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4. 2023-09-05 HSCP Internal Control Review

North Ayrshire Council · 5 September 2023
Back to Audit and Scrutiny Committee — 5 September 2023 and its agenda

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NORTH AYRSHIRE COUNCIL
5 September 2023                                                                                                                                                            
Audit and Scrutiny Committee
Title: North Ayrshire HSCP – Internal Control Review
Purpose: To highlight to the Committee the recent work which has
been undertaken to strengthen the internal control
environment of the Health and Social Care Partnership. 
Recommendation:  It is recommended that Committee notes the work which has
been undertaken.
1. Executive Summary
1.1 The internal control environment across the Health and Social Care Partnership
is a complex one due to the size and diversity of teams, operating locations,
systems and interactions with service users.
1.2 Recent improvement work has been led by the Head of Service (Finance and
Transformation) to review and tighten controls across a number of areas.
1.3 This report provides the Audit and Scrutiny with an overview of the work which
has been carried out and some of the improvements that have been
implemented.
2. Background
Framework of Financial Regulations
2.1 North Ayrshire Integration Joint Board (IJB) has its own set of Financial
Regulations; these relate specifically to the affairs of the IJB itself and therefore
are more limited and focussed in scope. All operational and transactional finance
matters for delivery of North Ayrshire Health and Social Care Partnership
(NAHSCP) services must comply with North Ayrshire Council Financial
Regulations and NHS Ayrshire & Arran Standing Financial Instructions.
2.2 The Council’s Financial Regulations provide a mandatory framework for the
financial administration of North Ayrshire Council and apply to every financial
transaction and to every employee throughout the Council.
Agenda Item 4

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2.3 Under the Financial Regulations, Heads of Service are responsible for: 
• Ensuring that their staff are familiar with the regulations and that they are
adhered to.
• Providing any information required by the Head of Finance
• The financial performance of their Service
• Endeavouring to ensure that they and their staff secure Best Value
• The maintenance of effective internal controls within the financial procedures
operated by their Service. 
North Ayrshire HSCP 
2.5 The Partnership has a workforce of around 3,600 staff – roughly half are
employed by the Council and half by NHS Ayrshire & Arran – and has an agreed
revenue budget for 2023/24 of £288.072m (excluding large hospital set aside),
of which £121.408m is provided by North Ayrshire Council. 
2.6 Services are delivered across all of our localities by staff teams under five Heads
of Service – Children and Families, Mental Health, Health and Community Care,
Chief Social Work Officer, Finance and Transformation – and the Business
Support team sit out with these services and work with frontline staff across the
Partnership. There are integrated management structures with some staff
working across the two organisations’ systems and processes.  This results in
our internal control environment being a complex one. 
2.7 It should also be remembered that our staff engage with thousands of service
users on a daily basis, and, across a number of establishments, staff require
access to cash and the ability to make purchases on behalf of service users, who
are not subject to the same obligations or contractual requirements as
employees. 
Effectiveness of Internal Control environment 
2.8 Our Annual Governance Statement 2022-23 notes that “North Ayrshire IJB has
responsibility for conducting, at least annually, a review of the effectiveness of its
governance framework including the system of internal control. The review of the
effectiveness of the framework is informed by the work of the Partnership Senior
Management Team who have responsibility for development and maintenance
of the governance environment (i.e., the Heads of Service), the annual report by
the Chief Internal Auditor and reports from Audit Scotland and other review
agencies.” 
2.9 The recent annual report 2022-23 by the Chief Internal Auditor to this Committee
noted the following outcomes from Internal Audit work carried out in the
Partnership:

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Type Audit Opinion Reported to
A&S
Investigation Visit to a Care
Establishment
Limited/Reasonable 15/11/2022
Assurance Social Care Establishments Reasonable 28/03/2023
Assurance CM2000 system Substantial 27/09/2022
Assurance Care Home admissions
process
Substantial 15/11/2022 
2.10 There have also been three recent fraud reports which have identified issues with
the control environment in the specific cases highlighted. Members will recall that
these reports related to the deliberate actions of individuals, however internal
controls have been tightened to avoid the opportunity for similar issues arising in
the future. 
2.11 In her annual report to the IJB Performance and Audit Committee, the Chief
Internal Auditor noted “Based on the audit work carried out in the IJB and relevant
work carried out in the parent bodies, my opinion is that reasonable assurance
can continue to be placed on the adequacy and effectiveness of the IJB’s
systems of governance, risk and internal control.” 
2.12 As part of the IJB’s own review of the effectiveness of the control environment,
partly informed by the Internal Audit findings, the Head of Finance and
Transformation has led a group of senior officers to identify and implement a
number of improvement actions focussing across the following areas: 
• Procurement Cards
• Children’s Houses
• Kinship Carers
• Staff Financial Training 
Procurement Cards 
2.13 A full review of all procurement cards held by officers within the Partnership has
been undertaken. The Partnership Senior Management Team (PSMT) recently
agreed the following criteria for staff to hold a card: 
• Establishments or offices where there is a requirement to purchase items to
support service users.
• Establishments or offices where there is a requirement to hold cash.
• Financial Intervention Officers who manage service users’ finances. 
2.14 Prior to the review, there were 99 cards held by Partnership staff and as a result
of the tightening of criteria and a review of services with multiple card holders,19
of these were removed from staff and the accounts closed. 
2.15 Corporate guidelines for the approval of new procurement card requests require
that they be approved by a line manager at Grade 14 or above. However, within
the Partnership this has been strengthened so that any new requests must be

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routed via the Head of Finance and Transformation, or in his absence the
Principal Manager (Business Support). These will only be approved if they meet
the criteria above and following review in conjunction with the appropriate Head
of Service. A similar process will also be followed for any requests to increase
spend limits. 
2.16 Concerns have also been highlighted previously around the volume of card
transactions which had not been reviewed and/or approved within the prescribed
timescales. Significant work has been undertaken with cardholders, their
approvers and involving Heads of Service where necessary and this has resulted
in a 91% reduction in the number of outstanding transactions (August 2023).
Regular reports are received from Corporate Procurement and monitored by
Business Support to ensure this issue does not reoccur. 
Children’s Houses 
2.17 Visits have been undertaken by Finance and Business Support staff to each of
the Children’s Houses to review the procedures and processes around the
recording, handling and storage of cash and these have been revised where
necessary. Each house now has the support of an Admin Worker each week to
assist with these tasks. 
2.18 House managers have been reminded of the need to minimise the use of cash
where possible, while being mindful of the setting and the need to use cash for
some outlays. Work is ongoing to establish bank accounts for children where
possible, to support the ability to provide young people with pocket money by
bank transfer. 
2.19 A programme of cash handling training has been delivered by colleagues from
the Corporate Fraud Team to staff in the children’s houses, helping ensure that
they are fully aware of their responsibilities. 
2.20 Eight of the procurement cards which were withdrawn were held by staff in the
children’s houses and there are now 2 held in each house – by the assistant
manager and a senior residential worker – with the house manager now acting
as approver for these transactions against their budget. 
2.21 The Senior Accountant for Children and Families has introduced regular budget
monitoring meetings with the House Managers to help ensure tighter controls
around expenditure. 
Financial Training 
2.22 A range of financial training courses is available for staff who require them as
part of their job role. There is a mix of face-to-face and e-learning and these
courses include Cash Handling, Financial Regulations, Budget Holder training,
Procurement Card (cardholder and approver) and Integra (requisitioner and
approver). 
2.23 It is essential that staff who require to complete this training to undertake their

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job do so and a range of reports is under development to enable better monitoring
of who has completed the training and where there are any gaps. 
2.24 The Head of Service (Finance and Transformation) will monitor this information
and ensure that staff are reminded of the requirements, with escalation to Heads
of Service where necessary. 
Kinship Carers 
2.25 Following the identification of two instances of over-payment to Kinship Carers,
a review of the controls around payments to Kinship Carers has taken place and
these have been tightened to ensure that Finance staff are always notified when
a placement begins or ends. 
2.26 Actions have included: 
• A formal annual review of kinship care placements.
• Ensuring that a kinship carer agreement form is completed, signed and
retained on file for each placement.
• Additional checks within the Finance team between fostering and kinship care
placements to help ensure there are no duplicate payments. 
These additional checks will ensure that if any overpayment occurs that it is
identified as quickly as possible to ensure funds can be recovered and also to
minimise impact on the Carer. 
Conclusions 
2.27 This report has outlined some of the recent improvement work which has been
undertaken. It is not intended to provide a guarantee that there will be no fraud
or error across the Partnership in future. In a workforce which operates across
numerous physical locations, with thousands of interactions with service users
each day, and with millions of payroll entries, accounts payable and income
transactions each year, it is almost inevitable that occasional human errors or
deliberate actions will happen. However, it is essential to ensure that the internal
control framework is as robust as possible to minimise the risk and recent work
has helped to support this. 
3. Proposals 
3.1 It is recommended that Committee notes the work which has been undertaken. 
4. Implications/Socio-economic Duty 
Financial 
4.1 The report describes improvement work which has been undertaken across the
financial control environment of the Health and Social Care Partnership.

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Human Resources 
4.2 None. 
Legal 
4.3 None. 
Equality/Socio-economic 
4.4 None. 
Climate Change and Carbon 
4.5 None. 
Key Priorities 
4.6 None. 
Community Wealth Building 
4.7 None. 
5. Consultation 
5.1 Consultation has taken place with staff across the Partnership and with
colleagues from Internal Audit and the Corporate Fraud Team during the review
which has been carried out. 
Caroline Cameron
Director, Health and Social Care Partnership 
For further information please contact Paul Doak, Head of Finance and
Transformation, NAHSCP, on pdoak@north-ayrshire.gov.uk. 
Background Papers
None.