public financial management systems dr salman shah lahore

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PUBLIC FINANCIAL PUBLIC FINANCIAL MANAGEMENT SYSTEMS MANAGEMENT SYSTEMS Dr Salman Shah Dr Salman Shah Lahore Lahore

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Page 1: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PUBLIC FINANCIAL PUBLIC FINANCIAL MANAGEMENT SYSTEMSMANAGEMENT SYSTEMS

Dr Salman ShahDr Salman ShahLahoreLahore

Page 2: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

Role of public sectorRole of public sectorGovernment is the largest organized activity Government is the largest organized activity in Pakistanin PakistanRecent budgets of the provincial and federal Recent budgets of the provincial and federal governments amounted to around $ 45 governments amounted to around $ 45 billionbillionEvery penny is resourced and disbursed Every penny is resourced and disbursed through the civil bureaucracythrough the civil bureaucracyThe budgetary process involves ministries, The budgetary process involves ministries, attached departments approved by attached departments approved by parliamentparliamentAuditor general reports to parliamentAuditor general reports to parliament

Page 3: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

Tiers of GovernmentTiers of Government

Federal Government

Provincial Government

Local Government

Service Providers

Ministries

Departments

ServiceProviders Service

Providers

Page 4: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

Resource DistributionResource Distribution

Federal Government $ 30 BillionDebt servicing 13 BillionDefense 6 Billion

Subsidies/inefficiency 6 BillionOther 5 Billion (PSDP)

Provincial Governments $ 15 Billionof which Local Government ?

Page 5: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

Effective AccountabilityEffective Accountability

Public sector organizations credibility with Public sector organizations credibility with the public depends on effective system of:the public depends on effective system of:

Reporting their performanceReporting their performance

Explain their actionsExplain their actions

Provide transparency to their processesProvide transparency to their processes

Clear lines of responsibilitiesClear lines of responsibilities

Well understood objectivesWell understood objectives

Robust systems of measuring performanceRobust systems of measuring performance

System of responsibility and accountabilitySystem of responsibility and accountability

Page 6: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

Role of audit in accountabilityRole of audit in accountability

Financial Audit traces spending in line with Financial Audit traces spending in line with budgetbudget

Economy audit deals with cost of input vs Economy audit deals with cost of input vs plannedplanned

Efficiency audit: lowest cost process followedEfficiency audit: lowest cost process followed

Effectiveness audit: results/output as plannedEffectiveness audit: results/output as planned

Sustainability audit: programs continuity over Sustainability audit: programs continuity over time time

Page 7: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

Public Policy implementation and Public Policy implementation and ReportingReporting

Policy Direction

ResourcingPolicy ObjectivesBudgets

Delivering the public good

Accounting Evaluating and reporting

Page 8: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

Comprehensive Approach To Comprehensive Approach To Public Financial Management Public Financial Management

(PFM) Reforms(PFM) Reforms

The PFM Performance Measurement Framework is one of the elements of a strengthened approach to supporting PFM reforms.

It is designed to measure PFM performance of countries across a wide range of development over time. The Performance Measurement Framework includes a set of high level indicators,

Page 9: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

Public Expenditures and Financial Public Expenditures and Financial Accountability (PEFA)Accountability (PEFA)

The PFM Performance Measurement Framework is an integrated monitoring framework that allows measurement of country PFM performance over time.

It has been developed by the PEFA partners, in collaboration with the World Bank/ OECD/DAC Joint Venture on PFM as a tool that would provide reliable information on the performance of PFM systems, processes and institutions over time.

Page 10: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

The set of high level performance indicators The selected 28 indicators for the country’s PFM system are structured into three categories:

A. PFM system out-turns: these capture the immediate results of the PFM system in terms of actual expenditures and revenues by comparing them to the original approved budget, as well as level of and changes in expenditure arrears.

B. Cross-cutting features of the PFM system: these capture the comprehensiveness and transparency of the PFM system across the whole of the budget cycle.

C. Budget cycle: these capture the performance of the key systems, processes and institutions within the budget cycle of the central government.

Page 11: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

Comprehensive Fiscal oversight:

Are the aggregate fiscal position and risks are

monitored and managed?

Comprehensive Fiscal oversight:

Are the aggregate fiscal position and risks are

monitored and managed?

Information:Is adequate fiscal, revenue and expenditure

information produced and disseminated to meet decision-making and management purposes?

Information:Is adequate fiscal, revenue and expenditure

information produced and disseminated to meet decision-making and management purposes?

Comprehensive, Policy-based, budget:

Does the budget capture all relevant

fiscal transactions, and is the process, giving regard to government

policy?

Comprehensive, Policy-based, budget:

Does the budget capture all relevant

fiscal transactions, and is the process, giving regard to government

policy?

Budget Realism:Is the budget realistic, and

implemented as intended in a

predictable manner?

Budget Realism:Is the budget realistic, and

implemented as intended in a

predictable manner?

Control :Is effective control and stewardship exercised

in the use of public funds?

Control :Is effective control and stewardship exercised

in the use of public funds?

The questions the PFM performance indicators seek to answer

Accountability and Transparency :

Are effective external financial accountability

and transparency arrangements in place?

Accountability and Transparency :

Are effective external financial accountability

and transparency arrangements in place?

MEASURING WHAT PERFORMANCE ?

Six PFM System Aspects

Page 12: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

CredibilityCredibility

Structure of the indicator set

A. PFM Out-turns

Comprehensiveness

Transparency

B. Key cross-cutting featuresExternal

Scrutiny and Audit

Accounting and

Reporting

Budget Execution

Policy-based

budgeting

C. Budget Cycle

STRUCTURE AND CONTENT OF THE INDICATORSSTRUCTURE AND CONTENT OF THE INDICATORS

Page 13: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

A. PFM OUT-TURNS

PI-1 Aggregate expenditure out-turn compared to original approved budget

PI-2 Composition of expenditure out-turn compared to original approved budget

PI-3 Aggregate revenue out-turn compared to original approved budget

PI-4 Stock and monitoring of expenditure payment arrears

THE CURRENT STANDARD SET OF HIGH-LEVEL INDICATORSTHE CURRENT STANDARD SET OF HIGH-LEVEL INDICATORS

PEFA JUNE 2012

Page 14: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-1 Aggregate expenditure out-turn compared PI-1 Aggregate expenditure out-turn compared to original approved budgetto original approved budget

Deviation of actual expenditure from original Deviation of actual expenditure from original budget was greater than 10% in only one of the budget was greater than 10% in only one of the last three years. last three years.

Grade BGrade B

Variance in expenditure composition exceeded Variance in expenditure composition exceeded 15 % in one of the last three years. 15 % in one of the last three years.

Grade CGrade C

PI-2 Composition of expenditure out-turn compared to original approved budget

Page 15: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-3 Aggregate revenue out-turn compared to PI-3 Aggregate revenue out-turn compared to original approved budget original approved budget

Actual revenue collection is within 94%-112% of Actual revenue collection is within 94%-112% of budgeted revenue during two of the last three years. budgeted revenue during two of the last three years. Grade BGrade B

There is no reliable data on the stock of arrears from the There is no reliable data on the stock of arrears from the last two years. Commitment accounting has been last two years. Commitment accounting has been introduced but is still in nascent stages. introduced but is still in nascent stages. Grade DGrade D

PI-4 Stock and monitoring of expenditure payment arrears

Page 16: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

B. KEY CROSS-CUTTING FEATURES : COMPREHENSIVENESS AND TRANSPARENCY

PI-5 Classification of the budget

PI-6 Comprehensiveness of information included in budget documentation

PI-7 Extent of unreported government operations

PI-8 Transparency of inter-governmental fiscal relations

PI-9 Oversight of aggregate fiscal risk from other public sector entities

PI-10 Public access to key fiscal information

THE CURRENT STANDARD SET OF HIGH-LEVEL INDICATORSTHE CURRENT STANDARD SET OF HIGH-LEVEL INDICATORS

Page 17: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-5 Classification of the budgetPI-5 Classification of the budget

The budget formulation and execution is based The budget formulation and execution is based on administrative, economic and sub-functional on administrative, economic and sub-functional classification, using GFS/COFOG standards with classification, using GFS/COFOG standards with some gaps, but consistent documentation in some gaps, but consistent documentation in accordance with GFS standards is produced. accordance with GFS standards is produced.

Grade AGrade A

United Nations Classification of Functions of United Nations Classification of Functions of Government (COFOG) Government (COFOG)

Page 18: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-6 Comprehensiveness of information PI-6 Comprehensiveness of information included in budget documentationincluded in budget documentation

The budget information includes 8 of 9 required The budget information includes 8 of 9 required elements. elements. Grade A Grade A

Fiscal reports as generated by AGPR on income Fiscal reports as generated by AGPR on income and expenditure lack inclusion of all information, and expenditure lack inclusion of all information, even for loan financed projects. even for loan financed projects. Grade D+Grade D+

PI-7 Extent of unreported government operations

Page 19: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-8 Transparency of inter-governmental PI-8 Transparency of inter-governmental fiscal relations fiscal relations

Transfers from federal government to Transfers from federal government to provincial government are transparent and provincial government are transparent and governed by rules settled under the governed by rules settled under the Constitution. Constitution.

Grade AGrade A

Page 20: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-9 Oversight of aggregate fiscal risk from PI-9 Oversight of aggregate fiscal risk from other public sector entitiesother public sector entities

A systematic procedure for monitoring A systematic procedure for monitoring consolidated overview of the fiscal risk consolidated overview of the fiscal risk caused by PSE/AGA is lacking. caused by PSE/AGA is lacking.

There is no practice of consolidating fiscal There is no practice of consolidating fiscal risk arising out of all AGAs and PEs. risk arising out of all AGAs and PEs.

Grade CGrade C

Page 21: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-10 Public access to key fiscal PI-10 Public access to key fiscal information information

Public access criteria are presently met in Public access criteria are presently met in 3 of the 6 essential areas 3 of the 6 essential areas No. Reports on budget execution are No. Reports on budget execution are prepared by the AGPR prepared by the AGPR PPRA requires award of all contracts PPRA requires award of all contracts above Pak Rs. 50 million to be published above Pak Rs. 50 million to be published on its website. There is no evidence of full on its website. There is no evidence of full compliance by MDAs compliance by MDAs Grade BGrade B

Page 22: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

C. BUDGET CYCLE

i. Policy-Based Budgeting

PI-11 Orderliness and participation in the annual budget process

PI-12 Multi-year perspective in fiscal planning, expenditure policy and

budgeting

THE CURRENT STANDARD SET OF HIGH-LEVEL INDICATORSTHE CURRENT STANDARD SET OF HIGH-LEVEL INDICATORS

Page 23: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-11 Orderliness and participation PI-11 Orderliness and participation in the annual budget process in the annual budget process

A clear annual budget calendar exists, is A clear annual budget calendar exists, is adhered to and allows MDAs enough time adhered to and allows MDAs enough time to complete their detailed estimates on to complete their detailed estimates on time. time.

Grade AGrade A

MDAs: Ministries, departments and agencies

Page 24: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-12 Multi-year perspective in fiscal planning, PI-12 Multi-year perspective in fiscal planning, expenditure policy and budgetingexpenditure policy and budgeting

Links between multi-year estimates as per Links between multi-year estimates as per MTBF and subsequent annual budgetary MTBF and subsequent annual budgetary ceilings are not strong ceilings are not strong

Grade B+Grade B+

Page 25: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

C. BUDGET CYCLE

ii. Predictability and Control in Budget Execution

PI-13 Transparency of taxpayer obligations and liabilities PI-14 Effectiveness of measures for taxpayer registration and tax assessmentPI-15 Effectiveness in collection of tax payments PI-16 Predictability in the availability of funds for commitment of expendituresPI-17 Recording and management of cash balances, debt and guaranteesPI-18 Effectiveness of payroll controlsPI-19 Competition, value for money and controls in procurementPI-20 Effectiveness of internal controls for non-salary expenditure and assets managementPI-21 Effectiveness of internal audit

THE CURRENT STANDARD SET OF HIGH-LEVEL INDICATORSTHE CURRENT STANDARD SET OF HIGH-LEVEL INDICATORS

Page 26: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-13 PI-13 Transparency of Taxpayer Obligations Transparency of Taxpayer Obligations and Liabilitiesand Liabilities

No substantial curtailment of discretionary No substantial curtailment of discretionary powers during last three years was made. powers during last three years was made.

tax appeals system needs improvement to tax appeals system needs improvement to work fairly, transparently and effectively work fairly, transparently and effectively

Grade BGrade B

Page 27: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-14 PI-14 Effectiveness of measures for taxpayer Effectiveness of measures for taxpayer registration and tax assessmentregistration and tax assessment

A data base of taxpayers is maintained for A data base of taxpayers is maintained for individual taxes. Linkages with other individual taxes. Linkages with other registration authorities are weak and registration authorities are weak and currently there are no provisions for currently there are no provisions for conducting surveys of potential taxpayers conducting surveys of potential taxpayers

Grade C+Grade C+

Page 28: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-15 PI-15 Effectiveness in collection of tax Effectiveness in collection of tax paymentspayments

total amount of tax arrears is significanttotal amount of tax arrears is significant

The current practices have different gaps The current practices have different gaps in recording, reporting and reconciliation of in recording, reporting and reconciliation of tax paid and tax self-assessed under tax paid and tax self-assessed under USAS USAS

Reconciling differences between AGPR, Reconciling differences between AGPR, FBR and SBP remain unresolved. FBR and SBP remain unresolved.

Grade D+ Grade D+

Page 29: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-16 Predictability in availability of funds for PI-16 Predictability in availability of funds for commitment of expenditurescommitment of expenditures

In-year adjustments, usually budget cuts, In-year adjustments, usually budget cuts, are made as per rules and regulations but are made as per rules and regulations but may not be predictable as these are may not be predictable as these are mostly driven by resource constraints. mostly driven by resource constraints.

Grade C+Grade C+

Page 30: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-17 Recording and management of cash balances, PI-17 Recording and management of cash balances, debt and guaranteesdebt and guarantees

debt are properly recorded, reconciled and debt are properly recorded, reconciled and reported by SBP, MoF and EAD respectively, reported by SBP, MoF and EAD respectively, however reconciliation differences exist between however reconciliation differences exist between AGPR and EAD for third party payments AGPR and EAD for third party payments

Government cash balances is consolidated and Government cash balances is consolidated and reported on daily basis by SBP. However, reported on daily basis by SBP. However, balances for exempt entities and revolving fund balances for exempt entities and revolving fund accounts are not included accounts are not included

Grade B+Grade B+

Page 31: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-18 Effectiveness of payroll controlsPI-18 Effectiveness of payroll controls

Payroll is backed by personnel filesPayroll is backed by personnel files

containing all information containing all information

Civil payroll is not subject to specific Civil payroll is not subject to specific payroll audit payroll audit

monthly list of employees to PAOs are monthly list of employees to PAOs are sufficient to identify ghost employees sufficient to identify ghost employees

Grade B+Grade B+

Page 32: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-19 PI-19 Transparency, competition and complaints Transparency, competition and complaints mechanisms in procurementmechanisms in procurement

Audit observations highlight use of other than Audit observations highlight use of other than competitive method of bidding without proper competitive method of bidding without proper justification. justification. Complete and reliable data is not available for 3 Complete and reliable data is not available for 3 out of 4 key information sets. out of 4 key information sets. PPRA complaint cell does not include members PPRA complaint cell does not include members from civil society and private sector. from civil society and private sector. framework meets four of the six listed framework meets four of the six listed requirements requirements Grade DGrade D

Page 33: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-20 Effectiveness of internal controls for non-PI-20 Effectiveness of internal controls for non-salary expendituresalary expenditure

Procedures to address risk of error and Procedures to address risk of error and fraud tend to create duplication of fraud tend to create duplication of approvals causing inefficient use of approvals causing inefficient use of personnel personnel

Audit Reports for past 3 years contain Audit Reports for past 3 years contain several observations on internal control several observations on internal control weaknesses. weaknesses.

Grade C+Grade C+

Page 34: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-21 Effectiveness of internal auditPI-21 Effectiveness of internal audit

Internal Audit is not yet developed effectively in Internal Audit is not yet developed effectively in most ministries.most ministries.There is no evidence suggesting that Internal There is no evidence suggesting that Internal Audit reports are issued regularly for most GoP Audit reports are issued regularly for most GoP entities. entities. As an operational internal audit function with As an operational internal audit function with regular reporting is not implemented, follow up regular reporting is not implemented, follow up management actions becomes non-existent As management actions becomes non-existent As an operational internal audit function with regular an operational internal audit function with regular reporting is not implemented, follow up reporting is not implemented, follow up management actions becomes non-existent management actions becomes non-existent Grade D Grade D

Page 35: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

C. BUDGET CYCLE

iii. Accounting, Recording and Reporting

PI-22 Timeliness and regularity of accounts reconciliation

PI-23 Availability of information on resources received by service delivery units

PI-24 Quality and timeliness of in-year budget reports

PI-25 Quality and timeliness of annual financial statements

THE CURRENT STANDARD SET OF HIGH-LEVEL INDICATORSTHE CURRENT STANDARD SET OF HIGH-LEVEL INDICATORS

C. BUDGET CYCLE

Iv. External accountability, audit and scrutiny

PI-26 Scope, nature and follow-up of external audit

PI-27 Legislative scrutiny of the annual budget law

PI-28 Legislative scrutiny of external audit reports

Page 36: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-22 Timeliness and regularity of accounts PI-22 Timeliness and regularity of accounts reconciliationreconciliation

Bank reconciliations are conducted Bank reconciliations are conducted monthly but unresolved reconciliation monthly but unresolved reconciliation differences remain differences remain Receipt side reconciliation practices of Receipt side reconciliation practices of treasury managed bank accounts are treasury managed bank accounts are deficient deficient Data of FBR, AGPR and SBP continue to Data of FBR, AGPR and SBP continue to differ for many reasons, differ for many reasons, Grade D+Grade D+

Page 37: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI- 23: PI- 23: Availability of information on resources Availability of information on resources received by service delivery unitsreceived by service delivery units

Generally provincial nowGenerally provincial now

Availability lowAvailability low

Page 38: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-24 Quality and timeliness of in-year budget reports PI-24 Quality and timeliness of in-year budget reports

Non-recording of expenditure at Non-recording of expenditure at commitment level by MDA remained major commitment level by MDA remained major deficiency to improve score. deficiency to improve score.

Government Fiscal Reports are generated Government Fiscal Reports are generated from GFMIS every month from GFMIS every month

Grade C+Grade C+

Page 39: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-25 Quality and timeliness of annual financial PI-25 Quality and timeliness of annual financial statementsstatements

Financial statements lack consolidation of Financial statements lack consolidation of independent departments independent departments

Financial Statements are being prepared Financial Statements are being prepared under cash basis of accounting and are under cash basis of accounting and are aligned with the format given by the cash aligned with the format given by the cash basis IPSAS basis IPSAS

Grade C+Grade C+

Page 40: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-26 Scope, nature and follow-up PI-26 Scope, nature and follow-up of external audit of external audit

INTOSAI auditing standards are adopted INTOSAI auditing standards are adopted but some aspects are only partially but some aspects are only partially implementedimplemented

submitted audit reports to the President, submitted audit reports to the President, within 8 months from the end of the fiscal within 8 months from the end of the fiscal yearyear

Grade BGrade B

Page 41: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-27 Legislative scrutiny of the PI-27 Legislative scrutiny of the annual budget law annual budget law

Time for the legislature for approving the budget, Time for the legislature for approving the budget, is too short to revise the detailed proposal and is too short to revise the detailed proposal and let the Executive re-submit the proposal. let the Executive re-submit the proposal.

The time for National Assembly review of the The time for National Assembly review of the budget law is less than a month budget law is less than a month

The legislature’s review is limited to bringing in The legislature’s review is limited to bringing in cut motion for voted expenditures only cut motion for voted expenditures only

Grade D+Grade D+

Page 42: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

PI-28 Legislative scrutiny of PI-28 Legislative scrutiny of external audit reports external audit reports

back-log of more than 10 years back-log of more than 10 years

The PAC includes concrete The PAC includes concrete recommendations in its reports recommendations in its reports

Substantial amount of recoveries have Substantial amount of recoveries have been made on recommendation of PAC been made on recommendation of PAC

Page 43: PUBLIC FINANCIAL MANAGEMENT SYSTEMS Dr Salman Shah Lahore

conclusionsconclusions

Our PFM has enormous shortcomingsOur PFM has enormous shortcomings

The performance indicators also indicate The performance indicators also indicate that accountability and performance that accountability and performance measures for delivery are the main measures for delivery are the main weaknessesweaknesses

Efficiency, economy, effectiveness and Efficiency, economy, effectiveness and sustainability measures are non existentsustainability measures are non existent

Service Providers are outside the systemService Providers are outside the system