. Detailed Findings ............................................................................................................................ 4
Appendix 1 – Action Plan ..................................................................................................................... 10
Appendix 2 – Audit Opinion ................................................................................................................. 13 
Contact Details 
Internal Auditor: Mhairi Weldon 
Telephone:  01546 604294 
e-mail:   Mhairi.weldon@argyll-bute.gov.uk 
www.argyll-bute.gov.uk
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Argyll and Bute Council – Internal Audit Report – Heritage Assets, August 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 heritage assets.
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 has a remarkably rich and diverse historic and cultural heritage reflecting
thousands of years of historic development.   
5. Heritage assets are intended to be preserved in trust for future generations because of their
cultural, environmental and historical associations.  In common with other Local Authorities, the
Council is responsible for caretaking these interesting, rare and unique artefacts.  This includes: 
 the records, civic chains and regalia of former parish and burgh councils, Argyll County
Council and Bute County Council 
 Anderson Trust Collection of paintings of Helensburgh and District
 Argyll Collection of prints, paintings, ceramics, textiles, drawings and sculpture
 McGrory photographic collection of Kintyre 1890 – 1911 (partially reproduced from
original glass plates)
 Other heritage assets including schools, museums, libraries, public art, scheduled
monuments and grave yards and historic gardens and landscapes.   
6. Sound asset management is crucial if the Council is to make best use of the resources available
to it to deliver its overall aims and objectives.  Asset management is a structured and systematic
approach to managing assets on an ongoing basis to address all phases of its life-cycle.  Effective
asset management planning means knowing what you own, where it’s located, it’s value, what it
costs you, what it will cost you in the future, whether it will support current and future service
delivery and who is responsible for it.  Asset management is the process of ensuring that the
Council’s Assets are:
 Fit for purpose
 Used efficiently
 Maintained on a sustainable basis
 Matched in investment terms to service needs  
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7. The Corporate Asset Management Strategy acknowledges that in preparing Service Asset
Management Plans, Service Asset Managers must consider sharing assets with Community
Partners and Third Sector to maximise public benefit.  Heritage assets are therefore managed
across Council Services and also in partnership with LiveArgyll and Kilmartin Museum who make
arrangements for artwork and historic artefacts to be displayed at various locations throughout
Argyll and Bute. 
8. Heritage assets are reported in the Council’s balance sheet at insurance valuation which is based
on market values and are updated periodically.  These assets are deemed to have indeterminate
lives and a high residual value and it is therefore considered inappropriate to charge
depreciation. 
9. In February 2022, another local authority reported that 1,330 objects from their art gallery and
museums’ collection with an aggregate value of just under £200k were missing due to thefts,
historic losses or unconfirmed location. It is therefore important that suitable measures are in
place for the management and control of such assets.
Scope 
10. The scope of the audit was to review the management and record keeping of heritage assets as
outlined in the Terms of Reference agreed with the Head of Commercial Services on 30
September 2022. 
Risks
11.  The risks considered throughout the audit were:
 SRR02:  Condition and suitability of infrastructure & asset base
 Audit Risk 1:  Heritage assets are ineffectively managed leading to damage, loss or theft of
items
 Audit Risk 2:  Heritage assets are not catalogued with sufficient information (e.g. description,
value, location, condition and ownership)
Audit Opinion
12. 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.
13. 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.
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Recommendations
14. We have highlighted one medium priority recommendations and five low priority
recommendations where we believe there is scope to strengthen the control and governance
environment. These are summarised below:
 Officers representing the various services involved should meet to discuss the
requirements for valuation, insurance and inclusion within the Council’s Annual
Accounts and nominate responsible officer(s) to take forward any actions identified as a
result.
 The procedure followed to create and maintain archive records should be documented.
 A list of missing artworks should be provided to schools with a request to check the
premises in an effort to locate them.
 The record of artworks belonging to the Argyll Collection should be updated to include
those omitted using details from the 2016 valuation schedule.  
 The condition of civic chains should be documented when issued and returned.
 A programme of inspections to evaluate the condition of artworks belonging to the
Argyll Collection should be implemented.
15. 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
16. 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 Policy and
procedures are in
place to ensure
assets are managed
appropriately
SRR02
Audit Risk 1
Substantial High level asset management
documentation is approved by Council
each year.  Heritage assets are
appropriately managed across various
services within the Council or by
external organisations acting as
curators via formal agreement. 
Artworks and civic chains are included
within the Council’s All Risks insurance
policy however, valuable archive
documents are not.
2 A robust cataloguing
procedure/system is
in place to prevent
assets being
misplaced, lost or
otherwise
unavailable for users
Audit Risk 2 Substantial There are detailed records of assets
held within each area of responsibility. 
Artworks recorded as missing from the
museum and libraries collection have
been recovered, however only 4 of 11
have been recovered for the Argyll
Collection and one has been located in
another local authority with whom we
share ownership.  The details of 6
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artworks were omitted from the Argyll
collection record.
3 Heritage assets are
displayed or stored
securely,
appropriately
insured and subject
to a programme of
inspection and
maintenance
SRR02
Audit Risk 1
Reasonable Museum exhibits and artworks on
display are available for the public to
view during opening hours.  Storage
areas are secure, however, in some
cases the artworks are inappropriately
stacked against each other.  Civic
chains and archive documents are
secured in council accommodation and
made available for use by prior
arrangement.  Elements of the
collections can be accessed digitally by
members of the public from their
personal devices, however there is no
access to historical archive records by
this means.  Most of the collections are
subject to periodic or ad-hoc
inspections, however, these are not
always recorded.  The Argyll Collection
is not currently rotated around schools
and is not inspected unless loaned to
external organisations who will check
the condition of the artwork.  
4 Heritage assets are
accurately reported
in the Council’s
financial statements
Audit Risk 2 Substantial Heritage assets are recorded as fixed
assets on the Council’s AIRS system
however there was no inclusion of the
civic chains nor any archive documents
considered to be of value.  The total
value of heritage assets recorded on
AIRS is correctly reflected on the
Council’s Annual Accounts. 
17. Further details of our conclusions against each control objective can be found in Section 3 of this
report.  
3. Detailed Findings
Policy and procedures are in place to ensure assets are managed appropriately
18. There is a Corporate Asset Management Strategy and Plan, together with a Capital Plan that are
approved by council at its budget setting meeting in February of each year.  These strategic
documents encompass all asset categories and their need to support and contribute to the
corporate objectives in the Argyll and Bute Outcome Improvement plan (ABOIP), they are
published on the Council’s webpage and are therefore available for public access. 
19. Heritage assets are managed across various services within the Council and also by LiveArgyll,
Kilmartin Museum and Culture, Heritage &Arts (CHARTS) Argyll & Isles who are appointed
curators with line management responsibilities.  The asset categories and the service area
responsible for their management are detailed in the table below.
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Asset Responsible Service Area
Archaeological Museum Exhibits Kilmartin Museum (Curator support via SLA)
Social History, Natural History and Fine Arts
Collections
CHARTS (Curator support and line
management of modern apprentice via SLA)
Archive Documents LiveArgyll
Anderson Trust Artworks Collection The Anderson Trust (stored & insured by the
Council) 
The Argyll Collection  Education Services
Museum and Libraries Artworks Collection LiveArgyll
War Memorials Amenity Services
Civic Chains Members Services 
20. Service Level Agreements (SLAs) are in place between the Council and LiveArgyll and also with
Kilmartin Museum who are appointed curators for the Council’s archaeological museum
exhibits.  An annual report summarising management of the collection has been provided by
Kilmartin Museum as required by the SLA.  A further agreement is in place between LiveArgyll
and CHARTS, who will provide professional support for the delivery of services at Campbeltown
Museum and train a modern apprentice in curator responsibilities.
21. There is guidance in place to manage the museum exhibits, Archives, the Argyll Collection and
the Museum and Libraries collection, the Anderson collection is managed by a Trust out with the
Council.  A security protocol is in place to guide members and officers when civic chains are
required to be worn at events.  
22. Paintings and museum exhibits are covered in the “All Risks” section of the Council’s insurance
policy with a value assigned that is consistent with the artworks valuations that took place in
2015 and 2016, there was no valuation provided for the museum exhibits.  The civic regalia are
also covered in this policy based on the original value and adjustments made accordingly.  There
is, however, no inclusion of archive documentation within the policy despite some of these being
of considerable value, in particular there are original drawings of the Hill House in Helensburgh
by Charles Rennie Macintosh.
Action Plan 1
A robust cataloguing procedure/system is in place to prevent assets being misplaced, lost or
otherwise unavailable for users
23. Heritage assets are managed by various officers across the Council and with third-party
organisations appointed as custodians.  These assets are included within the Council’s annual
accounts in accordance with accounting standards.
24. Detailed catalogues or a register of artworks are maintained for each of the collections.  
25. There is detailed guidance on how to maintain the records for the museum collections and this is
planned to be updated in the near future.   The catalogues for the archives are maintained in a
structured format on the Council’s shared drive area and whilst there is an acquisition policy and
collecting agreement explaining what may be accepted, the process to create and maintain
these records has not been documented.  
Action Plan 2
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26. Records held for the artworks collections and war memorials are maintained in list formats and
require little updating.  Copies of all records were provided and found to be comprehensive with
appropriate fields available for completion.
27. The 2015 and 2016 valuation schedules were reviewed, it was found that there were no
artworks recorded as missing at the time of the valuation for the Anderson Collection, however,
there were six items recorded as missing in the valuation schedule for the Museum and libraries
collection, these have all now been located and updated on the custodian’s collection record
provided.  Additionally, there are 54 entries on the Museum and Libraries collection record that
are not included within the valuation schedule as they had been added after the valuation
exercise took place.  These artworks will be included in any future valuation exercise conducted.  
28. There were 11 artworks recorded as missing in the valuation document for the Argyll Collection,
five of these have been located and six remain missing, the value of these artworks is unknown,
they are as follows:
 Unknown artist, Round Bowl, Ceramic, Green, 195mm diameter (no record)
 Anne Gillie, Drawing, 43 X 56cm (location unknown)
 Charles Mitchell, winged skull, mixed media, 64 X 64cm (location unknown)
 William Birnie, "Mains Farm, Buchlyvie", watercolour, 55 X 72cm (no record)
 Rock Samples, Rocks, granite, pumice, black rock, beige pebble and beige rock with
water worn holes(reference no. missing from list)
 Unknown (Anita Man), Penguins and two chicks, Wood carving, 210mm tall (no record)
Action Plan 3
29. A sample of 36 artworks including the 17 recorded as missing on the valuation documents and
an additional 19 with the highest values was selected from across the three collections and
records were compared with the valuation schedules of 2015 and 2016, these were found to
contain similar fields for storing information.  There was a small number of differences in sizes
recorded across the collections, however these are considered to be immaterial.
30. The review of the Argyll Collection record revealed that four of the five recovered artworks were
included, however the remaining artwork is located at another local authority with whom the
Council shares ownership and the record has not been updated to reflect this.   Additionally,
there was no detail entered against the reference number for 4 of the artworks that remain
missing and one was omitted from the record (both reference and detail).  One further entry for
an artwork that has been recovered but has a duplicate reference was not included on the
record provided.  
Action Plan 4
Heritage assets are displayed or stored securely, appropriately insured and subject to a
programme of inspection and maintenance
31. The 6 missing items noted above, one located at another local authority and one located
remotely were removed from the sample of 36 artworks leaving 28 for viewing.   
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Location Artworks
Expected
Artworks
Found
Comments
Helensburgh Library 2 2 One located in Library storage room, the
other on display in Campbeltown Marriage
Room.
Helensburgh Library
Anderson Collection
5 5 All items were located in the storage area.
Castle House
Museum
2 2 Both on display to the public near the main
entrance.
Library HQ 2 2 Both are displayed although visits are by
appointment only, one is situated on an easel
and the other on the floor against a cabinet.
Campbeltown
Museum/ Marriage
Room
7 7 Three were displayed in the Marriage room, 2
in the museum and 2 in storage.  
Schools 10 10 All 10 artworks were located although one
was at a different school from that recorded. 
32. All but one of the artworks viewed on display were appropriately fixed to a wall or mounted on
an easel, the remaining one was placed on the floor leaning against a cabinet.  The locations
allow either members of the public or school pupils to view the artworks within opening hours
and are secured within the buildings when closed.
33. The purpose of the Argyll Collection is to provide a learning resource for the young people of
Argyll and Bute that will enable them to experience fine art in an area with little access to
museums and galleries.  The artworks were formerly rotated around schools to provide a variety
of artist’s works for young people to view, however, there has been no full rotation since May
2013 and following the valuation exercise in 2016, art teachers are no longer prepared to be
responsible for transporting valuable artworks in private vehicles and no budget is currently
available to fund the professional packaging and transportation required.  The Cultural Co-
ordinator, Education is working with CHARTS to identify and apply for external funding to
reinstate the rotation of the artworks.
34. The artworks in storage belonging to the Anderson Collection and those located at Campbeltown
Museum were located in numbered racks in purpose designed, climate controlled locked storage
rooms.  The remaining artworks were located in secure storage areas, wrapped in protective
coverings and stacked upright against other artworks at floor level.  This situation is not ideal as
it is difficult to locate specific items and damage may result from the accumulated weight of
multiple artworks or movement to gain access to other items in the storage areas.  A potential
storage solution at Council Headquarters in Kilmory had been identified for the Argyll Collection
and is expected to progress under the “Our Modern Work Space” project.
35. The Council’s Members Services Officers are responsible for managing the Civic Chains.  Seven of
these are retained at Kilmory Castle in a suitable protective environment.  All seven were
present, stored in protective casing and appeared to be in good condition at the time of the
review.  The remaining two are located at Mull Museum and Inveraray Castle.  Chains are issued
by the Council Officers following authorisation from the Executive Director.
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36. Archive records are retained in Council office accommodation in a climate controlled storage
area.  Access to records by the public is by prior arrangement and officers are present at all
times.
37. War memorials are located across the Argyll and Bute area, 16 of these were viewed and found
to be located according to the record provided, appeared to be in good condition with
surrounding grounds maintained and accessible by members of the public at any time.
38. There is no specific reference of heritage assets within the ICT Digital Strategy 2021/24,
however, the document encompasses all services with an aim to create efficiencies, savings and
improve services for both staff and customers.  Elements of the collections can be viewed on the
internet with further links provided to social media sites to obtain additional information. 
Committee records from 1995 and other information is available to the public on the Council’s
website, however, historical archive records cannot be accessed digitally by members of the
public as the system used is not able to replicate the structured format of files from the shared
drive area.  There has been some consideration of creating a new digital archive facility that
would be accessible by the public, however, this was deemed to be cost prohibitive.
39. The artworks and museum collections are marketed via websites and social media platforms
operated by the various appointed curators.  These items are non-income generating to
encourage the public to enjoy the content, there is a small charge, however, to those who wish
some research to be conducted by the archivist team on their behalf and any associated printing
of documents.  LiveArgyll are currently exploring an opportunity to generate income via the
installation of donation receptacles in some of their facilities.
40. Heritage assets are not generally disposed of due to their historical and cultural significance,
however, they may be loaned to other areas of the Council or external organisations by use of a
formal terms of agreement which is completed in each instance.
41. The museum and library exhibits are inspected prior to and following exhibitions with the
condition noted on records and dated.  Periodic artefact checks are undertaken by the museum
curator in compliance with the SLAs in place.  
42. Archive documents are inspected as part of the stock-taking process and whenever extracted for
use. The Anderson collection is managed independently by the Trust who carry out their own
inspections. Civic chains are carefully checked by a Council Officer prior to and following every
issue for use at events, however, this is not documented.
Action Plan 5
43. The Argyll Collection is not currently subject of any programme of inspection, when artworks are
loaned, the condition is checked by the external organisations.
Action Plan 6
44. There is no budget nor schedule for maintenance or preservation of heritage assets, any needs
would be of an ad-hoc nature and identified during inspections or at time of use.   Any funding
required to address identified needs for maintenance or preservation would be requested via
the appropriate channels. 
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Heritage assets are accurately reported in the Council’s financial statements
45. Heritage Assets are recorded as fixed assets on the Council’s AIRS system which holds details of
two museums, two monuments, two clock towers, 57 war memorials and 270 works of art in this
category.   One of the works of art from the sample selected for review had the incorrect value
applied on AIRS, however, the overall effect of this error is immaterial.  The values of the
remaining items correspond with those provided on the 2015 and 2016 valuation records and
excludes those that were recorded as missing at that time.  There is no inclusion of any museum
exhibits, valuable archive documents owned by the Council nor the Civic chains.
Action Plan 1
46. The total value of heritage assets recorded on AIRS has been correctly reflected in the Council’s
Audited Accounts as at 31 March 2021. 
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Appendix 1 – Action Plan 
No. Findings & Recommendations Risk Agreed Action Responsibility/ 
Due Date
Medium
1
Valuations, Insurance & Fixed Assets Register
Finding:  Civic chains, archive documents and museum
exhibits are not included within the Council’s programme
of valuations.   
Finding:  There is no inclusion of valuable archive
documentation within the Council’s All Risks insurance
policy.   
Finding:  Civic chains, Museum exhibits and valuable
archive documents are not included within the Council’s
Fixed Asset Register, AIRS. 
Recommendation:  Officers representing the various
services involved should meet to discuss the requirements
for valuation, insurance and inclusion within the Council’s
Annual Accounts and nominate responsible officer(s) to
take forward any actions identified as a result. 
Valuable heritage assets
may not be
appropriately covered
by the Council’s All Risks
insurance policy should
they be lost, stolen or
damaged. 
The value of assets
stated on the Council’s
annual accounts may be
incorrect.
Officers representing
the various services
involved will meet to
discuss the
requirements for
valuation, insurance
and inclusion within
the Council’s Annual
Accounts and
nominate responsible
officer(s) to take
forward any actions
identified as a result. 
Head of Legal and
Regulatory Support 
31 March 2023 
Low 2
Archives cataloguing procedure
Finding:  Whilst there are some policies surrounding the
management of archives, there is no documented
procedure in place regarding creation and maintenance of
records. 
Recommendation:  The procedure followed to create and
maintain archive records should be documented.
Failure to document
formal policies,
procedures and
processes may lead to
the loss of skill and/or
knowledge when staff
members leave.
Procedure notes will
be reviewed and
updated.
Archives Officer
31 March 2023
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No. Findings & Recommendations Risk Agreed Action Responsibility/ 
Due Date
Low 3
Argyll Collection – Missing Assets
Finding:  Six missing artworks at the time of the valuation
in 2016 have not been located. 
Recommendation:  A list of missing artworks should be
provided to schools with a request to check the premises
in an effort to locate them.
Assets may have been
lost or stolen.
A list of missing
artworks will be
provided to schools
with a request to check
the premises in an
effort to locate them.
Cultural Co-ordinator,
Education
31 December 2022 
Low 4
Argyll Collection – Record Keeping
Finding:  There were no entries on the record provided
for 4 of the missing artworks, one shared with other local
authorities nor one with a duplicate reference number.   
Recommendation:  The record of artworks belonging to
the Argyll Collection should be updated to include those
omitted using details from the 2016 valuation schedule. 
Incomplete or incorrect
records may lead to
inefficient management
of assets.
The record will be
updated to include
missing artworks
identified in the 2016
valuation.
Cultural Co-ordinator,
Education
31 December 2022 
Low 5
Civic Chains
Finding:  Civic chains are carefully checked by a Council
Officer prior to and following issue for use at events,
however, this is not recorded. 
Recommendation:  The condition of civic chains should be
documented when issued and returned.
The condition of civic
chains would not be
available should the
information be required.
The record of issue of
chains will be updated
to include date
checked and condition
of chain at that time.
Members Services
Officer
31 December 2022
Low 6
Argyll Collection – Artworks Inspections
Finding:  There is currently no programme of inspections
taking place to evaluate the condition of artworks held. 
Recommendation:  A programme of inspections to
evaluate the condition of artworks belonging to the Argyll
Collection should be implemented. 
The condition of
artworks would not be
available should the
information be required
e.g. insurance claim.
Programme of
inspections will be
agreed by Education
Services
Cultural Co-ordinator,
Education
31 December 2022 
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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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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. 
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Argyll and Bute Council
Internal Audit Report
November 2022
FINAL 
High Medium Low VFM
Number of
Findings
0 0 0 0 
Early Years – use of Covid
recovery funds 
Audit Opinion: High 
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November 2022 
Contents 
1. Executive Summary ........................................................................................................................ 3
Introduction ............................................................................................................................................ 3
Background ............................................................................................................................................. 3
Scope ....................................................................................................................................................... 4
Risks ........................................................................................................................................................ 4
Audit Opinion ......................................................................................................................................... 4
2. Objectives and Summary Assessment ........................................................................................... 4
3. Detailed Findings ............................................................................................................................ 5
Appendix 1 – Audit Opinion ................................................................................................................... 9 
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 – Early Years –use of Covid Recovery Funds,
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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 Early Years – use of Covid recovery funds.
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. No actions have been identified 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. The COVID-19 pandemic has impacted upon educational delivery with the closure of schools and
early learning establishments across Scotland putting education outcomes at risk and increasing
educational and social inequities for children and young people. During periods of lockdown,
some learners may have had positive experiences, enjoying the extra time with family and
developing their digital skills and independent learning. Research suggests, however,
that COVID-19 may have had adverse consequences on the health and wellbeing of some
learners, as well as their attainment. 
5. Early learning and childcare (ELC) plays a vital role in supporting families attaining high quality
learning which is linked with improved outcomes for children. Throughout the pandemic, access
to ELC was provided for those children who needed it most and the Scottish Government
prioritised the re-opening of ELC to all children ahead of the re-opening of other sectors.   
6. The Scottish Government's 'Covid Recovery Strategy for a Fairer Scotland' strategy identifies
three key outcomes as most likely to have the greatest impact on tackling the inequality and
disadvantage highlighted by Covid: financial security for low income households; wellbeing of
children and young people; and good, green jobs and fair work. 
7. In order to mitigate inequity caused by the pandemic, and champion a vision that supports
children and young people to continue to progress their learning and achievement, the Scottish
Government has published the Coronavirus (COVID-19) education recovery: key actions and next
steps plan, to achieve the long term aims to: improve children's outcomes; help to close the
poverty-related outcome gap; increase family resilience; and support parents and carers into
work, study or training. 
8. Using the Getting It Right For Every Child (GIRFEC) approach, where the needs of the individual
learner must be at the centre of our actions, the education recovery plan recognises that
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schools, teachers and early years practitioners will know best how to help individual children,
including identifying those who need extra support with specific subjects or with their health
and wellbeing, and what type of individual support that may be required. 
9. Across Scotland over £450m of additional funding has already been committed during 2020/21
and 2021/22 as part of education recovery. £240m of that total has already been provided for
the recruitment of extra staff to promote resilience and to provide additional support for
learning and teaching. In addition, a further £145.5m is being added permanently to the local
government settlement from April 2022 to allow local authorities to offer sustained employment
of additional teachers and support staff.  
Scope 
10. The scope of the audit was to assess compliance and use of Early Years Covid recovery funds as
outlined in the Terms of Reference agreed with the (Acting) Education Manager on 19 July 2022.
Risks
11.  The risks considered throughout the audit were:
 Audit Risk 1: COVID-19 recovery funding is not being used effectively or for the purposes
intended
Audit Opinion
12. 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 1 to this report.
13. Our overall audit opinion for this audit is that we can take a High level of assurance.  This means
that 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.
2. Objectives and Summary Assessment
14. 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, Early
Years Team, has an
appropriate plan for
the use of Covid
recovery funding.
Audit Risk 1 Satisfactory The Covid recovery funding provided
the Early Years team with the ability to
bring forward a future planned project
to support effective transitions into
Primary School. Management were
able to react quickly by redeploying
resources already within the team to
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create the 12 month secondment for
the Education Support Officer (ESO)
Transitions post  
2 Plans to support
effective transitions
into P1/P2 have
been developed and
these have been
communicated to
staff.
Audit Risk 1 Satisfactory The Early Years team have provided
strong evidence that the ESO
(Transitions) has assisted them in 
developing plans and taking action to
embed play-based pedagogy in early
primary and creating the Argyll and
Bute Play Pedagogy Network on
Google classroom. This allows teachers
to share good practice across the
authority and as mechanism for the
ESO to deliver network sessions, post
Career-long professional learning
(CLPL) webinars and provide
participants with up to date literature/
blogs etc. about play. 
In addition,  there is good evidence of
engaging with staff and using feedback
to tailor materials and help shape
training and development and identify
a key Improvement Outcome for future
year’s transitions.
3 Appropriate
performance and
reporting
arrangements are in
Place.
Audit Risk 1 Satisfactory The Scottish Government only required
Local authorities to report on the
number and type of additional staff
recruited using this funding and the
setting they are employed in. The
Council have submitted returns in the
format requested, confirming that 1
post was used in Early Years. 
15. Further details of our conclusions against each control objective can be found in Section 3 of this
report.  
3. Detailed Findings
The Council, Early Years Team, has an appropriate plan for the use of Covid recovery funding. 
16. In February 2021 the Scottish Government announced an additional allocation of £60 million to
further support Covid recovery in education in 2021-22. In May 2021, Argyll and Bute Council
(the Council) received a letter informing them of their allocation of £869, 000, stating:
 Funding will be distributed as a redetermination of the General Revenue Grant in 2021-
22. 
 Local authorities will be required to report on the number and type of additional staff
recruited using this funding and the setting they are employed in. 
 This funding covers continued education recovery COVID costs and supports continued
financial sustainability. 
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 It is expected that additional flexibility may be required in how these costs are managed,
and it is for local authorities to manage this against ongoing funding requirements for
education recovery 
17. The Scottish Government agreed with COSLA Leaders the funding could be used flexibly by local
authorities for the following purposes in relation to Early Years:
 To employ early years practitioners to support the transition from ELC to primary school
by, for example, embedding play-based pedagogy in early primary, supporting
information sharing and organising transition activities.
18. As is practice with educational funding, COSLA issued a distribution notice to Councils asking
Leaders to consider and agree the recommendations from the Settlement and Distribution
Groups (SDG) that the allocated funding be split 90% for schools and 10% for Early Learning and
Childcare (ELC), noting that the split is for distribution purposes only. Councils were asked to
submit a funding response to COSLA to provide details of their intended split and plans for use.
19. The Council’s response confirmed that, in line with recommendations, the intended distribution
for Early Years would be £89, 600 (10%) with planned use to support consistency of transition
from all ELC settings to Primary One by providing:
 training and direct peer support in the classroom to Primary One teachers to develop
their confidence and skills in delivering active and play based learning. 
 active and play based learning outdoors as is central to our curriculum vision. 
 additional Early Years practitioners to ensure that developmental milestones and other
quality data are shared with schools, checking it is understood so that transitions to
schools are effective and well supported. 
20. Given the short timescales, the Education Manager Early Years, in place at the time, decided that
the most efficient and effective use of resources to deliver this project was via an additional
Education Support Officer (ESO) post to be in place for the academic year. The member of staff
selected to deliver the Transitions project was chosen because their current work, undertaken as
part of the ‘Into Headship’ assignment, on Play Pedagogy provided the team with the ability to
implement the project at short notice. 
21. Financial records confirm that the cost centre, EDU - COVID 19 - Education Recovery - Additional
Staff in School and ELC settings, has been set up and provides evidence of defrayal of the
funding on employee costs specifically relating to one Early Years post - Education Support
Officer (ESO) – Transitions. 
22. Educational funding is awarded for academic years and so crosses financial years meaning
automatic approval for Ear Marked Reserves to be taken forward for use in the next financial
year. In the financial year 2021-22 a total of £45,043.70 was spent with the remaining balance of
£44,556.30 being carried forward to the current financial year, 2022-23 as part of the larger
Education Ear Marked Reserve for Covid Recovery Funding. 
23.  The total costs relating to ESO Transitions post amounted to £68,848 for the academic year 21-
22 and officers confirmed that the remaining underspend of £20,752 is available for Early Years
team to spend to  support active and play-based learning outdoors. This is consistent with the
award letter and the Council’s planned use. 
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Plans to support effective transitions into P1/P2 have been developed and these have been
communicated to staff. 
24. The Education Support Officer (ESO) developed and shared various plans, training materials and
resources to ensure the transition to school is based around a developmental, play-based
approach to learning. The main examples of these are: 
 The Argyll and Bute Play Pedagogy Network on Google classroom to allow teachers to
share resources and good practice across the authority. 
 A Framework for Transition – providing details of events and key activities across the
academic year.
 Primary One Teachers transition resource
 Introduction to Developing  Playful Pedagogy in the Primary Classroom and A Whole
School Approach - continuing professional development (CPD) sessions
 Transition – self-evaluation form
 Somewhere Over the Rainbow Transition Project, which included setting up a Facebook
page to share good practice and encourage continuity with transition across the summer
months
 Coming back to school in a bubble – a book for children
 Planning for Play Outdoors 
25. The Argyll and Bute Play Pedagogy Network on Google classroom provided the mechanism for
the ESO to deliver network sessions, host CPD webinars and provide participants with up to date
literature / blogs etc about play. Examples of  how the developmental, play-based approach to
learning has been shared with staff and rolled out include: 
 Using the Play Pedagogy Network teachers from 18 schools participated in 5 training
sessions
 4 sessions of “Introduction to Developing  Playful Pedagogy in the Primary Classroom”
were delivered between May and November 2021
 17 schools due to be inspected from across the authority were initially offered support
to implement and develop  play pedagogy in preparation for an inspection.  
 Bespoke support from the ESO for schools who made specific requests. 
 60 teachers from across 25 schools participated in the In Service Day training /CLPL
session held on 14th  February 22. The session aim was to provide an enhanced
understanding of how play pedagogy can be delivered in the classroom
 “A Whole School Approach” session held on 20th April 2022 was attended by about 70
teachers from 30 schools 
26. To evaluate performance the ESO initiated a Google Forms survey before Christmas 2021 using
the Transition – Self Evaluation form to gather the thoughts of ELC settings and schools on how 
effective the transition projects were across the authority.  A total of 67 responses were
received, these were fairly evenly spread between all 4 areas and a wide variety of roles with
half of the respondents choosing to leave comments and feedback. 
27. The general consensus was that the transition projects were not perceived to have been taken
forward in schools as well as they had been in ELC. 
 The survey itself showed us that not enough Primary One teachers were represented. 
This could imply that relevant information does not always reach the correct people.
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 Transition is generally successful in ELC but aspects could be improved when children
reach Primary One.
 Further work is required in order to ensure that all Primary One teachers have a sound
understanding on what constitutes a ‘quality’ transition. 
28. The results of the survey led to the creation of a key Improvement Objective for future years
transition “To ensure that the transition project work is carried forward into Primary One in a
more meaningful and comprehensive manner than in previous years” and helped shape the In
Service day and the April CLPL session noted above. 
Appropriate performance and reporting arrangements are in Place 
29. The Scottish Government required local authorities to report on the number and type of
additional staff recruited using this funding and the setting they are employed in. The Council
have submitted returns in the format requested, confirming that one ESO post was used in Early
Years. 
30. The secondment has now finished and the current Education Manager Early Years confirmed
that transitions will continue to be monitored in line with the ESO role/job description and as
required by the national curriculum requirements.
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Appendix 1 – 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. 
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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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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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 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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 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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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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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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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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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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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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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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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. 
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Argyll and Bute Council
Internal Audit Report
November 2022
Final 
High Medium Low VFM
Number of Findings 0 0 0  0 
Oban Airport
Audit Opinion: High 
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Contents 
1. Executive Summary .............................................................................................................. 3
Introduction................................................................................................................................. 3
Background.................................................................................................................................. 3
Scope........................................................................................................................................... 4
Risks ............................................................................................................................................ 4
Audit Opinion .............................................................................................................................. 4
2. Objectives and Summary Assessment.................................................................................... 4
3. Detailed Findings .................................................................................................................. 6
Appendix 2 – Audit Opinion.......................................................................................................... 9 
Contact Details 
Internal Auditor: Leanne Rennie 
Telephone:  01369 708516 
e-mail:   Leanne.rennie@argyll-bute.gov.uk 
www.argyll-bute.gov.uk
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1. Executive Summary
Introduction
1. As part of the 2022/23 internal audit plan, approved by the Audit & Scrutiny Committee in
March 2021, we have undertaken an audit of Argyll and Bute Council’s (the Council) system of
internal control and governance in relation to Oban Airport.
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. Oban Airport is one of three aerodromes operated by the Council, and licensed under Article 211
of the ANO 2009 by the Civil Aviation Authority (CAA). Deemed as a Public Service Obligation
(PSO), scheduled services, and scholar flights for island school children, operate from Oban
airport to Coll, Colonsay, Islay and Tiree. Additionally, the airport deals with chartered traffic and
military flights as well as general aviation traffic such as medevacs, coastguard operations,
training flights and scenic tours by private operators. 
5. Prior to the grant of a licence and for continued licensing, the CAA requires the Aerodrome
Operator to meet the minimum standards detailed in CAP168 Licensing of Aerodromes. CAP 168
sets out the standards required at UK national licensed aerodromes relating to management
systems, operational procedures, physical characteristics, assessment and treatment of
obstacles, visual aids, rescue and fire-fighting services and medical services. 
6. The Oban Airport Aerodrome Manual (the Manual) provides information about the airport, its
systems for managing safety and the required operational procedures.  The Airport Rescue &
Fire Fighting Service (RFFS) manual provides guidance on the agreed policy and procedures
designed to achieve an effective and efficient RFFS. Both manuals are derived from CAP168.
7. Oban Airport operate the ‘Redkite Equipment Management system’ which is used in all UK
airports to help ensure they meet the requirements of the CAA in regard to RFFS personnel and
equipment.
8. The overall remit of internal audit is to provide assurance over compliance with the 22 airport
operating instructions (AOIs) established by the Manual and the further procedures established
by the RFFS manual. Our approach, as agreed in 2018/19, is to provide this assurance over a five
year cyclical basis. 
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Scope 
9. The scope of the audit was to provide assurance over compliance with five of the airport
operating instructions (AOIs) established by the Manual and the further procedures established
by the RFFS manual as outlined in the Terms of Reference agreed with the Oban Airport Station
Manager on 28 September 2021. The operating instructions audited in 2022/23 were:
 AOI 1 – Airside Access Compliance
 AOI 2 – Airside Safety Compliance
 AOI 3 – Airside Driving Compliance
 AOI 4 – Airside Vehicle & Equipment Compliance
 AOI 5 – Airside Stands & Parking Arrangement Compliance 
Risks
10.  The risks considered throughout the audit were:
 Audit Risk 1: Failure to comply with operating instructions could result in increased risk
of accidents and/or the airport losing its CAA licence
Audit Opinion
11. 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.
12. Our overall audit opinion for this audit is that we can take a high level of assurance. This means
that 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.
2. Objectives and Summary Assessment
13. 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
CO1 The Manual, setting out the
operational procedures of the
airport, is up to date, appropriate
and accessible to all relevant
staff.
Audit
Risk 1
High The Manual is updated
annually and is available to
appropriate officers. The
document was found to be
comprehensive with each
section outlining the Council
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policy for compliance with
regulations and procedures. 
CO2 AOI1 – Access to the aircraft
movement area is restricted to
appropriate and competent
personnel.
Audit
Risk 1
High Access to the aircraft
movement area was found
to be restricted to
appropriate personnel. 
Training is carried out on an
ongoing basis.
CO3 AOI2 - Appropriate action is
being taken to minimise airside
hazards.
Audit
Risk 1
High The aerodrome operating
manual sets out a
comprehensive list of
potential hazards that can
occur in regard to both
airport and apron activity. 
Training on minimising
airside hazards is carried out
on an ongoing basis.
CO4 AOI3 - Airside drivers are
appropriately trained and comply
with the driving procedures
established by the Manual.
Audit
Risk 1
High All traffic incidents and all
accidents are recorded
within the appropriate
database. Training on
airside driving is carried out
on an ongoing basis.
CO5 AOI4 - Airside vehicles and
equipment are properly
maintained, used only by
appropriate personnel and
appropriately insured.
Audit
Risk 1
High All airside vehicles are
insured under the Councils
overarching vehicle
insurance policy. 
A review of the
maintenance records
confirmed that all vehicles
are being maintained per
the agreed schedule and
meet VOSA standards where
applicable. Training on
airside equipment is carried
out on an ongoing basis.
CO6 AOI5 - Procedures for parking
and manoeuvring aircraft are
consistent with the requirements
of the Manual.
Audit
Risk 1
High A review of procedures for
parking and manoeuvring
found them to be
comprehensive and
consistent with the
requirements of the
manual.
Equipment available on site
for parking and
manoeuvring of aircraft was
found to be appropriate.
Training covers all aspects of
airside stands and parking. 
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14. Further details of our conclusions against each control objective can be found in Section 3 of this
report.  
3. Detailed Findings
The Manual, setting out the operational procedures of the airport, is up to date, appropriate and
accessible to all relevant staff
15. The Manual is available to all relevant personnel on the Council HUB with a hard copy held
onsite at the airport. Each section within the Manual sets out:
 the Council’s policy and established procedures to ensure compliance with relevant rules
and/or regulations 
 appropriate monitoring arrangements (where applicable)
 roles and responsibilities of relevant personnel.
16. The Manual is reviewed annually by the Station Manager, last updated October 2022.  The
updated version is submitted to the CAA who have 28 days to highlight any queries on the
Manual’s content. If no response is received in 28 days then the revised Manual is adopted.  
17. In June 2020, in response to COVID, a guidance manual entitled ‘Oban & the Isles Airports –
COVID secure procedures’ was issued by the Station Manager. It is available on the Council HUB
and paper copies are kept in the office.
The airport complies with the Rules of the Air Regulations regarding airside access.
18. The Manual states that all personnel must have received appropriate training (and records kept)
be over the age of 16 and are in possession of a current airside driver pass. All airside personnel
undergo an initial induction training course which includes an overview of all elements stated in
the Manual. Thereafter the Airport has a 12 monthly rolling training programme. 
The airport complies with the operating instructions to monitor airside safety. 
19. The Manual states that all traffic incidents or accidents must be reported accordingly. It also
states that training must be in place and personnel are complying with the procedures in order
to minimise airside hazards. 
The Airport complies with the operating instructions regarding airside driving. 
20. The Manual states that all traffic incidents or accidents must be reported and recorded.
Occurrences are reported to either CAA or AIB depending on the nature of the incident. All
personnel must also be trained in all aspects of airside driving to ensure competency.                                                                                                                                                  
The airport complies with the operating instructions regarding permitted vehicles airside. 
21. The Manual states that training must be in place for all personnel in relation to the operation of
airside vehicles and equipment. All vehicles used airside must be insured and a
maintenance/inspection programme is followed. Airport vehicles are checked on a daily basis by
personnel and details recorded. 
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The airport complies with the procedures for parking and manoeuvring aircraft.
22.  The Manual states that a training programme must be in place. Airport policy for the majority of
aircraft is to self-park, in the event of any congestion marshals will be provided. Personnel must be
issued with the appropriate clothing and equipment, ie, orange bats and illuminated wands (in the
event of reduced lighting). Fuel spillages and emergencies will be reported accordingly. 
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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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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. 
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Argyll and Bute Council 
Internal Audit Report
August 2022
Final   
Contact Details 
Internal Auditor: Leanne Rennie
Telephone:  01369 708516
e-mail:   leanne.rennie@argyll-bute.gov.uk 
LiveArgyll 
Establishment Visit
Campbeltown Aqualibrium & Library 
Audit Opinion: Amber 
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Library –August 2022
1. Executive Summary
Introduction
As part of the 2022/23 internal audit plan agreed with LiveArgyll management, we undertake
establishment visits at LiveArgyll sites. LiveArgyll operate 26 establishments and we had agreed that
22 of these would be subject to establishment visits over a four year cyclical basis. As a result of
Covid19, this delayed a number of Establishment visits which we intend to undertake over the next 2
years to bring visits back up to date.
1. Appendix 1 sets out the schedule of establishment visits which focus on the areas set out in
exhibit 1 and we have agreed checklists for each area with LiveArgyll management.  
Exhibit 1 – Establishment Visits Areas of Focus
Building Exterior Floors Environment Baby Changing Units
Doors Public Spaces Signage Income Collection / Facility Booking
Ceilings Windows Fixtures & Fittings Floats
Walls Elevators Toilets Banking
Swimming Pool /
Health Suite
Library Sports Hall / Gym Staff 
2. The audit tests are predominantly observational so any issues highlighted are based on what was
witnessed on the visit day. Due to the limiting nature of audit evidence we do not include
recommendations in this report.  Rather it provides an overview of issues identified allowing the
LiveArgyll management team to determine whether any corrective action is required.
3. To ensure consistency of approach, the issues raised do not take account of any planned
structural work in the short to medium term. For example, if we identify superficial structural
damage we will still report it even if we are aware the establishment is due to be refurbished.
Background
4. On 19th July 2022 we visited the Campbeltown Aqualibrium and Library. The scope of the audit
was to assess the site against the audit questions agreed with LiveArgyll. 
Audit Opinion
5. We provide an overall audit opinion for all the establishment visits we conduct. This is based on
our judgement on the extent to which there are issues requiring corrective action and how
critical they are.  We assess establishment visits as either:
 Red – Intervention is required to correct material areas of concern
 Amber – Issues identified can be managed through a programme of works 
 Green – Issues identified are relatively minor 
6. Our overall opinion for this establishment visit is Amber. This means that whilst we have
identified issues we are not of the view that they post an immediate risk to service delivery.
However, management should consider how best to address the issues within a reasonable
timescale. 
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Findings
7. Exhibit 2 summarises the conclusions of the work and any observations made on the day of the
visit. 
Exhibit 2 – Summary Assessment of Control Objectives 
Area Strengths Areas for Consideration
1 Building
Exterior
On approach the building conveys the
appropriate corporate image.
None.
2 Doors The main entrance doors open freely. None.
3 Ceilings All ceilings are in good condition with no
cracks or water damage. 
There are several ongoing leaks
throughout the building and
although these have been
reported and repaired to some
degree they need to be
addressed to maintain the
functionality of all areas and
minimise the risk to staff and
users of the facility.
4 Walls All walls are clean and damage free, no
posters on walls. Skirting is secure.
None.
5 Floors &
Public Spaces 
Floors are predominantly clean throughout.  None.
6 Windows  Windows are clean and tidy with no visible
cracks or damaged frames and poolside
windows open and close freely. No posters
are on the windows. 
None.
7 Elevators There are two elevators, which are in good
working order and kept clean and tidy.
None.
8 Environment There is adequate lighting and ventilation
and noise levels are acceptable. All lights are
in good working order and bins are emptied
several times a day. 
None.
9 Signage Internal signage all in place. None.
10 Noticeboards
& Leaflets
There is adequate and up to date
noticeboards and leaflets.
None.
11 Furniture,
Fittings &
Equipment
All furniture and fittings are in good clean
order and not in a hazardous position. All
sockets are in good working order.
None.
12 Toilets  The toilets are predominantly clean and tidy. None.
13 Baby
Changing
Units
Baby changing units are in good clean
condition.
None.
14 Swimming
Pool
The shop is well stocked and clean and tidy. 
The swimming pool area is well lit with no
visible breakages to floor or wall tiles. The
changing village is clean and tidy with no
apparent breakages to tiles on the walls or
the floor.  The health suite is clean and tidy.
None.
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Area Strengths Areas for Consideration
15 Sports Hall,
Gym and
Studios
The gym is clean and tidy adequately lit and
well equipped. All machines appear to be in
good working order. 
None.
16 Libraries All books are kept in good order on the
shelves and are clean and tidy. There is no
discarded stock inappropriately disposed of. 
The public access computers are all in
working order. 
None. 
17 Income
Collection
There are two vending machines which are
emptied on a weekly basis by two staff.
None. 
18 Booking of
Facilities
No events are held at the Aqualibrium,
however the hall can be booked for
meetings/conferences.
None.
19 Floats Floats are checked on a daily basis by the
Senior Duty Officer. 
None.
20 Banking Banking is performed on a daily basis by the
Senior Duty Officer at the local post office.
None. 
Management Response
LA fully adhere to all agreed maintenance protocols with Council partners. Water ingress issues have
been regularly reported and whilst some remedial action(s) have taken place, the overall issue
remains.  Some provision has been made within the Council’s Strategic Asset Management Plan
(SAMP) for further investigative works. 
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Appendix 1 – Establishment Visit Schedule 2022-24 
2022/23 2023/24 Complete
Leisure     
Aqualibrium     
Helensburgh Pool    
Riverside Leisure Centre      
Rothesay Leisure Pool      
Mid Argyll Sports Centre    
Libraries     
Campbeltown    
Cardross    
Dunoon     
Helensburgh      
Lochgilphead     
Oban In progress   
Rosneath      
Rothesay      
Tarbert    
Sandbank Office  N/A N/A N/A
Halls & Community Centres     
Queens Hall, Dunoon      
Victoria Hall, Campbeltown    
Victoria Halls, Helensburgh      
Corran Halls, Oban In progress   
Kintyre Community Education Centre    
Lochgilphead Community Centre    
Moat Centre, Rothesay      
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Argyll & Bute Health & Social Care Partnership
Internal Audit Report
September 2022
FINAL 
High Medium Low VFM
Number of Findings 0 1 0 0 
Performance Management
Audit Opinion: Substantial 
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HSCP, September 2022 
Contents 
1. Executive Summary ........................................................................................................................ 3
Introduction ............................................................................................................................................ 3
Background ............................................................................................................................................. 3
Scope ....................................................................................................................................................... 4
Risks ........................................................................................................................................................ 4
Audit Opinion ......................................................................................................................................... 4
Recommendations ................................................................................................................................. 4
2. Objectives and Summary Assessment ........................................................................................... 4
3. Detailed Findings ............................................................................................................................ 5
Appendix 2 – Audit Opinion ................................................................................................................. 11 
Contact Details 
Internal Auditor: Paul Macaskill
Telephone:  01546 604108 
e-mail:   paul.macaskill@argyll-bute.gov.uk 
www.argyll-bute.gov.uk
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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 & Bute Health & Social Care Partnership
(HSCP) system of internal control and governance in relation to Performance Management.
2. The audit was conducted in accordance with the Public Sector Internal Audit Standards (PSIAS)
with our conclusions based on discussions with Health & Social Care Partnership 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 HSCP.
3. The contents of this report have been agreed with the appropriate Health & Social Care
Partnership 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. Effective performance reporting ensures that non-executive appointees, elected members and
senior management have the information that allows them to effectively scrutinise HSCP’s
performance against agreed key priorities and objectives. Fundamental to this is the Integrated
Performance Management Framework (IPMF) document which sets out the Partnership’s
approach to performance monitoring.
5. The Performance Management Framework document sets out the following messages namely :
 Roles and responsibilities need to be clearly identified;
 managers need to be involved in the development of the KPI’s to ensure ownership and
keep them relevant to their services and improved service outcomes; 
 need to learn from what has worked and what has not with regards to previous
performance reporting;
 data is accessible for all managers across health and social care;
 performance reporting needs to capture manager commentary to give context and allow
for more challenging discussions with regards to addressing poor performance and
understanding the local context;
 development of a performance culture needs to be progressive and responsive to wider
organisational issues. 
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Scope 
6. The scope of the audit was to assess the adequacy of, and compliance with HSCP’S Performance
Management Framework arrangements as outlined in the Terms of Reference agreed with the
Senior Performance and Improvement Manager on 27th July 2022.
Risks
7.  The risks considered throughout the audit were:
 Audit Risk 1: HSCP does not have an effective Integrated Performance Management
Framework
 Audit Risk 2: Performance targets are not regularly monitored and reviewed
 Audit Risk 3: Roles and responsibilities are not clear
 Audit Risk 4: Performance reporting is not carried in line with Performance Management
Framework
Audit Opinion
8. 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.
9. 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
10. We have highlighted one medium priority recommendations where we believe there is scope to
strengthen the control and governance environment. These are summarised below:
 HSCP performance information should be made available on the Councils performance
information system
11. 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
12. 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
CO1 HSCP’s Performance
Management
Framework clearly
sets out the
Audit Risk 1  Substantial Performance reporting during the
pandemic focussed on addressing the
re-mobilisation of services. This new
approach was as per guidance from
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planning
performance and
improvement
functions.
the Scottish Government and was
based upon 6 priority areas. A revised
IPMF is currently being prepared and
will focus on eliminating long waits in
both inpatient and outpatients
services.
CO2 Appropriate
performance
targets are agreed
annually,
communicated and
periodically
reviewed.
Audit Risk 2
Audit Risk 3
Substantial Performance targets during COVID
were set at 70%-80% of THE 2019/20
service activity as at November 2021.
Targets were agreed with the Scottish
Government. Performance reporting
will be based upon a revised set of
targets that reflect priorities going
forward. 
CO3 Performance is
regularly monitored
and reported. 
Audit Risk 4 High Performance is regularly reported to
the IJB at their bi-monthly meetings.
HSCP performance information
should be made available on the
Councils performance information
system. A comprehensive annual
report for 2020-21 which includes a
summary of performance against
targets has been published. 
13. Further details of our conclusions against each control objective can be found in Section 3 of this
report.  
3. Detailed Findings
HSCP’s Performance Management Framework clearly sets out the planning performance and
improvement functions.
14. Due to service pressures arising from the pandemic during 2020/21, there has been some
disruption to Performance reporting as the HSCP focussed on addressing the pandemic and re-
mobilisation of services. The Scottish Government (SG) Cabinet Secretary for Health in
December 2020 directed Chief Executives in both Local Authorities and Health Boards to
prioritise critical service provision. 
15. The change to performance reporting to reflect this directive was agreed at the January 2021
Integrated Joint Board (IJB) i.e. the IJB board agreed to a “temporary suspension of normal
outcome performance reporting and instead performance reporting will focus on remobilisation
of health and care services and COVID-19 related activity”. Prior to the suspension HSCP
Performance reporting was based upon reporting against the HSCP Health & Wellbeing Outcome
Indicators.
16. During the period 2021 -2022 HSCP adopted the NHS Highland Remobilisation Plan which
describes a system to support the delivery of services for acute and social care within the HSCP
and wider NHS Highland Board. The plan focused on the areas agreed as priorities with the
Scottish Government. An extensive suite of remobilisation performance indicators were
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developed and reported on a weekly and monthly basis to inform managers with regards to their
performance against key remobilisation targets. 
17. The Remobilisation Plan was based upon 6 key principles namely :
 Establishment of a clinical priority matrix;
 protection of essential services e.g. mental health, cancer services;
 active waiting list management;
 realistic medicine remaining at the core;
 review of long waiting patients;
 patient communication.
18. The NHS Scotland Chief Operating Officer has recently written to all NHS Boards identifying a
new focus with regards to eliminating long waits in both inpatient and outpatients services.
Consequently HSCP are currently preparing a revised IPMF that will address performance in
these areas.
19. A review of the proposed IPMF found it to be comprehensive covering the following areas
namely:
 Overarching Principles
 Reporting Responsibilities and Timescales
 Performance Reporting and Data Governance 
20. Key Performance Indicators The revised IPMF is scheduled to be adopted during
2022/23.Governance of the IPMF will be carried out via the Clinical and Care Governance
Committee, however current governance of Performance reporting will continue to be carried
out by the IJB until the new arrangements come into force.
21. Prior to the changes performance monitoring was based upon a suite of outcomes which
focussed on the experience and quality of services for people using those services, carers and
their families. Reporting was carried out against 9 key National Health and Well-being outcomes
and 23 sub indicators. These outcomes and indicators formed the basis for reporting for all
HSCPs across Scotland. Examples of outcomes are :
 People are able to improve their health;
 people are able to live in the community;
 people have positive service user experience;
 services are centred on quality of life;
 services reduce health inequalities
 unpaid carers are supported
Appropriate performance targets are agreed annually, communicated and periodically reviewed.
22. Performance targets during COVID were set at 70%-80% of 2019/20 service activity as at
November 2021. These targets were agreed with the Scottish Government.
23. Example of performance reporting relating to Adult Care as at June 2022 is shown below: 
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HSCP, September 2022
Service  Target  Actual Variance
Total no. of
Adult
referrals
716 916 28%
Adult
Protection
referrals
224 258 15%
Total new
people in
receipt of
homecare
36 26 -28%
Total new
care home
placements
16 14 -13%
Total no. of
delayed
discharges 
10 9 -10% 
Targets have not been updated over the last 2 years but have remained based on the Scottish
Government requirement of 70%-80% of 2019/20 service activity as at November 2021.
24. Performance reports include comparisons against all other Scottish health Boards as regards
waiting times. As at May 2021 NHS Highland Board have 48% proportion of Outpatients waiting
more than 12 weeks, statistically this is below the overall proportion for Scotland at 50%.
25. A review of performance reports confirmed that performance reporting was in line with SG
guidance during the relevant periods.
26. New Key Performance Indicators have been established with a series of targets across both
inpatient and outpatient specialities for 2022/24. This will replace the previously reported
Remobilisation targets identified within the NHS Remobilisation plan. 
Performance is regularly monitored and reported.
27. The IJB meets bi-monthly with performance reporting being a standard agenda item. The Head
of Strategic Planning and Performance presents to the IJB Board meetings an update on the
impact on service performance with regards to Covid19 pandemic and the progress made with
regard to remobilising health and social care services in Argyll & Bute.
28. A review of the Performance reports found them to be comprehensive and cover the following
areas:
 Covid 19 overview
 Immunisation performance
 Remobilisation performance against all HSCP services
 Waiting times performances
 Virtual new and return outpatient performance
29. The IJB is required to set a balanced budget each year and therefore has to deliver Health and
Social Care Services to the communities it serves within the financial resources available to it.
Financial performance is reported in detail to the IJB at each of its meetings and to its Finance
and Policy Committee which meets on a monthly basis. It also publishes its Annual Report and
Accounts which are subject to independent external audit.
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HSCP, September 2022
30. The budget for 2020/21 required new savings of £5.7m to be delivered. In addition there were
£4.7m of previously agreed savings still to be achieved, making the total savings due to be
delivered in year to £10.4m. The HSCP reported an under spend of £1.1m for the financial year
2020/21 which enabled early repayment of debt owed to Argyll & Bute Council.
31. Up until 2020 HSCP performance reporting was highlighted via the Councils Pyramid
Performance Management information system against a suite of outcomes which focussed on
the experience and quality of services for people using those services, carers and their families.
However since 2020 there has been no performance reporting of any kind for HSCP services via
Pyramid.       
Action Plan 1
32. It is a requirement by the Public Bodies (Joint Working) (Scotland) Act 2014) that A&B HSCP
produce an Annual report. The report provides an opportunity to report to partners and local
communities an update on annual performance. The 2020-21 report provided a commentary on
performance across all relevant service areas including the following:
 Covid 19 performance;
 remobilisation performance reporting;
 homecare;
 residential care;
 mental health;
 delayed discharge;
 service referral activity;
 waiting times;
 virtual appointments;
 benchmarking;
 performance outcomes and improvements;
Included within the report is a comparison of actual spend against budget for all services with a
commentary attached in regard to the financial outlook, risks and plans for the future. It was
noted that the total spend across all services was 0.4% below budget. The 2021-22 report is
currently in draft form and will be published shortly.
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Appendix 1 – Action Plan 
No Finding Risk Agreed Action Responsibility / Due Date
Medium
1 Pyramid Reporting
Up until 2020 HSCP performance reporting was
highlighted via Councils Pyramid Performance
Management Information system, however, since 2020 no
performance reporting for HSCP services has been
included.
Failure to report
performance on
Pyramid may lead to
ineffective decision
making.
The new national focus
on the remobilisation
and waiting times,
effectively made the
current HSCP
performance
management defunct. 
This affected all the
HSCP’s with a radical
shift to address
recovery from Covid.
The Dashboard
supporting the IPMF will
form the new reporting
and hopefully be built
on the system that
replaces Pyramid for the
council next year. 
Douglas Hunter, Senior
Manager Performance &
Improvement (HSCP) 
March 2023 
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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 HSCP to achieve better
value for money (VFM). 
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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. 
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Argyll & Bute Health & Social Care Partnership
Internal Audit Report
November 2022
FINAL 
High Medium Low VFM
Number of Findings 0 3 0 0 
Directions
Audit Opinion: Substantial 
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Contents 
1. Executive Summary .............................................................................................................. 1
Introduction................................................................................................................................. 1
Background.................................................................................................................................. 1
Scope........................................................................................................................................... 2
Risks ............................................................................................................................................ 2
Audit Opinion .............................................................................................................................. 2
Recommendations ....................................................................................................................... 2
2. Objectives and Summary Assessment.................................................................................... 3
3. Detailed Findings .................................................................................................................. 4
Appendix 1 – Action Plan.............................................................................................................. 8
Appendix 2 – Audit Opinion........................................................................................................ 11 
Contact Details 
Internal Auditor: Mhairi Weldon  
Telephone:  01546 604294 
e-mail:   mhairi.weldon@argyll-bute.gov.uk 
www.argyll-bute.gov.uk
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1. Executive Summary
Introduction
1. As part of the 2022/23 internal audit plan, approved by the Audit & Risk Committee in April
2022, we have undertaken an audit of Argyll & Bute Health & Social Care Partnership (HSCP)
system of internal control and governance in relation to Directions.
2. The audit was conducted in accordance with the Public Sector Internal Audit Standards (PSIAS)
with our conclusions based on discussions with Health & Social Care Partnership 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 HSCP.
3. The contents of this report have been agreed with the appropriate Health & Social Care
Partnership 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. The Public Bodies (Joint Working) (Scotland) Act 2014 (The Act) provided the legal framework for
the Integration of Health and Social care in Scotland.  This means that Argyll and Bute Council
and NHS Highland delegate certain functions to the Argyll and Bute Integration Joint Board (IJB). 
In order to secure the performance of these functions, the IJB must give a direction to either the
Council or NHS Highland to carry out these functions in terms of sections 26 and 27 of the Act.
5. Section 29 of the Act places a duty on Integration Authorities to develop a strategic plan, also
known as a strategic commissioning plan, for integrated functions and budgets under their
control.  The legislation sets out what functions and budgets must be delegated and those that
may be delegated.
6. Each Integration Authority must set out how they will plan and deliver services for their area
over the medium term using integrated budgets under their control.  Stakeholders must be fully
engaged in the preparation, publication and review of the strategic commissioning plan in order
to establish a meaningful co-production approach to enable Integration Authorities to deliver
the national outcomes for health and wellbeing, and achieve the core aims of integration.
7. A full list of the functions and associated directions issued to Argyll and Bute Council and NHS
Highland was appended to a report submitted to the IJB 28 September 2016.  This report also
stated that these functions must be performed in accordance with all legal and regulatory
requirements and payments must be specified.  The appendix noted that the Direction will be
for the period from 1st April 2016 with no end date, however, it is also noted that this Direction
may vary and further Directions to either replace or expand on this Direction may be issued.
8. The Scheme of Integration listing these functions was revised and subsequently approved by
Scottish government in March 2021.  This scheme states that the annual direction from the IJB
to the Council and NHS Highland will take the form of a letter from the Chief Officer referring to
the arrangements for delivery set out in the Strategic Plan and will include information on:
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 The delegated functions(s) that are being directed
 The outcomes and activity levels to be delivered for those delegated functions
 The amount and method of determining the payment to carry out the delegated
functions.
Once issued, these can be amended or varied by a subsequent direction by the IJB.
9. The IJB issued 3 directions in 2020-21 and one each in the following 2 years at the time of
budget setting.  It is considered that formal directions are not required for the majority of
actions to take place due to the good working relationships in place between the HSCP, NHS and
the Council.
Scope 
10. The scope of the audit was to provide assurance over the arrangements for Directions Setting
including compliance with the January 2020 statutory guidance as outlined in the Terms of
Reference agreed with the Chief Officer on 14 November 2022. 
Risks
11.  The risks considered throughout the audit were:
 SRR01:  Financial Sustainability
 SRR02:  Delivery of Strategic Objectives
 SRR05:  Partnership Working
 SRR16:  Support Services
 Audit Risk 1:  Failure to comply with statutory guidance 
Audit Opinion
12. 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.
13. 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
14. We have highlighted three medium priority recommendations where we believe there is scope
to strengthen the control and governance environment. These are summarised below:
 A Directions Policy should be prepared and submitted to the IJB Committee for approval
and subsequent implementation.
 A process should be put in place to monitor progress in implementing directions and this
information should be used to update the Directions Log.  A unique reference number
field should also be added to the Log.
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 Performance reports submitted to IJB Committee meetings should include a summary of
directions issued and the progress made towards implementing the content of those
directions. 
15. 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
16. 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 Strategic
Commissioning Plan
has been prepared
in accordance with
Scottish
Government
Guidance.
All Risks Substantial A Strategic Commissioning Plan and
other planning documents have been
prepared in accordance with Scottish
government Guidance, however, a
Directions Policy has not yet been
prepared and submitted to the IJB
committee for approval and
subsequent implementation.
2 Directions are
aligned to the
Strategic
Commissioning Plan
setting out how each
integrated function
is to be exercised
and the associated
budget
All Risks Substantial Directions issued are clearly aligned to
the Strategic Commissioning Plan
covering all functions of the IJB and the
allocated financial resources.  Reports
submitted to the IJB committee
contain a directions section and was
completed in all relevant instances. 
Directions issued by Argyll and Bute IJB
are consistent with those issued by
two other IJBs albeit in a different
format.
3 Directions are issued
to the appropriate
authority when
required, are logged
and followed up to
ensure they are
carried out in
pursuit of the
purpose intended.
SRR01 Reasonable Directions are promptly issued at the
same time as the associated report is
approved at the IJB Committee.  A
directions log has been prepared and
maintained, however, it does not
contain a unique reference for each
direction nor a field to record the
current status/progress in
implementing the content of the
direction.  There was no evidence
within the IJB Committee papers to
suggest that the content of the
directions issued May and November
2020 had been fully implemented. 
17. Further details of our conclusions against each control objective can be found in Section 3 of this
report.  
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3. Detailed Findings
A Strategic Commissioning Plan has been prepared in accordance with Scottish Government
Guidance
18. The IJB has in place a Joint Strategic Plan 2022-25, a Joint Strategic Commissioning Strategy
2022-25 and a revised Scheme of Integration 2021.  These are comprehensive documents that
are consistent with the aims of integration, they clearly list all of the functions that have been
delegated to the IJB and the underlying legislation.  There is also clear linkage to key priorities
and commissioning intentions as well as addressing both local and national outcomes and
objectives.
19. The Strategic Commissioning Strategy contains a detailed explanation of what commissioning is,
who the strategy is for, governance arrangements, models used and how outcomes are
monitored.  There are also links to several national plans and strategies as well as those
prepared at a local level.
20. The stages of the commissioning cycle are analysed using various data sets including population
statistics, indicators of health and wellbeing, and activity and spend profiles by service and
locality.
21. Appropriate engagement has taken place and feedback received has been collated and
considered in the preparation of the Strategic Commissioning Strategy.  Additional consultation
has taken place in accordance with the budget setting process.
22. The mechanism to action the content of the Strategic Commissioning Strategy is through the use
of binding Directions from the IJB to one or both of the health board and local authority.
23. Scottish Government guidance states that a Directions Policy should be prepared, this
requirement was raised in a report submitted to the IJB committee in November 2020 but as yet
a Directions Policy has not yet been prepared.
Action Plan 1
Directions are aligned to the Strategic Commissioning Plan setting out how each integrated
function is to be exercised and the associated budget
24. There were five directions issued over the last three years, three in respect of annual budget
allocations, one for HR resourcing and one for information governance. 
25. As part of the budget setting process of the IJB, a direction is issued to both the Council and NHS
Highland referring to each of the functions as set out within the IJB Scheme of Integration and
the underlying legislative requirements.  Two additional directions were issued in 2020 in
respect of HR resourcing and information governance, these directions were included within the
respective reports containing the full details.
26.  The annual directions in respect of the budget proposals are generic, contain the high level
budget allocation and refer to the content of the more detailed budget report submitted to the
same committee in March each year that includes an appendix showing the budget allocation to
each function.  The budget is based on the mid-range scenario as outlined in previous planning
documents and had been in development since October the previous year with the Finance and
Policy committee and IJB kept informed of progress through a number of Budget Outlook
reports, proposed savings and consultation results.  
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27. The HR resourcing direction does not include the budget allocation, however this is included
within the content of the main body of the report.  The information governance direction does
not include budget allocations as they are not required, this direction is instructing the
implementation of a new policy to manage information as part of normal working practices and
should be complied with utilising existing budget allocations.  
28. All five directions are linked to the service planning and design phase of strategic commissioning
and appear to meet all clinical and care governance requirements and standards to ensure
patient safety and public protection as well as ensure staff and financial governance.
29. The directions issued were in writing and identified either the Council or NHS Highland as the
recipient.  The directions clearly drew upon the content of the associated reports submitted to
the same IJB committee meetings which contained sufficient detail to allow the functions to be
performed and achieve the desired outcome.  
30. The directions attached to the budget reports presented to the March IJB committee meetings
each year are written in a standard template format.  These directions clearly state that the
functions delegated to the IJB should be carried out by the Council and NHS Highland as
specified in the scheme of integration with the full details of the functions to be carried out
embedded within the relevant legislation attached to each function.
31. Both of the additional directions issued in 2020 were clearly written as a paragraph of text
within the directions section of the report containing the specific details.
32. The budgets allocated to the functions are carefully monitored via the budget monitoring
process, human resources via workforce planning and establishment reviews and functions
activity via quarterly performance reports.  
33. Directions are submitted to the IJB committee as draft and become formal directions once
approved.  There are four voting members each from the Council and NHS Highland and
representatives also attend from various service areas, the independent sector and the general
public on the IJB committee.  The directions are considered to have been issued to appropriate
senior executives upon approval by the IJB committee and no further action mandate is
prepared.
34. Ninety reports have been submitted to the IJB committee since March 2021, the reports were
reviewed to assess if a direction should have been issued in accordance with their content. 
Directions were found to have been issued as a result of the annual budget process in March
each year and were not considered to be required in connection with the remaining 88.  
35. All reports reviewed contained a designated section for directions that allowed the author to
complete a tick box indicating whether they considered a direction was required and if so
whether this was for the Council, NHS Highland or both.  All but two directions sections within
the reports were found to have been appropriately completed.  The two that were incorrectly
completed indicated that a direction was required for the Council in respect of the annual review
of charges for services provided.  A direction was not required for each of these as the fees and
charges are reviewed as part of the annual budget process and therefore included within the
generic annual budget directions.
36. The content of directions submitted to four other IJBs was reviewed and compared to those
issued by Argyll and Bute IJB.  The results are as follows:
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 Glasgow City IJB – an annual directions report is prepared which lists all directions issued
in the previous 12 month period.  The most recent report was issued in June 2022 and
listed a total of 31 directions.  Each direction has a unique reference number, one being
consistent with the budget setting process and the remainder relating to adjustments to
funding and delivery of services.
 CNES IJB – budget directions to the Council, NHS and Alcohol and Drugs Partnership are
submitted to an IJB meeting following the budget approval meeting.  Each function is
detailed separately within the direction and includes details of the operational delivery
arrangements, the underlying legislation for each function, the budget resource
allocated, linkage to the Strategic plan and any additional notes. 
 Borders IJB – Formal directions were submitted to the IJB committee from March 2022
following agreement of a directions Policy at the December 2021 committee.  The
directions included one to implement the agreed budget by both the Council and NHS in
line with the content of the separate report submitted to the same committee.  The
remaining directions referred to the development of plans and a business case.
 Dumfries & Galloway IJB – an annual directions report is prepared with the full
directions log appended.  All directions issued for the year 2021-22 were in May 2021 in
relation to annual budget allocations.  Each function is listed as a separate direction with
unique reference number along with the detail and the desired outcomes.  
37. Argyll and Bute IJB direction setting is therefore consistent with those submitted by CNES and
Dumfries and Galloway IJBs albeit in varying formats.
Directions are issued to the appropriate authority when required, are logged and followed up to
ensure they are carried out in pursuit of the purpose intended.
38. Draft directions are submitted to the IJB committee meeting along with the associated report. 
Once approved by the committee, they are considered to have been issued to the Council, NHS
Highland or both at that time, there is no time-lag involved.
39. A directions log is appropriately maintained on an Excel spreadsheet and includes the following
fields to record information:
 report title – refers to the function concerned
 the date of issue – IJB committee meeting date
 Decision – notes whether the Council, NHS Highland or both are to receive the directions
and also contains the resources allocated or refers the reader to the relevant IJB
meeting agenda item containing the resource information to carry out the direction 
 Comments – indicates current status of the direction or any issues raised
 Author/Contact & Presented by – identifies the report author and the officer presenting
the report to the IJB committee
The log does not contain a field to record a unique reference number as suggested within the
2020 Scottish Government Guidance.
Action Plan 2
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40. The Directions log is monitored by the Business Improvement Manager, HSCP, however the
progress in implementing the content of directions issued is not currently reported to the IJB
committee.
Action Plan 3
41. The Directions log indicates that all directions issued have been completed, however, there is no
comment in respect of the May 2020 direction regarding HR Resourcing to confirm that the
temporary posts funded had been terminated.
Action Plan 2
42. The information governance policy attached to the November 2020 direction requests that
annual assurance is provided to the IJB regarding arrangements in place at both the Council and
NHS Highland.  There was no evidence that this has been provided within the IJB Committee
documents reviewed.
Action Plan 2
43. The direction issued in respect of the 2022-23 annual budget has also been recorded as
complete, however this budget year is still in progress.
Action Plan 2 
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Appendix 1 – Action Plan 
No Finding Risk Agreed Action Responsibility / Due Date
Medium
1 Directions Policy
Finding:  A Directions Policy has not been prepared in
accordance with Scottish Government Guidance. 
Recommendation:  A Directions Policy should be prepared
and submitted to the IJB Committee for approval and
subsequent implementation.
It may be unclear when
a direction is required
to be issued.
A Directions Policy will
be prepared and
submitted to the IJB
Committee
Business Improvement
Manager 
31 March 2023
Medium
2 Directions Log
Finding:  There is no field within the directions log to
provide a unique reference for each direction issued.   
Finding:  the direction issued in respect of the 2022-23
annual budget has been noted as complete, however, the
budget year is still in progress. 
Finding:  There was no evidence that the temporary posts
funded as a result of the direction had been terminated
upon conclusion of the 23 month agreed period. 
Finding:  There was no evidence within the IJB committee
papers that assurance had been provided regarding
information governance arrangements within the Council
or NHS Highland. 
Recommendation:  A process should be put in place to
monitor progress in implementing directions and this
information should be used to update the Directions Log. 
A unique reference number field should also be added to
the Log.
Directions may not
comply with Scottish
Government guidance. 
The directions log may
provide an inaccurate
reflection of progress
made.
A process will be put in
place to monitor
progress in
implementing directions
and this information will
be used to update the
Directions Log.  A field
will also be added to the
Directions Log to assign
a unique reference
number to each
direction.
Business Improvement
Manager 
31 March 2023
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No Finding Risk Agreed Action Responsibility / Due Date
Medium
3 Performance Management
Finding:  Progress in implementation of directions is not
currently reported to the IJB committee. 
Recommendation:  Performance reports submitted to IJB
Committee meetings should include a summary of
directions issued and the progress made towards
implementing the content of those directions.
The IJB may not be
compliant with Scottish
Government Guidance
and committee
members may not be
aware of the progress
being made in
progressing directions.
Performance reports
will include a summary
of directions issued and
the progress made
towards implementing
the content of those
directions.
Business Improvement
Manager 
31 March 2023 
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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 HSCP to achieve better
value for money (VFM). 
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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. 
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Argyll & Bute Health & Social Care Partnership
Internal Audit Report
December 2022
FINAL 
High Medium Low VFM
Number of Findings 0 0 0 0 
Commissioning
Audit Opinion: SUBSTANTIAL 
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2022 
Contents 
1. Executive Summary .............................................................................................................. 3
Introduction................................................................................................................................. 3
Background.................................................................................................................................. 3
Scope........................................................................................................................................... 4
Risks ............................................................................................................................................ 4
Audit Opinion .............................................................................................................................. 4
2. Objectives and Summary Assessment.................................................................................... 4
3. Detailed Findings .................................................................................................................. 6 
Contact Details 
Internal Auditor: Moira Weatherstone 
Telephone:  01546 604146 
e-mail:   moira.weatherstone@argyll-bute.gov.uk 
www.argyll-bute.gov.uk
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2022
1. Executive Summary
Introduction
1. As part of the 2022/23 internal audit plan, approved by the Audit & Risk Committee in April
2022, we have undertaken an audit of Argyll & Bute Health & Social Care Partnership (HSCP)
system of internal control and governance in relation to Commissioning. 
2. The audit was conducted in accordance with the Public Sector Internal Audit Standards (PSIAS)
with our conclusions based on discussions with Health & Social Care Partnership 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. 
3. The contents of this report have been agreed with the appropriate Health & Social Care
Partnership 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. The HSCP is responsible for the planning and delivery of health and social care services for adults
and children within Argyll & Bute. Public services may be delivered internally, commissioned
through providers of health and social care or by community or social enterprise groups.  The
Care Act requires local authorities to help develop a market that delivers a wide range of
sustainable high quality care and support services through the provision of care at home or
residential care home services. 
5. Strategic commissioning in the adult, children and young people health and social care context
relates to all of the activities involved in assessing and forecasting need, linking investment to
agreed outcomes, identifying and considering options, planning the nature, range and quality of
future services and working in partnership to put theses in place. There are different ways to
approach commissioning, however the principles are in line with the independent Review of
Adult Social Care (IRoASC) where they are collaborative in their approach.   
6. The HSCP objectives have been developed through engagement with partners, staff and the
public, with the publication of the Commissioning Strategy 2022/2025 (the Strategy).  The
Strategy has been developed using the best practice guide form the Scottish Government,
applying the four steps of the Commissioning Cycle; Analyse, Plan, Deliver and Review.  The
Strategy is for all providers and potential providers of health and social care, for community or
social enterprise groups and for people who use, or work in, health and social care services. 
7. The strategy will be future proofed in line with the IRoASC which recommends that Integration
Joint Boards should continue to develop strategic commissioning plans, and should be given
direct responsibility for procurement, holding contracts and contract monitoring. 
8. As is the case in any market, providers may leave from time to time sometimes because they
have failed financially or operationally. The care services may be sold or taken over by another
provider(s), fail to meet regulatory standards or fail to make the necessary improvements to
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maintain standards in social care or be unable to recruit staff. When care providers leave the
market and close services, managing the situation and withdrawal from the market is really
important as disruption to care services can cause distress and pose real risks to people’s health
and wellbeing.  It can also cause stress and anxiety for families and carers of those who use the
service.
Scope 
9. The scope of the audit was to provide assurance that measures are in place to minimise the risk
and impact of commissioned service providers withdrawing from the market as outlined in the
Terms of Reference agreed with the Chief Officer (HSCP) and Chief Finance Officer (HSCP)  on 21
October 2022.
Risks
10.  The risks considered throughout the audit were: 
 SRR07: sustainability of commissioned service providers
 Audit Risk 1: HSCP does not have effective measures in place to minimise the risk of
commissioned service providers withdrawing from the market
 Audit Risk 2: failure to have robust contract management arrangements in place
 Audit Risk 3: failure to meet client care and support needs
Audit Opinion
11. 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 1 to this report. 
12. 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.
2. Objectives and Summary Assessment
13. 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 Measures are in
place to minimise
the risk and impact
of commissioned
service providers
withdrawing from
the market
SRR07
Audit Risk 1
High Whilst the risk of commissioned
service providers can never be fully
mitigated, measures are in place to
minimise the risk and impact of
commissioned service providers
withdrawing from the market. This
includes a risk based approach to
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assessing providers prior to
commissioning and regular ongoing
review meetings with providers
identifying any issues which can be
escalated and addressed. A mulita
agency group was formed – The Argyll
& Bute Care Homes Assurance Group
Meeting as an assurance function for
the HSCP for Care Homes and Care at
Home Services. The purpose of the
Care Home and Care at Home
Assurance Group is to provide
oversight and support to care homes
and care at home service primarily
focused on older adults.
2 Commissioning
Policies and
Procedures are in
place and being
followed
Audit Risk 2 High A commissioning strategy for all the
main care groups is in place. This is the
first Argyll and Bute Health and Social
Care Partnership Joint Strategic
Commissioning Strategy. Argyll & Bute
Council have well established
procurement policies and procedures
in place, this includes supplementary
guidance notes which are specifically
applicable to Health and Social Care
Contracts. There is also an agreed
HSCP guidance document: “Guidance
for Closure of a Care Home”.  
3 Measures are in
place to review and
monitor
commissioned
services to ensure
the ongoing
sustainability of
service provision
SRR07
Audit Risk 2
Audit Risk 3
High The Council’s Procurement Team is
heavily involved in managing
commissioned services alongside Social
Work colleagues.  They meet regularly,
with providers and identify any issues
through a scorecards system, this is
carried on through the life of the
contract and is updated regularly.
4 Measures are in
place to review
performance and
value for money
associated with
commissioned
services
Audit Risk 2
Audit Risk 3
High Monitoring overall compliance by all to
the terms of the agreement and
contract Key Performance Indicators
(KPIs) and Service Level Agreements
(SLAs) and implementing improvement
plans in the event of under-
performance is reviewed when
updating scorecards. 
14. Further details of our conclusions against each control objective can be found in Section 3 of this
report.  
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3. Detailed Findings
Measures are in place to minimise the risk and impact of commissioned service providers
withdrawing from the market
15. Commissioning of social care services is the one of the highest areas of spend in the Council and
whilst the risks of commissioned providers withdrawing from the market can never be fully
mitigated, working together the HSCP and the Council’s procurement team have put in place
measures to minimise the risk and impact of commissioned service providers withdrawing from
the market.   
16. Throughout the commissioning journey the Council’s procurement team offer an instrumental
amount of support to the HSCP in terms of ensuring that the desired outcomes are met and
there is ongoing contract monitoring. 
17. Taking a risk based approach, prior commissioning with a provider for services, numerous checks
are undertaken. As part of the pre-contract checks the Single Procurement Document (SPD)
requires to be completed. This is a set of standardised statements that have been developed to
support Procurement Officers in adopting a consistent approach to defining minimum
requirements in contract notices, these are aligned to the relevant selection questions in the
SPD (Scotland) and are available in the standardised statements document on the Procurement
Journey SPD (Scotland) website.  The Procurement Journey provides guidance for public sector
buyers who procure goods, services and care and support services. 
18. In general, the HSCP are careful about applying strict criteria that will automatically exclude
providers as it is recognised that there is a limited number of providers in Argyll and Bute. The
risks from this approach are mitigated through contract management during the life of the
contract. 
19. Argyll & Bute Care Homes Assurance Group is a multi-agency group which was set up as an
assurance function for the HSCP for Care Homes and Care at Home Services. The group covers all
care homes and care at home services within Argyll and Bute. The purpose of the Care Home
and Care at Home Assurance Group is to provide oversight and support to care homes and care
at home services primarily focused on older adults. This multi-agency group has responsibility to
address both short term actions and to link with the relevant oversight and strategic planning
groups to raise strategic issues affecting care homes and care at home services. The group also
has the responsibility to action any concerns, directly with the home or care at home provider in
the first instance, including recording agreed actions. 
20. In addition, the group requires to read daily information (5 days a week) from care homes with
an overview of Covid-19 issues, staffing, safety, PPE, testing and any other pertinent issues. 
21. Measures are in place to minimise the impact of commissioned service providers withdrawing
from the market. The HSCP guidance document: “Guidance for Closure of a Care Home”,
updated and approved in May 2022 is guidance for the Closure of a Care Home based on the
CoSLA guidance document “Good Practice Guidance on the Close of a Care Home”.  The purpose
of this document is to provide guidance for the HSCP to identify and manage any possible risks 
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22. and ensure continuity of service provision in the event of a planned or unplanned closure of a
Care Home within Argyll and Bute. Included in the guidance is an action plan for closure and
identifies a responsible person for each action point. Any contingency Plan has to be agreed and
signed off by Care Inspectorate. 
Commissioning Policies and Procedures are in place and being followed
23. The Scottish Government and COSLA jointly published guidance on the Procurement of Care and
Support Services (“the Guidance”). The Guidance aims to assist public bodies to deliver positive
outcomes for service users and carers through the delivery of good quality, flexible and
responsive services and in recognition of the significant impact that delivery of such services will
have on the quality of life, health and well-being of service users and carers. 
24. The Guidance introduces a set of Guiding Principles which include the requirements: 
 to have in place a commissioning strategy for all the main care groups should be in place
which is supported by delivery plans and works towards an overarching commissioning
strategy;
 to have written and approved policies and procedures for the procurement of care and
support services which reflect developments in self-directed support and the guiding
principles from the Guidance. 
In line with the guidance, the first HSCP Joint Strategic Commissioning Strategy (JSCS) for
everyone in Argyll and Bute who require health and social care services was approved in March
2022, covering the period April 2022 to March 2025.  Working with partners in the HSCP, the
manager of Argyll & Bute Council (the Council) Procurement Commercial and Contract
Management Team and the Senior Procurement Officer for the Council were members of the
working group. 
25. The Council’s Procurement, Commercial and Contract Management Team are involved in
contract/commissioning work to support colleagues to procure services in a way that gives the
best chance of achieving the desired outcomes and in line with the principles of the JSCS. 
26. Embedded within the JSCS is the Market Facilitation Plan which describes how the HSCP aim to
work with providers and potential providers of adult, children and young people social care in
order to ensure they deliver the best services available with the resources which they have.
Various types of contractual arrangements exist across the partnership which are clearly defined
within the JSCS: Framework Agreements/Collaborative Agreements/Grants/ Contracts for
services and supplies/Spot Purchases and bespoke arrangements. 
27. The Council have well established procurement policies and procedures in place. A Procurement
Strategy 2022-2025 and The Procurement Manual 2022 is available to all social work staff on the
intranet – HUB.  These are the overarching documents applicable to Council staff involved in the
procurement process. 
28. Within the Council’s procedures there are supplementary guidance notes, one of which provides
guidance on the procurement of Health and Social Care contracts.  This provides a summary of
the thresholds that apply to care and support contracts and identifies roles and responsibilities
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for health and social care contracts.  A separate supplementary note - the Contract Supplier
Management Toolkit explains how contracts are to be managed. 
Measures are in place to review and monitor commissioned services to ensure the ongoing
sustainability of service provision 
29. The Council’s procurement staff work alongside HSCP staff to ensure that ongoing monitoring is
undertaken.  Regular meetings are held with providers, HSCP staff, the Care Inspectorate where
appropriate and Council procurement staff.  Any issues are identified through a scorecard
system. The scorecard is reviewed and updated through the life of the contract. Meetings
identify any major or minor concerns which are then reported back to the relevant managers
with any agreed actions being taken forward. 
30. Any issues or concerns highlighted by the provider regarding the sustainability of the service are
recorded and escalated to the appropriate management and an action plan put in place to
support the provider. 
Measures are in place to review performance and value for money associated with
commissioned services 
31. A review of performance and assessment of value for money forms part of the process of
ongoing regular meetings with suppliers.  These are recorded on the provider scorecard which is
completed after each review meeting. In addition, this will also be reviewed and assessed at the
time of any contract variations or renewals. 
32. The Argyll & Bute Care Homes Assurance Group also have collective responsibility to focus on
the quality of care home/care at home experience for residents, service users and families. 
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Appendix 1 – 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. 
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1 
ARGYLL AND BUTE COUNCIL AUDIT AND SCRUTINY
COMMITTEE 
CHIEF EXECUTIVE     20 DECEMBER 2022 
COUNCIL 6-MONTH PERFORMANCE REPORT – APRIL TO SEPTEMBER 2022
__________________________________________________________________ 
1. SUMMARY 
1.1 The Performance and Improvement Framework (PIF) sets out the process for
presenting the Council’s performance reports. 
This paper presents the Council’s 6-month Performance Report for April to
September 2022. 
It is recommended that the Audit and Scrutiny Committee: 
1.2 Note that this report presents Council performance on strategic activities across all
services; 
1.3 Review and scrutinise the Councils 6-month Performance Report; 
1.4 Note that the Strategic and Area Committees have responsibility to scrutinise
operational performance; 
1.5 Note the planned activity for Performance Management and Reporting during
2022/23 onwards. 
Pippa Milne
Chief Executive 
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2 
ARGYLL AND BUTE COUNCIL AUDIT AND SCRUTINY
COMMITTEE
CHIEF EXECUTIVE     20 DECEMBER 2022
___________________________________________________________________ 
COUNCIL 6-MONTH PERFORMANCE REPORT – APRIL TO SEPTEMBER 2022 
2. SUMMARY 
2.1 The Performance and Improvement Framework (PIF) sets out the process for
presenting the Council’s performance reports. 
2.2 The paper identifies the strategic activities across council services that have
occurred during the reporting period, reports on key performance and outlines the
planned activity for Performance Management and Reporting commencing
2022/23 
3. RECOMMENDATIONS
It is recommended that the Audit and Scrutiny Committee: 
3.1 Note that this report presents Council performance on strategic activities across all
services; 
3.2 Review and scrutinise the Councils 6-month Performance Report; 
3.3 Note that the Strategic and Area Committees have responsibility to scrutinise
operational performance; 
3.4 Note the planned activity for Performance Management and Reporting during
2022/23 onwards. 
4. DETAIL 
4.1 The Performance and Improvement Framework (PIF) was approved by the
Council in September 2017. The PIF sets out the agreed framework for planning,
monitoring and reporting the Councils performance. 
4.2 To support scrutiny of performance by Elected Members and Senior Officers in
September 2020 the Performance Management Project commenced. An output
of the project to date has been to identify a suite of 47 high-level indicators
aligned to the Corporate Outcomes. These 47 indicators are known as the
Corporate Outcome Indicators – COIs. The majority of the COIs are reported
annually after FQ4 with the exception of 13 COIs which are reported quarterly to
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the Area Committees. The full list of the 47 Corporate Outcome Indicators is
attached, however work is in progress to finalise the wording for some indicators
(Appendix 1).  
4.3 The following sections detail the Council’s Management Information which are
high-level cross cutting themes such as absence, risks and complaints along
with Council activities to note.   
4.4 Absence  
Absence data for FQ1 22/23 saw increases for both Teachers and LGE on the
same quarter last year. In FQ2 22/23 teacher absence has reduced by half a day
on the same quarter last year, whereas LGE absence has increased by half a
day. 
It should be noted that sickness levels are always lowest in FQ2 for both LGE
and Teachers due to the summer holiday period.   
Figure 1:  Teacher and LGE Absence trends across each quarter since 20/21 
The top three reasons for absence in both FQ1 and FQ2 22/23 have been – 
 Stress/Depression/Mental Health
 Infections
 Other Musculoskeletal Reasons (Fracture and broken bone. This does
not include back and neck pain which has its own category) 
This is quite different from the same two quarters last year the top three reasons
being – 
 Stress/Depression/Mental Health
 Stomach/Liver/Kidney/Digestive
FQ1
20/21
FQ2
20/21
FQ3
20/21
FQ4
20/21
FQ1
21/22
FQ2
21/22
FQ3
21/22
FQ4
21/22
FQ1
22/23
FQ2
22/23
LGE 1.59 1.89 2.94 2.82 3.32 3.16 3.49 3.42 3.57 3.66
TEACHER 0.82 0.92 1.52 1.15 1.36 0.89 1.6 1.77 1.79 1.22
1.59
1.89
2.94 2.82
3.32 3.16
3.49 3.42 3.57 3.66
0.82 0.92
1.52
1.15 1.36
0.89
1.6 1.77 1.79
1.22
0
0.5
1
1.5
2
2.5
3
3.5
4
LGE
TEACHER
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 Medical Treatment
With no Covid restrictions and Covid related absence now counting in normal
sickness absence reporting figures the increase in days lost due to infections
was anticipated. However, as the NHS moves back towards business as usual a
rise in absences due to Medical Treatment has not been seen. 
The following is the analysis of the reasons for absence across the service
conditions of APTC, Manual and Teachers for all work days lost - 
 For APTC staff it was Stress/Depression/Mental Health accounting for
20% 
 For Manual Workers it was Stress/Depression/Mental Health accounting
for 34%   
 For Teachers the top reason for absence was Infections accounting for
28% 
Following consultation with staff and managers the Supporting Attendance and
Stress in the Workplace procedures were simplified and improved last year. Both
procedures are intended to have a positive impact on reducing absence. A
survey will be conducted in December 2022 to establish the impact and
customer satisfaction of the above procedures.   
The focus of the Wellbeing Team has been on supporting managers dealing with
long term absence, particularly within the HSCP. However, despite this we have
seen a continued increase in absence in this area and this must be investigated
further. Another new wellbeing initiative has just been launched in October 2022.
The Recalibrate Programme focuses on a range of lifestyle subjects and is
designed to help build healthy habits that support positive health and wellbeing.
This programme is being delivered via Teams over a 12-week period. 
4.5 Quality Conversations 
The Quality conversations approach has replaced the Council’s previous PRD
process. The focus is on ensuring managers and employees have conversations
about performance, learning and career aspirations throughout the year. The
desired outcomes are that employees are clear about what is expected of them
and have the skills and knowledge to deliver on their agreed objectives. The
approach also aims to ensure that managers feel confident and have the skills to
agree objectives with employees and deliver quality feedback and recognition for
their work, or discuss barriers to performance as well as employee career
aspirations. The previous approach did not measure these outcomes and so
initial baseline surveys for both employees and managers took place during
summer 2022. 
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The employee survey consisted of 11 questions, and the manager survey
consisted of 8 questions. Initial indications from the employee survey are that
employees know what is expected of them in their role, including the behaviours
expected, and have the knowledge and skills required to deliver their objectives. 
These surveys are currently being analysed by the HR and OD team, who
continue to support departments with the roll out of the quality conversation
approach. Feedback from the baseline surveys will be used to provide more
targeted support across the organisation. 
Going forward we will be surveying employees annually. Additionally, we will be
surveying managers on their handling of Quality Conversations, this is a
perspective we have not had from PRDs. 
4.6 Complaints   
The first 2 quarters of 2022/23 saw the number of complaints rising compared
with the last 2 quarters of 2021/22. During FQ1 and FQ2 there were 274 Stage 1
Complaints and 120 Stage 2 Complaints received. Roads and Infrastructure
Services continues to receive the majority of complaints. Performance within
timescale has decreased over the recent 2 quarters and the Compliance and
Regulatory team will continue to support services to try to improve this. 
The table below provides a breakdown by Service. A detailed Annual 
Complaints Report will be submitted to this Committee meeting. 
Stage 1 Stage 2 
Total
number
Number
in time
%
within
time
Total
number
Number
in time
%
within
time
Chief Executives      
Directorate  0 0 - 1 1 100%
Financial Services 16 13 81% 4 3 75%
Community Planning
& Development
0 0 - 0 0 -
Executive Director
Douglas Hendry      
Directorate 3 3 100% 0 0 -
Education 13 13 100% 18 15 83%
Legal and Regulatory
Support
4 4 100% 7 6 86%
Commercial Services 4 4 100% 0 0 -
Executive Director
Kirsty Flanagan      
Directorate 0 0 - 0 0 -
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Customer Support
Services
5 5 100% 0 0 -
Roads and
Infrastructure
180 146 81% 55 33 60%
Development and
Economic Growth
32 23 72% 12 6 50%
Health & Social
Care Partnership      
Adult Care - Health &
Community Care
3 3 100% 7 3 43%
Adult Care - Acute &
Complex Care
1 1 100% 5 1 20%
Children and
Families & Criminal
Justice
12 8 67% 11 6 55%
Live Argyll      
Live Argyll 1 1 100% 0 0 -
Overall Totals 274 224 82% 120 74 62% 
4.7 Audit Recommendations 
Internal and External Audit Reports are presented at this committee meeting. 
Audit recommendations are reported quarterly to the Strategic Management 
Team and actions to complete them are recorded and allocated to the 
responsible officers.  
4.8 Finance 
The performance against budget for the first six months of financial year 2022-
23 is a forecast overspend of £0.395m or 0.1%. For reference the 2021-22
forecast overspend as at September 2021 was £0.399m or 0.2%.   
Social Work, managed by the Health and Social Care Partnership, is reporting a
forecast overspend of £0.263m due to a high demand for Services. Within
Executive Director Kirsty Flanagan, there is a forecast overspend of £0.106m
mainly from an under-recovery of income within Parks and Pest Control. Central
Budgets are projecting an £0.026m overspend resulting from the Elected
Members pay award, which is set nationally via Statutory Instrument, being
greater than the available budget. 
It should be noted that the above forecast overspend does not include the
potential impact of the 2022-23 pay settlement, where negotiations were not
finalised as at the end of September 2022. 
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4.9 Strategic Risk Register (SRR) 
The Strategic Risk Register (SRR) details significant challenges and the agreed
approaches to manage them. These specific interventions are subject to scrutiny
at Strategic Committee Level and kept under review by the Council’s Strategic
Management Team. 
The reported SRR has twelve risks in total. Three are red, six are amber and the
remaining three are green. The three red risks relate to population and economic
decline, Waste Management, and Cyber Security. 
4.10 Operational Risks 
Executive Director Kirsty Flanagan has six red risks. These relate to the cost of
delivering environmental health services in relation to public health; the impact of
extreme weather on both the road network and the cost of winter maintenance;
waste disposal; the affordability of maintaining ageing bridges and retaining
walls on the road network and cyber security breach and associated attack. 
Executive Director Douglas Hendry has five red risks. These relate to delivery
failure of school kitchen supplies; capital investment to keep buildings safe and
operational; the availability of resources and funding to delivery capital projects;
compliance with the conditions of externally funded projects and increasing utility
costs associated with gas, electricity, oil etc. 
Key actions have been agreed to address these red risks and all other risks in
the operational risk registers. 
Other Strategic Activities 
4.11 Education 
Achievements
Dunoon Grammar School received an accolade as the World’s Best School for
Community Collaboration at the World’s Best School Prizes.  The winners of the
5 categories share a cash prize of US $250,000.  This is truly outstanding
achievement and as CEO I wish to highlight the key role of the Head Teacher
David Mitchell and his staff for their leadership to their pupils who are the stars of
this award. 
Attainment
The Annual Participation Measure on the economic and employment activity of
16 – 19 year olds showed a 0.4% rise for Argyll and Bute compared to 2021 with
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93.6% of young people in education employment or training.  Argyll and Bute
placed 5th out of the 32 local authorities.  
A Nurturing Council
A further ten schools in Argyll and Bute achieved accreditation for developing
nurturing cultures in their school communities bringing the total number of
schools to 18.  Part of the Council’s ‘Our Children, Their Nurturing Education’
strategy which aims to ensure that our young people have the emotional support
they require to survive.  Led by the Council’s Educational Psychology service,
the programme helps staff to better understand learner’s behaviours and put into
practice nurturing approaches to support them including children showing signs
of distressed behaviour. 
A Leading Council
In a UK first, the Council has teamed up with leading drone specialists to trial the
use of Unmanned Aerial Vehicles (drones) in delivering school meals. Flying
from Oban Airport, the trial involved delivering meals freshly prepared in Oban to
Lochnell Primary 1.5km away.  Whilst the majority of our schools have kitchens
on site preparing meals, the provision of school meals to some rural and remote
schools rely on traditional methods of transport including vans, taxis and ferries
which can be affected by weather conditions. All pupils in early years and P1 -
P5 are entitled to free school meals and the use of drones may offer an
alternative carbon free mode of transport that could reduce costs and delivery
times.  The trials are part of ambitious plans to create an Unmanned Aerial
Vehicle Innovations Logistics Hub at Oban Airport.   
LEIP – Learning Estates Investment Programme
Further to engagement with residents, the Council agreed to submit a business
case and funding application to the Scottish Government for a new school
campus on Mull.  This is the beginning of a competitive bidding process which if
successful will require a major financial commitment to the project from the
Council. 
4.12 Place 
Current Large Scale Capital Investment
The Council is currently delivering across 18 large scale projects worth £35m to the
area of which the Council’s contribution is over £5m.  Projects includes the following; 
 £10m Conservation Area Regeneration Schemes and Townscape Heritage
across Helensburgh, Dunoon, Lochgilphead and Rothesay.
 £10m Regeneration Capital Grant Funding (Scottish Government’s RCGF)
supporting 15 projects including Tiree Community Business Hub, Kerrera Old
School Community Hub and Ulva Ferry Shore Facilities Building.
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 Scottish Government Place Based Investment (£821,000). Projects include a
regional shopfront improvement scheme, public realm improvement works in
Oban and Bowmore, priority building repairs in Rothesay and Dunoon and pier
resurfacing works in Helensburgh.
 Scottish Government Islands Programme (£740,000); investment for ten projects
on Jura, Gigha, Tiree, Kerrera, Mull, Iona, Islay, Colonsay and Rothesay. 
 Scotland Loves Local (£46,000); supporting local economics and encouraging
shopping locally. 
 £1.5m public realm project to transform Lochgilphead Front Green to create a
new public square, play park, additional seating, new waling and cycling facilities
was completed.  Thanks to the funding partners:- the Cooperative’s Local
Community Fund, the Lochgilphead Phoenix Project and two Scottish
Government funds, Cycling, Walking and Safer Routes (CWSR) and Town
Centre Funds. 
Work to improve the waterfront in Ardrishaig has commenced.  The £700,000
scheme will create a new public square, improved car parking,  additional seating
within a new loch-side viewing area,  art work and improved accessibility for the
Argyll Sea Kayak Trail to make it easier for kayakers to go between Loch Fyne and
the Crinan Canal. 
The new £23m leisure centre and swimming pool was completed on time and
budget.  Part of a wider waterfront regeneration strategy, the facilities includes a
luxury health suite with steam room and sauna, a café, shop, fitness studios and a
gym with panoramic views of the river Clyde.  The project includes new flood
defences on the waterfront.  Thanks to the UK Government from £5m from the Libor
Fund and £100,000 from Sports Scotland. 
Helensburgh Pier received £345,000 to improve the appearance and add to the
overall improvement works at the waterfront.  Funded by Crown Estates Scotland
and the Scottish Government’s Placed Based Investment Programme, work started
July for an eight week period. 
Planned Capital Programmes
In September the Council’s Environment, Development and Infrastructure
Committee agreed a £500,000 capital programme to improve the quantity and
quality of footpaths across Argyll and Bute.  Responsible for approximately one
million square metres of footpaths, the programme will focus on improving access
for all abilities by dropping kerbs at crossing points. 
At the September Council meeting the Council agreed the Strategic Housing
Investment Plan (SHIP) which sets out plans for 750 housing units in the coming
years including 247 homes this year.
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In August the Council’s Policy and Resources Committee approved the programme
submission to the UK Government with regards to the UK Shared Prosperity Fund.
This fund is the successor to the EU Structural Fund.  
Argyll and Bute’s allocation is £4.5m. All local authorities are required to submit a
plan indicating how the funds will be invested and sets out for each priority
interventions, outputs and outcomes.  
Argyll and Bute’s plan is aligned to the three priorities – 
a) Communities and place 
b) Supporting local business 
c) People and skills
4.13 Environment
Argyll and Bute Council has reduced its carbon emissions for the fourth year in a
row and by a third since 2015/16. This is as a result of a range of measures including
making buildings more energy and heat efficient, the street lighting LED scheme,
electric and hybrid vehicles and recycling municipal waste.   
As part of Argyll and Bute’s Community Planning Partnership the Council has
allocated £50,000 to part-fund a new post. The new Climate Action Project Manager
will have responsibility for formulating a new Climate Action Plan with a strong focus
on community involvement.   
The Council received over £2m from the Scottish Government’s Energy Efficient
Programme. This funding is for means tested grants of between £8,000 and £21,100
per household.  
In July the Council appointed a principal contractor to deliver the Campbeltown Flood
Protection Scheme. This is part of a £15m scheme to reduce the risk of flooding in
the town including new pipelines to separate surface and sewer drainage, a new
‘storage dam’ facility, a large culvert and underground storage areas.  Some homes
and businesses will benefit from mitigations including the removal of flood protection
barriers on doors, automatically closing airbricks and small pump systems.  
4.14 Housing
The Council agreed to an additional £90,000 of funding (on top of £72,000 previously
awarded) for six affordable houses on the Isle of Ulva. These will be delivered by the
North West Mull Community Woodland Company who purchased the island via the
Community Right-to-Buy initiative in 2018.  
In response to the growing challenge with regards to the provision of housing, a
housing group led by Executive Director, Kirsty Flanagan has been established.
Together with Heads of Service and Senior Officers the group will identify solutions
and actions to address housing market issues across all sectors, not just the Council.
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11 
It will also consider how to remove any barriers to developing additional housing
across the area. 
4.15 Cost Of Living 
In September the Council agreed to lobby Government and create a Short Life
Working Group to alleviate the particular impacts of the cost of living/fuel cost crisis
faced by our communities.   
Argyll and Bute has -
 The highest number of inhabited islands of all Scottish Local Authorities
 Highest percentage of people living in Remote Rural Areas of all mainland
Councils.
 Third lowest median pay rate (gross) of all Scottish Local Authorities.
 Ranked most vulnerable to post Covid economic shock.
 Additional costs of living in our communities range from 13% to 185% above
costs in urban UK areas.
 Nearly 70% of all households are at risk of fuel poverty or of extreme fuel
poverty.
The Council calls on Governments to -
 Urgently provide information on funding for people who do not get their
energy through typical means, 50% of our households are non-gas compared
to 14% of all Scottish properties.
 Apply price caps to oil, LPG and solid fuel to ensure all households are given
the support they need to heat their homes.
 Remove the variable standing charge rate that compounds the already higher
costs for households in remote and rural areas.  This must be changed to a
uniform charge.
 Deliver equity in support for the cost of living and fuel cost crisis by making
sure that the support measures are pivoted to take account of the additional
costs incurred with remote, rural and island living. 
The following is a link to the report that went to Council on 29 September 2022 Link
to Council document - Cost of living_argyll-bute.gov.uk) with further details on this
item. 
4.16 Care
The Council agreed to take the extraordinary step to take the legal responsibility for
the Kintyre Care Centre, a 40 bedroom private sector care home in Campbeltown.
The Kintyre Care Centre provides the only nursing care provision in Campbeltown
and the west of Argyll.  The care centre was due to be closed by the owner HC-One
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for commercial reasons. The Integrated Joint Board of the HSCP considered that it
was critically important to try to prevent the closure of the remaining care centre in
the area and agreement was reached. The HSCP cannot legally own buildings as it
is a partnership between the Council and NHS Highland.
Other Activities
4.17 Performance Management Project 
Data Challenge 
Following on from previous updates the Council is continuing on the highly
ambitious initiative to establish a ‘data platform’. The ‘data platform’ will collect
data from various systems and over time will enable the data to be accessed
and explored in a dashboard format. 
A Data Advisory Group consisting of senior officers from across the organisation
(both Council and HSCP) has been set up and is accountable to the Executive
Leadership Team (ELT).   
We aim to harness our data to ensure an evidence led approach to performance
management, service design, policy development, strategies and other decisions
that impacts on outcomes for our communities and stakeholders. 
Option Appraisals have been developed and presented to ELT with the decision
to use current ‘on site’ technology as the best option. This will allow the
opportunity to scale-up accordingly as the ‘data platform’ matures. Alongside this
a number of Data Challenges have been identified. One such challenge is to
explore how we can identify, and therefore support, children that are entitled to
financial support. 
This internal initiative has and will maintain close links with the Scottish Local
Government Digital Office data initiative and links to an action within the
Council’s Best Value Improvement Action Plan. 
Change Programme - Service Design 
After completing Phase 1 of the Performance Excellence Project to review
performance at Corporate Level, ELT agreed that Services will undertake a
review of Performance as part of the Service Design activity. The project team
will provide guidance and support to Services and are currently considering
approaches to this significant activity. A proposal will be presented to the ELT in
due course. 
4.18 PIF Activity 
As of this financial year the delivery of our Corporate Outcomes will be
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monitored through a suite of 47 Indicators that have been identified. These are
known as Corporate Outcome Indicators (COIs). 
A Council-wide Business Plan will be developed during 2022/23 which will align
to our Corporate Plan, and the renewed Argyll and Bute Outcome Improvement
Plan (ABOIP). This will replace the previous Service Plans which were not
renewed for 2022/23. 
The 6-monthly ASC report will continue to present performance on cross-cutting
strategic themes such as Absence, Complaints and Risks. Additional information
relating to strategic activity will also be reported. 
This agreed process feeds into the Performance Management Project which
commenced in September 2020. 
5.0 CONCLUSION 
This report updates the Audit and Scrutiny Committee on how we are delivering our
outcomes; the key challenges and how we plan to manage them; other Strategic
activity along with implemented and planned changes to the PIF.   
6.0 IMPLICATIONS
6.1 Policy: None
6.2 Financial: None
6.3  Legal: None
6.4  HR: None
6.5  Fairer Scotland Duty: None
6.5.1   Equalities - protected characteristics: None
6.5.2   Socio-economic Duty: None
6.5.3  Islands: None
6.6 Climate Change: None
6.7 Risk: This report sets out key challenges to the organisation and actions in
response to these.
6.8 Customer Service: None                 
For further information contact: 
 Stuart Green, Corporate Support Manager
stuart.green@argyll-bute.gov.uk 
 Sonya Thomas, Performance and Improvement Officer 
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sonya.thomas@argyll-bute.gov.uk 
APPENDICES 
Appendix 1 - Suite of 47 Corporate Outcome Indicators 
Pippa Milne, Chief Executive – Argyll and Bute Council 
03 November 2022 
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Appendix 1 
Corporate
Outcome
Corporate Outcome Indicator  Reporting
Frequency 
CO1: People live
active healthier
independent lives 
Maximise distribution of Scottish Welfare Fund Quarterly
The percentage of clients satisfied that they are better able to deal with their financial problems Quarterly
Maximise distribution of Discretionary Housing Payment (DHP) fund Annually
Proportion of care services graded 'good' (4) or better in Care Inspectorate Inspections Annually
Total percentage of adults receiving any care or support who rated it as excellent or good Every 2 Years
Total combined percentage carers who feel supported to continue in their caring role Every 2 Years
CO2: People will live
in safer and stronger
communities
The percentage of groups who say their effectiveness has increased as a result of capacity building by the community development team Annually
The information provided to our community groups, individuals and partners is easy to understand Annually
The total value of compensation settlements for vehicle damage / driver injury as a result of road / bridge faults Annually
Percentage of adults residents stating their neighbourhood as a 'very good' place to live (CSS – survey owner) Annually 
CO3: Children and
young people have the
best possible start
Provide quality meals within cost margins to all pupils Quarterly
Increase the percentage of our care experienced young people that have the recommended additional tracking and monitoring plans in place Quarterly
Percentage of children living in poverty (After Housing Costs) Annually
Our percentage rate for attendance across all Argyll and Bute schools is comparable or better than the Scottish national average Annually
Support the increase in the uptake of available Grants, Allowance and Entitlements Annually
A counselling service is available in all secondary schools Annually
The percentage of children with no concerns across all domains at 27 to 30 month assessment  Annually
95% of schools that have a suitability rating of A or B  Annually 
CO4: Education,
skills and training
maximise
opportunities for all
Maintain the percentage of all young people leaving school achieving a positive destination into further education, training or employment Annually
Maintain the percentage of successful examination presentations in levels 4 and 5 for Literacy and Numeracy by our senior phase pupils Annually
Increase the uptake of wider achievement opportunities which complement traditional SQA awards and offer alternative ways to develop learning, life and work skills Annually
The percentage of Modern Apprentices that go on to a positive destination after completing the Argyll and Bute Council Modern Apprentice Programme Annually
The percentage of children that achieve their appropriate developmental milestones by Primary 1 Annually
The percentage pass rate for the National 5 qualification is comparable or better than the Scottish national average Annually
The percentage pass rate for the National Higher qualification is comparable or better than the Scottish national average Annually  
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Appendix 1 
CO5: Our economy
is diverse and
thriving
Percentage of procurement spend spent on local enterprises Quarterly
Increase the number of community benefits that are delivered through the contracts we award locally Quarterly
Number of business and industry planning applications submitted annually Annually
The percentage of homeless applicants who required temporary accommodation this period Quarterly
Number of new affordable homes completed per annum Annually
The total number of visitor trips to Argyll and Bute Bi-Annually
The total visitor spend in Argyll and Bute Bi-Annually
Gross Value Added (GVA) per capita Annually
Unemployment rate - Claimant Count as a %age of working age population Annually
Unemployment rate - Claimant Count as a %age of the population (16-24) Annually
The number of business gateway start-ups per 10,000 of population Annually
Geographical percentage coverage of 4/5G mobile phone connectivity  Annually 
CO6: We have
an infrastructure
that supports
sustainable
growth
The percentage of waste that is recycled, composted or recovered Quarterly
The number of tonnes of waste sent to landfill Quarterly
Percentage of street cleanliness Quarterly
The percentage of roads in need of maintenance as defined by the annual survey Annually
CO2 emissions per capita (per head of total population)  Annually
G Getting it right
Increase the percentage of all Self-Service and automated contacts Quarterly
Sickness absence days per employee (non-teacher) Quarterly
Sickness absence days per Teacher Quarterly
Level of employee satisfaction Annually
Level of customer satisfaction Annually 
TOTAL NUMBER OF COIs 47 
TOTAL FOR COMM SERVICES
COMMITTEE
TOTAL FOR EDI COMMITTEE TOTAL FOR P&R COMMITTEE 
25 15 7 
ALL COIs ARE REPORTED TO THE ASC ANNUALLY 
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Audit & Scrutiny Committee Work Plan 2022 – 2023 
This is an outline plan to facilitate forward planning of reports to the Audit & Scrutiny Committee 
Report  Lead Service Regularity
20 December 2022 Reports to Committee Services by 25 November 2022
Internal Audit and Counter Fraud Summary of Activities Chief Internal Auditor Quarterly
Internal Audit Report Follow Up Chief Internal Auditor Quarterly
Internal Audit Reports to Audit and Scrutiny Committee 
 Early Years
 Heritage Assets 
Chief Internal Auditor Quarterly
External Audit Update Report Audit Scotland/Mazars Quarterly
Verbal Update by Chair(s) of Scrutiny Panel Chair and Vice Chair of Audit & Scrutiny
Committee  
Quarterly
Council 6-month Performance Report – April to September 2022 Chief Executive/Head of Customer Support
Services
Bi-Annual
16 March 2023 Reports to Committee Services by 20 February 2022
Internal Audit and Counter Fraud Summary of Activities Chief Internal Auditor Quarterly
Internal Audit Report Follow Up Chief Internal Auditor Quarterly
Internal Audit Reports to Audit and Scrutiny Committee 2023/24 Chief Internal Auditor Quarterly
Verbal Update by Chair(s) of Scrutiny Panel Chair and Vice Chair of Audit & Scrutiny
Committee  
Quarterly
RIPSA Annual Report Governance and Risk Manager Annual
Internal Audit 2023/24 Plan Chief Internal Auditor Annual
External Audit – 2022/23 Annual Plan Audit Scotland Annual
2021/22 Unaudited Annual Accounts Preparation Plan and Timetable Head of Financial Services Annual
Treasury Management Strategy and Annual Investment Strategy Head of Financial Services Annual
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Audit & Scrutiny Committee Work Plan 2022 – 2023 
Progress against Best Value Action Plan Update Chief Executive/Head of Customer Support
Services
Annual
Internal Audit Charter and Internal Audit Manual Chief Internal Auditor Annual
Scrutiny Manual and Framework Update Chief Internal Auditor Annual
15 June 2023 Reports to Committee Services by 22 May 2023
Internal Audit and Counter Fraud Summary of Activities Chief Internal Auditor Quarterly
Internal Audit Report Follow Up Chief Internal Auditor Quarterly
Internal Audit Reports to Audit and Scrutiny Committee 
 
Chief Internal Auditor Quarterly 
External Audit Update Report Audit Scotland Quarterly
Verbal Update by Chair(s) of Scrutiny Panel Chair and Vice Chair of Audit & Scrutiny
Committee  
Quarterly
Council Performance Report – October 2022 to March 2023  Head of Customer Support Services Bi-Annual
Audit Scotland Report – Financial Overview 2021/22 (Usually comes
in March – delayed in 2022)
Head of Financial Services Annual
Strategic Risk Register Update Chief Executive Annual
Internal Audit 2022/23 Annual Report  Chief Internal Auditor Annual
Review of Code of Corporate Governance Governance, Risk and Safety Manager Annual
External Audit 2022/23 Management Report Audit Scotland Annual
Local Government Benchmarking Framework Report Head of Customer Support Services Annual
Unaudited Financial Accounts Head of Financial Services Annual
Local Government in Scotland:  Challenges and Performance 2023 Audit Scotland Annual
XX September 2023 Reports to Committee Services by XX August 2023
Internal Audit and Counter Fraud Summary of Activities Chief Internal Auditor Quarterly
Internal Audit Report Follow Up Chief Internal Auditor Quarterly
Internal Audit Reports to Audit and Scrutiny Committee  Chief Internal Auditor Quarterly
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Audit & Scrutiny Committee Work Plan 2022 – 2023 
External Audit Update Report Audit Scotland Quarterly
Verbal Update by Chair(s) of Scrutiny Panel Chair and Vice Chair of Audit & Scrutiny
Committee  
Quarterly
PSIAS Self-Assessment  Chief Internal Auditor Annual
Local Government Benchmarking Framework Report Head of Customer Support Services Annual
Corporate Complaints Annual Report 2021/22  Governance, Risk and Safety Manager Annual
Freedom of Information Annual Report 2021/22  Governance, Risk and Safety Manager Annual
Audit & Scrutiny Committee 2021/22 Annual Report  Audit & Scrutiny Committee Chair Annual
Strategic Risk Register – Assurance Mapping Chief Internal Auditor Annual
Strategic Risk Register Update  Chief Executive Annual
Trust Fund Annual Accounts  External Audit Annual
Local Government in Scotland Overview 2022 Audit Scotland Annual
Counter Fraud Annual Update (End of 2 year pilot) Chief Internal Auditor Annual  Page 181

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