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Internal Audit and Counter Fraud Summary of Activities

Argyll and Bute Council · 23 June 2022
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ARGYLL AND BUTE COUNCIL  AUDIT & SCRUTINY COMMITTEE   
FINANCIAL SERVICES  23 JUNE 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 one of 2022/23.  
1.2 Core activities together with a progress update statement are shown below: 
 2021/22 Audit Plan progress: Complete 
 Individual Audits undertaken: 7 audits have been completed during the
period. Two audits have been assessed as providing high assurance, three
substantial assurance, one reasonable assurance and one limited
assurance (HSCP Audit 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. Management have responded to previous
quarter notifications and there are no outstanding issues. The continuous
monitoring programme has been completed for 2021/22. 
 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 Seven audits have been completed since the previous Committee in March
2022. Three audits are currently in progress and will be reported to a future
meeting of the Committee. 
Audits Completed 
 Civil Contingencies
 Climate Change Act
 Complaints Handling – HSCP
 ELC Parental Satisfaction
 ICT - Remote Working

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 Planning Applications
 School Fund Governance   
Audit in Progress 
 Heritage Assets
 EMA
 Workforce Planning (HSCP)  
3.2 In addition to those already in progress indicative audits planned for Quarter 2
2022/23 are:  
3.3 2022/23 Audit Plan 
 Cyber Security
 Early Years
 LEADER   
Scrutiny  
3.4 Work has been completed on the 2021/22 scrutiny plan. The Community Asset
Transfer Process and Fly Tipping reviews have been completed and reports
have been issued and are presented to this Committee.     
Counter Fraud  
3.5 The paragraphs below summarise the work carried out by the Counter Fraud
Team (CFT) and provide an update on total billing for the pilot to the end of
April 2022. The pilot end date is September 2022.  The previous update
provided to the Audit and Scrutiny was only a small snippet of work carried out
from the start of 2022.  During this time a small value was rebilled as a
pending large review was still to be finalised, along with other proactive work.  
This full update is the basis for the proposal to make the CFT a permanent
fixture to continue to protect the public purse.    
3.6 In March there were two referrals alleging fraud by a council officer.  The
investigation concluded there was evidence of fraud.  This remains under
investigation and is currently with the Councils Monitoring officer.  
3.7 The CFT continue to perform visits to referral addresses when and where
possible.  CFT staff have made visits to Campbeltown, Garelochead,
Rosneath, Tarbert and Bute to date and been accompanied by other
department staff due to collaborative work.  The CFT plan for 2022 to revisit
Bute due to high volume of work identified.  Furthermore visits will be made to
Oban and Helensburgh.  
3.8 Investigations into potential Council Tax anomalies continue to be carried
out.  These mainly consist of potentially fraudulent claims for single person
discounts, fictitious tenants or claims of second home status for the avoidance
of 100% premium of Council Tax. A rolling programme of reviews is also
carried out on council tax discounts and exemptions to ensure they are only

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applied where appropriate. The CFT have also been working with debt
recovery officers to assist in any way possible to recover some accounts with
high levels of debt.  These are ongoing due to the large scale nature of the
investigations.  The below table summaries all fraud activity work to date (April
2022) and provides a summary of rebilling. 
Investigation
Area
No. of
Referrals
Summary
Council tax 64  10 fraudulent referrals resulting in
investigative work and rebilling
Benefits 17  Numerous referrals and details passed
to DWP and other agency partners
Blue Badge 4  No offences found to date by blue
badge team
Employee 10  3 Upheld
 2 Partially Upheld
 2 Not Upheld 
There has been additional referrals
where the same officers have been
reported twice or three times.
Others 9  A variety of referrals from Police
Intelligence, Licensing, Non Domestic
Rate requests
Proactive
Work 
Reviews of Single Person, Student, Second
home and Agriculture.  
Individual review and visits from referrals have
resulted in rebilling or disproving erroneous
referrals. 
Review of Covid grants resulting in £230,000
worth of central government money being
investigated with a large portion rebilled to
companies due to error and/or fraudulent
claims.  Argyll and Bute will rebill a % to
Scottish Government to put back into our
communities.  Grant reviews will remain
ongoing individually and in co-operation with
other Local Authorities and Police Scotland.
Total  Rebilled to Date £693,416 (ending April 2022)
Recovered to Date £590,364 (same period) 
Additional Updates from Quarter Four  
3.9 Internal Audit are in the process of completing the 2021/22 Audit Plan for the
Health and Social Care Partnership (HSCP). Our planned and approved work
for the HSCP for 2021/22 was not completed in full, specifically, work relating
to ‘Workforce Planning’.  A short review was undertaken to assess progress to
towards the completion of a workforce plan. This will be reported to the Audit

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and Risk Committee of the HSCP in June. The Complaints Handling audit is
presented to this Committee for information.  
3.10 The post of Chief Internal Audit has been filled with the new Chief Internal
Auditor taking up position at the beginning of July. 
Continuous Monitoring  
3.11 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.   The continuous monitoring
programme has been completed for 2021/22.  
3.12 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  
3.13 A follow up process for national reports is in place whereby management are
advised of national reports published and asked to confirm what, if any, action
is planned as a result of the report.  Table 2 details the national reports issued
during quarter four 2021/22.  
Table 2: National Reports

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National Report Issued
To
Detail Management
response/ Action
taken
The 2020/21
audit of the
Scottish
Environment
Protection
Agency
Executive
Director –
Kirsty
Flanagan
The full financial impact of a
cyber-attack on Scotland's
environmental agency is still
not clear, and the incident
remains a warning to other
public sector bodies.
SMT attended a
Cyber Security
Session provided by
the Digital Office
summarising the six
key findings that
apply to the wider
public sector.  ICT
have addressed the
issues identified and
continue to do so.  
Addressing
Climate Change
in Scotland
Executive
Director –
Douglas
Hendry
A summary of key
recommendations for public
bodies.
Much of the report
content is being
addressed by
component
departments already
as part of our De-
carbonisation Plan
and business as
usual.  The main
action to be
addressed relates to
Carbon Budgeting
and this will require
input from Financial
Services and
component Climate
Board Departments.
Local
Government in
Scotland
Financial
Overview
2020/21
Chief
Executive
/ Interim
Head of
Financial
Services
Scotland’s Councils have
increased reserves over the
last year but must address the
impacts of an overall reduction
in funding and ongoing
challenges caused by Covid-
19.
Actions identified in
the report have
already been
addressed, the full
report is submitted to
this committee under
separate cover.
Local
Government in
Scotland
Overview 2022
Chief
Executive
Scotland’s councils have had
a pivotal role in supporting and
working with communities as
they responded to the impacts
of Covid-19. Now councils
must lead recovery work with
and alongside their local
communities, focusing on
getting the services people
need in place as pressures
and stresses escalate and
impact the day to day lives of
individuals and communities.
No specific actions
identified.  The link
to the report has
been passed to all
elected members
with a
recommendation to
read as it provides a
useful national
context for the
issues faced in Argyll
and Bute.   
National Fraud Initiative (NFI)

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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 Matches are available for review and progress is monitored monthly by the
Counter Fraud Team and reported quarterly to the Audit and Scrutiny
Committee.   
Table 3: National Fraud Initiative Progress at 21/02/2022: 
Operational
Area
Total
Matches
Recommende
d / High Risk
Matches
Matches
Complete 
WIP Match Description
CT to Elect
Register 
1000 n/a   CT records to Electoral
Register/ other data sets to
ensure discount awarded to
only those living alone aged
over 18, taking into account
disregarded occupants. 
(CT to other Datasets will
not be progressed further
due to poor quality data)
CT rising 18s  194 n/a  
Housing
Benefits
29 14 26 0 HB records to records in
other authorities / other
datasets including student
loans, payroll and pensions
to identify undeclared
income and capital.
Payroll 57 9 1 1 Payroll records to other
datasets including other
payrolls and pensions to
ensure employee is not
receiving additional income
Blue Badges 255 220 255 0 Blue badge records to
DWP data to identify
deceased claimant with
valid badge.
Housing
Waiting list
264 263 264 0 Housing waiting list records
to other organisations
HBCTR and tenant data to
identify undisclosed
changes in circs or false
info.
Council Tax
Reduction
398 71 320 0 CTR records with records in
other authorities / other
datasets including; student
loans, payroll and pensions
to identify undeclared
income and capital

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Creditors 4839 0 150 0 Analyses Creditors data to
identify possible duplicate
vendors and payments,
VAT errors or fraud and
multiple vendors sharing a
bank account.
Procurement 176 0 38 0 Payroll matched to
Creditors and Companies
House data to identify
potential undeclared
interests that have given a
pecuniary advantage.
Business
Rates
120 0 105 0 Non-domestic Rates
Records within and
between authorities to
identify businesses
fraudulently in receipt of
multiple small business
bonus scheme grants. 
Overall Summary of Matches 
Matches
Complete
Work In
Progress
Cleared Frauds Errors Total
Value £
Recovering Recove
ring
Value £ 
1166 1 1046 1 119 673.66 1 673.66 
Internal Audit Development  
3.16 The table below details progress against the action points in our Internal Audit
development plan.  No additional items have been added in quarter four.
Table 4: Internal Audit Development Key Actions: 
Area For
Improvement
Agreed Action Progress
Update
Timescale
VC and conference
facility
Progress plan to use former audit room
at Whitegates as a video conference
facility. 
The new facility is well progressed but
paused due to the Council’s response
to the pandemic situation.
Delayed No current
timescale
due to
ongoing
office
closures 
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 on currently being on track. 
Internal Audit Team Scorecard 2021– 22 – FQ4 21/22 (as at March 2022)
BO115 We Are Efficient And Cost Effective    
Internal Audit Level of Satisfaction
Actual  96% G 
Target 80%
Review of Strategic Risk register Status Complete G

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Target Complete 
Percentage of audit plan completed
Status 100% G 
Target 100%
Percentage of audit recommendations accepted by
management
Actual  100%
G
Target 100% 
4 CONCLUSION  
4.1 The 2021/22 audit plan has been completed and the Counter Fraud Team is
continuing to develop and delivering a positive output for the Council.  
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 604146)
Moira Weatherstone
Interim Chief Internal Auditor
14 June 2022