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Report for: INFORMATION

Contains Confidential or Exempt Information

No

Title Annual Report including Head of Audit’s Opinion and Quarter 4 Audit & Investigation Performance Report

Member Reporting N/A

Contact Details Mike Pinder, Head of Audit & Investigations, ext. 2350

For Consideration By Audit Committee

Date to be Considered 21 June 2017

Implementation Date if Not Called In

21 June 2017

Affected Wards All

Keywords/Index Audit & Investigation Performance Report

1. Details of Recommendations

1.1 To note the report on the Head of Audit’s Opinion include Quarter 4 update. 1.2 To agree the Internal Audit Charter.

Summary The attached report includes the annual report and Head of Audit’s Opinion and describes the work undertaken by the Audit and Investigation Shared Service team to the end of Quarter Four. The report also includes the Internal Audit Charter, which is a document setting how Internal Audit work with the organisation, for approval by the Audit Committee.

If the recommendations are adopted, how will residents benefit?

Benefits to residents and reasons why they will benefit, link to Values

Dates by which they can expect to notice a difference

Internal Audit activity provides independent assurance to the Chief Executive, Members and Senior Officers on the adequacy of the internal control environment in Hounslow Council. This aids Members and Officers in ensuring that we are continually learning from experience. All counter fraud activity assists the Council in its value of spending money wisely. Every pound lost through fraudulent behaviours is a resource or asset diverted away from services provided to those who are in genuine need.

Ongoing

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2. Background

2.1 This report outlines the performance of the Audit & Investigations Shared Service from April 1 to the 31 March 2017.

2.2 Internal Audit and Investigations activity within the Council is delivered under a

shared service arrangement with the London Borough of Ealing.

2.3 The Public Sector Internal Audit Standards require that the Head of Internal Audit (for the Council it is the Head of Audit and Investigations) presents an annual report to an Authority’s Audit Committee. This is reflected in the terms of reference of the Committee. The report provides Members of the Audit Committee with:

The Head of Internal Audit Opinion for 2016/17;

An overview of the Council’s risk exposure and its overall system of internal control;

The work undertaken by Internal Audit in 2016/17;

Review of the outcomes of key internal audit reports; and

An overview of the performance of Internal Audit.

3. Reason for Decision and Options Considered

The Audit Committee is presented with details in the attached report.

4. Key Implications

4.1 The performance of the audit team (including the Strategic Audit Partner) is measured by:

%age of Internal Audit Plan completed (100% target);

%age of draft audit reports issued on time (95% target);

%age of final reports issued on time (95% target) ; and

%age of assignments completed within agreed budget (100% target).

4.2 The performance of the fraud team during the year is measured by:

The number of cases where fraud is established; and

The amount of money identified for recovery In addition to these performance indicators, the benefits of counter fraud work are reported within Appendix B.

5. Financial Details

a) Financial Impact on the Budget

In terms of the impact on the Internal Audit and Investigation service budget, there are no impacts on the basis that all services are delivered within existing budgets.

b) Comments of the Director of Finance and Corporate Services

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The Director of Finance and Corporate Services liaises closely with the Head of Internal Audit and Investigation on the progress of specific cases.

6. Legal (to be completed in conjunction with the Legal Department)

a) Legal Details

All Local Authorities are required to make a proper provision for Internal Audit in line with the 1972 Local Government Act and Accounts and Audit Regulations 2015 (as amended). The Public Sector Internal Audit Standards (2013) also require the proper planning of audit work. Local authorities are required to demonstrate proper stewardship of public funds in line with the 1972 Local Government Act. The London Borough of Hounslow utilises a fraud and investigation team to assist in its safeguarding of public funds and the recovery of funds that have been misappropriated.

c) Comments of the Head of Governance

The Director of Finance and Corporate Services, as the Council’s Chief Finance Officer, continues to have a personal statutory responsibility concerning the proper administration of the council’s financial affairs notwithstanding any appointment to perform the internal audit and investigation function.

7. Value for Money

Internal Audit seeks to provide value for money both in terms of the delivery of the service and through reviews of individual auditable areas. The investigation team provides good value for money to the Council and residents: the presence of the team helps prevent fraud by acting as a visible deterrent.

8. Sustainability Impact Appraisal

Not applicable.

9. Risk Management

Internal Audit activity is directly influenced by the Council’s risk management processes.

10. Links to Council Priorities

Efficient use of Council resources.

11. Equalities, Human Rights and Community Cohesion

No direct implications arising.

12. Staffing/Workforce and Accommodation implications

The recruitment exercise for the permanent Head of Audit was successful and Mike Pinder joined us on 20 March 2017.

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13. Property and Assets

None.

14. Any Other Implications

None.

15. Consultation

None.

16. Timetable for Implementation

Not applicable.

17. Appendices

Appendix A – Internal Audit Performance Report 1 April – 31 March 2017. Appendix B – Counter Fraud Performance Report 1 April – 31 March 2017.

18. Background Information

Counter Fraud Plan 2016/17 https://democraticservices.hounslow.gov.uk/documents/s122820/Counter%20Fraud%20Plan%202016-2017.pdf Internal Audit Plan 2016/17 https://democraticservices.hounslow.gov.uk/documents/s122853/Draft%20Internal%20Audit%20Plan%202016-2017.pdf

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Appendix B

APPENDIX A

LONDON BOROUGH OF HOUNSLOW INTERNAL AUDIT PERFORMANCE REPORT 1 April – 31 March 2017 June 2017

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1. Introduction 1.1 The purpose of the report is to provide Audit Committee members and

management with the Annual Report including Head of Audit’s Opinion and update on the delivery of the audit plan and highlight any issues that should be brought to the Committee’s attention.

2. Background 2.1 The fundamental role of Internal Audit is to provide senior management and

members with an independent assurance on the adequacy, effectiveness and efficiency of the system of internal control and report major weaknesses together with recommendations for improvement. The role is fulfilled by carrying out appropriate audit work in accordance with the Annual Plan as approved by the Director of Finance and Corporate Services and the Audit Committee. As Internal Audit is a major source of assurance that the Council is effectively managing its risks, a key rationale for the development of the Internal Audit Plan was the Council’s own Corporate and Service Risk registers.

3. Head of Audit’s Opinion

3.1 This report gives a summary of the work carried out by Internal Audit in the financial year 2016/17 and the results of that work as reported in progress reports to Committee throughout the year and as set out in section 5 covering the period 1 January to 31 March 2017. From the work undertaken during the year, my overall opinion on the Council’s system of internal control, governance and risk management is that:

3.2 Reasonable assurance can be given that there is a sound system of internal control, designed to meet the organisation’s objectives and that controls are applied consistently.

3.3 Controls relating to key financial systems were overall concluded to be at a reasonable assurance level. This is borne out by the Controls Assurance Monitoring work. The themes identified from this work were around reconciliations and audit trail. Management have also responded positively to issues raised and we will monitor progress through the managed audit work.

3.4 Internal Audit work on other systems has also concluded that there is an overall reasonable level of assurance. During the year only four reports were issued with limited reports being savings delivery, recruitment process, HB Law contractual arrangements, and fire safety and legionella. In addition one no assurance report was also issued in relation to contract management (Logicalis).

3.5 The basis for the opinion considers not only the assurance level of each report for the year, but the relative materiality of the system assessed during the year. In 2015/16 the overall opinion was substantial. The actual level of assurance remains consistent, but the definitions have changed following the change in internal audit providers and a difference in the assurance terminology for reports.

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3.6 Whilst direct comparison of the assurance levels is not quite as simplistic, a broad comparison is set out in the table below.

Assurance Level (2015/16)

Assurance Level (2016/17)

Definition

Full Substantial There is a sound system of internal control designed to achieve the client’s objectives. The control processes tested are being consistently applied.

Substantial Reasonable While there is a basically sound system of internal control, there are weaknesses, which put some of the client’s objectives at risk. There is evidence that the level of non-compliance with some of the control processes may put some of the client’s objectives at risk.

Limited Limited Weaknesses in the system of internal controls are such as to put the client’s objectives at risk. The level of non-compliance puts the client’s objectives at risk.

None None Control processes are generally weak leaving the processes / systems open to significant error or abuse. Significant non-compliance with basic control processes leaves the processes / systems open to error or abuse.

4. 2016/17 Audit Plan Progress 4.1 This report provides a progress update on the work of internal audit to the 31

March 2017. 4.2 The contract with the new Strategic Audit Partner, PwC, was signed in June of

this year, with audit work for 2016/17 starting shortly after this. 4.3 The 2016/17 Plan was approved by the Audit Committee in March 2016. The

plan presented was indicative and can be subject to revision during the year to take account of changing priorities and emerging risks, which is aligned with good internal audit practice.

4.4 The following table shows progress against the 2016/17 audit plan, illustrating the status (draft/final/in progress etc) of each review:

Table 1

Audit Title Scope Audit Status

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1 Lampton 360 Governance

Review of Lampton 360 governance arrangements including reporting, membership, directorships and funding.

Cancelled, due to the RSM review with similar scope. Audit work has also been included in the plan for 2017/18.

2 Fortnightly waste collection programme (Lampton 360)

Project assurance review that looks at planning for transition to fortnightly waste collection.

Deferred to 2017/18 due to delay in delivery of the programme.

3 Pension Fund Administration

Review of Pension Administration arrangements

Finalised (Substantial assurance)

4 Continuous auditing and monitoring Phase 1 (Key financial systems)

Audit of key controls for five major systems: Accounts Payable, Accounts Receivable, NNDR, Council tax, Payroll

Finalised (Reasonable Assurance)

5 Continuous auditing and monitoring Phase 2 (Key financial systems)

Finalised (Reasonable Assurance)

6 Savings delivery Review of the management controls and reporting procedures to effectively monitor the delivery of savings commitments.

Finalised (Limited assurance)

7 Schools themed audits – Payroll and safe recruitment

Review of payroll and safe recruitment arrangements in 5 schools maintained by the Council

Finalised (Reasonable assurance overall)

8 Schools themed audits – Procurement

Review of procurement arrangements in 5 schools maintained by the Council

Finalised (Reasonable assurance overall)

9 Schools themed audits – Financial governance

Review of financial governance arrangements in 5 schools maintained by the Council

Finalised (Reasonable assurance overall)

10 Complaints Handling Procedures

Assessment of control design for the corporate complaints handling procedure process

Finalised (Reasonable assurance)

11 Cash Imprest Accounts Review of cash locations, including appropriateness of expenditure and reconciliation

Finalised (Substantial assurance)

12 Recruitment Processes Review of recruitment procedures, including pre-employment checks and vetting

Finalised (Limited assurance)

13 Fire Safety and Legionella

Review of H&S assessments, governance, monitoring of remedial actions and training arrangements for fire safety and legionella for non-residential properties across the Council

Finalised (Limited assurance)

14 Corporate Governance Arrangements

Review of adequacy and effectiveness of the Corporate Governance arrangements.

Finalised (Audit opinion not applicable)

15 Procurement and Contract Management

General procurement compliance review, review to be extended to consider supplier resilience reviews.

Deferred to 2017/18 due to delay in preparation of the draft policies.

16 Logicalis contract management review

Review of contract management arrangements for Logicalis contract (ICT) with focus on value for money considerations.

Finalised (No assurance)

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17 Hounslow Civic Centre Project assurance review. Finalised (Reasonable assurance)

18 Right to Buy Review of controls and procedures regarding the implementation of the Right to Buy scheme.

Finalised (Reasonable assurance)

19 Pathway from Adult Social Care Assessment

Review of pathway arrangements from adult social care assessment, from referral to creation of the Support Plan

Finalised (Reasonable assurance)

20 IT risk diagnostic Use of IT Risk Diagnostic to identify risk areas in IT.

Draft report issued

21 IT governance and third party management

Review of the mechanisms that are currently in place to provide IT governance and management of third party providers who provide IT services on behalf of the Council.

Fieldwork in progress

22 Assurance mapping Development of assurance map for 2017/18.

Finalised (Audit opinion not applicable)

23 Looked after children Review of controls and safeguarding arrangements in looked after children

Finalised (Substantial assurance)

24 Anti-Social Behaviour Review of strategy against required performance as outlined in Pledge 1 of Council's promises

Draft report issued

25 Housing Benefits

The implications of risk based verification for HB

Draft report issued

26 Grants Verification Grant certification testing, e.g.. Troubled Families

Finalised - grant certification

27 Bribery Act Review of the implementation of the measures contained within the Bribery Act

Finalised (Substantial assurance)

28 HB Law Contractual Arrangements

Contract management arrangements including billing and performance management

Finalised (Limited Assurance)

29 Planning Services

Completion of system based review on planning services to include compliance with statutory requirements.

Finalised (Substantial Assurance)

30 Voids Management

Policies and procedures regarding the management of voids

Deferred to 2017/18

31 Governance Arrangements - Uplifts in residential and nursing care.

Review of governance arrangements including roles and responsibilities for uplifts in residential and nursing care in Children's and Adults

Field work in progress

32 Community Centres Governance review of arrangements within the centres

Deferred to 2017/18

4.5 Key performance indicators (KPIs) have been established to measure the

delivery of the audit service across the shared service. These are how we measure our performance to ensure that all audits on the plan for each Council are delivered by the end of the financial year. The shared service KPIs for delivery against the audit plan for each quarter are (based on draft reports issued):

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Quarter 1 – 15% of 16/17 audits delivered (draft report issued) Quarter 2 – 35% of 16/17 audits delivered (draft report issued) Quarter 3 – 65% of 16/17 audits delivered (draft report issued) Quarter 4 – 100% of 16/17 audits delivered (draft report issued) 4.6 The table below provides a summary of progress in terms of the number of

reports at draft or final stage and those in progress: Table 2

Audit Status Number of reviews

Percentage Completion

Finalised 22 82%

Draft 3 11%

In Progress 2 7%

Fieldwork scheduled 0 0%

Scoping in progress 0 0%

Total 27 100%

Deferred to 17/18 4

Cancelled 1

Total 32

4.7 The current percentage output of 93% of the plan delivered at draft or final stage

is slightly behind target, this is due in part to the delayed start to the audit plan. 4.8 Since the previous report three reports have been issued with a Limited

Assurance report and one with no Assurance:

1) Limited assurance: Savings delivery. This included one high level recommendation around the planning and recording phase.

2) Limited assurance: Recruitment Processes. This include two high level findings on:

a. They relate to control weaknesses in performance of follow-up checks for the existing employees,

b. A lack of clarity for roles and responsibilities for verification checks for school employees.

3) Limited assurance: HB Law. This included two high level findings in respect of contract monitoring and feedback processes.

4) No assurance: Contract Management (Logicalis). This included four high level findings, which were largely around two issues being:

a. The lack of documented contract management processes. b. The lack of a designated contracts officer for the Logicalis contract.

All recommendations have been accepted and action plans to resolve the issues have been agreed and put in place.

4.9 Follow-Up Work Internal Audit carries out a review of the progress in implementing

recommendations raised. High risk recommendations are followed up as they become due to allow the Committee to be made aware of progress against high risk priority recommendations on a regular basis. The status of high risk recommendations due to be implemented by 31 May are outlined below:

Table 3

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Number of High Risk Recommendations due to be implemented

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Number of High Risk recommendations fully implemented 24

Number of High Risk recommendations partially implemented

1

Partially implemented recommendations (those for which action has been undertaken, but which were not fully completed by the original action date) will continue to be monitored against revised implementation dates. Any instances of non-implementation will be reported to future meetings of the Audit Committee. Details of the partially implemented high risk recommendations and progress against it is provided in the table below: Details of partially implemented recommendation:

Audit Risk Area Status

Pathway to Adult Social Care

Assessment Process Management indicated implemented, but need to compiling evidence to support implementation. Revised date to June 17.

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Appendix B

LONDON BOROUGH OF HOUNSLOW COUNTER FRAUD TEAM PERFORMANCE REPORT Quarter 4 1 April – 31 March 2017 June 2017

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1. Introduction

1.1 This report details the performance of the Audit & Investigations Shared Service

in respect of the delivery of investigation services on behalf of the London Borough of Hounslow. The purpose of the report is to provide Audit Committee members and management with an update on the work undertaken by the Shared Service to Quarter 4 (1 April to 31 March 2017) and highlight key issues for the attention of Members.

1.2 The service achieved a total of 92 proven cases against a target of 68 for the year. Within this the team also identified in excess of £1m losses, representing in the region of £660k (notional) and £406k (actual) for the Council as a whole.

2. Background

2.1 As previously reported to the Committee, Internal Audit & Investigation services are delivered by the Internal Audit and Investigations Shared Service, which has brought together the Internal Audit and Investigation resources of the London Boroughs of Hounslow and Ealing.

2.2 The Shared Service, hosted by the London Borough of Ealing, enhances the Internal Audit and Investigation services delivered to the two boroughs, by bringing together a wealth of experience, improving overall service resilience, whilst also providing the opportunity to share best practice and harmonise counter fraud processes.

2.3 The Shared Service is responsible for the investigation of all types of suspected fraud within the Council, including but not limited to:

Corporate fraud matters in relation to offences committed by employees;

Procurement fraud by employees, Contractors or other third parties;

Fraud within schools;

Housing tenancy related fraud; Council Tax fraud, including Council Tax Reduction, discounts and exemptions; and

Blue Badges.

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3. Detail

3.1 Performance 1 April – 31 March 2017 3.1.1 The table below shows the number of new cases reported to the fraud team

from 1 April to 31 March 2017. The table below provides a summary of cases open and closed during the quarter: Summary of open/closed cases (Table 1)

Case Numbers

Open Cases (end quarter 3)

178

New Cases added (during quarter 4)

97

Cases Closed (during quarter 4)

127

Open Cases (end of quarter 4)

148

New offences (Table 2)

Case type Fraud alleged Total Sub-total

Council Tax 152

Council Tax Discount 20

Council Tax Reduction Support Data

132

Tenancy 67

Application 13

Occupancy 4

Right To Buy 32

Sub-let 17

Succession 1

Parking 66

Blue Badge 63

Other 2

Parking permit 1

Deception 23

Benefit 13

Grant 2

Insurance 2

Instrument of Payment 2

Planning 4

Financial investigation 9

Other 1

Planning 5

Proceeds of Crime Act 2

Sub-let 1

Other 7

Other 7

Business rates 3

National Non-Domestic Rates 3

Corruption 2

Bribery 1

Planning 1

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3.1.2 At the end of the period there were 148 cases open on the fraud system (there were 178 cases previously reported as open at the end of Quarter 3). It should be noted that cases will frequently and necessarily run for a number of months, so that the number closed does not correlate directly to those opened (shown in Table 1 above) in the same period.

3.1.3 Audit & Investigation must have reasonable and sufficient grounds to conduct a criminal investigation. Cases will be screened out, or not progressed with, for a variety of reasons including: that there is a more appropriate agency to deal with the allegation; that the allegation has no merit (including cases that are suspected of being malicious); or cases where after initial enquiries it is apparent that there are insufficient grounds to warrant further action. Only a proportion of the allegations received will progress to a full investigation. Resource is required to adequately address each stage of this process.

3.1.4 The table below shows the number of cases completed during the period 1 April to 31 March 2017, including those passed to other agencies (such as Department for Work and Pensions, Police or other London Borough) and those for which no further action was taken following initial enquiries. Cases closed 1 April – 31 March 2017 (Table 3)

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Council Tax 231 Council Tax discount 16 1 11 4 Council Tax Reduction 214 47 109 58 Other 1 1

Tenancy 80 Application 15 8 7 Occupancy 11 3 8 Other 1 1 Right To Buy 39 6 33 Sub-let 13 11 2 Succession 1 1

Parking 65 Blue Badge 61 2 24 35 Other 2 2 Parking permit 2 2

Deception 50 Benefit 33 9 12 12 Employment 2 1 1 Expenses 1 1 Grant 3 3 Insurance 2 2 Instrument of Payment 1 1 No Recourse to Public

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Corruption 4 Bribery 2 1 1 Conflict 1 1 Planning 1 1

Financial 3 Investigation Benefit 1 1 Other 2 2

Disciplinary Other 2 2 1 1

Total 442 70 207 165

325 cases were previously reported as closed at the end of Quarter 3. 3.1.5 The details of the 165 investigations completed between the 1 April and 31

March 2017 are detailed below (122 investigations were reported as completed at the end of Quarter 3).

Completed investigations 1 April - 31 March 2017 (Table 4)

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Council Tax C-Tax discount 3 1 1 3,236 CTRS 18 40 20 18,000 102,368 10,930

Tenancy Application 4 3 2 36,000 6,562 Occupancy 7 1 1 18,000 Other 1 Right To Buy 28 5 8 573,500 730 Sub-let 1 1 1 18,000

Parking Blue Badge 7 28 28 2,576

Deception Benefit 12 293,244 Employment 1 1 Expenses 1 Other 1

Corruption Bribery 1

Disciplinary Other 1

Total 73 92 62 666,076 406,140 10,930

Sections 3.1.4 – 3.1.6 below provide an explanation of the sanctions, notional and actual loss columns in Table 3 above:

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Sanctions - 3.1.6 Allegations involving ‘Council Tax’ resulted in identified losses of £105,604; 1

prosecution for a CTRS offence; the acceptance of 18 Council Tax Reduction Scheme financial penalties amounting to £10,930; and the ending of 1 Council tax discount and the refusal of 1 associated tenancy application.

3.1.7 Allegations involving ‘Deception’ mostly involved historic benefit fraud cases

and resulted in identified losses totalling £293,244. 1 further case resulted in a disciplinary penalty.

3.1.8 ‘Parking’ cases resulted in 28 proven instances of Blue Badge misuse. 1 case was prosecuted, 2 Blue Badges were seized and 25 written warnings were issued to first-time offenders.

3.1.9 Proved ‘Tenancy’ allegations involved Right to Buy applications, Occupancy, Tenancy applications, and sub-let. These cases resulted in actual proved losses of £7,292, the refusal of 1 tenancy application, the refusal of 5 Right to Buy applications and the recovery of 6 properties.

Notional loss proved - £666,076.

3.1.10 The notional loss is the amount the underlying asset would have been worth to the Council.

3.1.11 In the Annual Fraud Indicator 2011 the National Fraud Authority estimated a notional loss for a misused Blue Badge of £92.

3.1.12 28 Blue Badge cases have been proved and sanctioned, providing a notional saving of £2576. In addition 1 further case has been prosecuted

3.1.13 The Right to Buy scheme helps eligible council and housing association tenants in England to buy their home with a discount, in London, of up to £103,900. A Right to Buy sale that proceeds based on the provision of incorrect information results in a loss to the authority of a valuable asset at a fraction of its true value.

3.1.14 The 5 proved Right to Buy cases would therefore provide a notional saving of £519,500 (plus £54,000 for three tenancies recovered as a result of these investigations).

3.1.15 In their Protecting the Public Purse 2012 publication the Audit Commission identified an average annual notional cost of £18,000 to house a family or individual in temporary accommodation. This average notional cost has been used to estimate the nominal cost to the public purse of housing a tenancy fraudster.

3.1.16 In addition to the three council tenancies recovered above as part of the Right to Buy investigations, a further three have also been recovered providing an additional notional saving of £54,000. A further two applications have been rejected as the result of investigations creating additional saving of £36,000 (occupancy – ie. abandoned the property; sub-let; and, application – ie. weren’t entitled to the property in the first place).

3.1.17 The total of these notional savings to 31 March 2017 is £666,076.

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Actual Financial loss proved - £406,140.

3.1.18 Proved fraudulent loss for the period, including cases where fraud was proved but a sanction was not imposed, totalled £406,140. This loss is subject to on-going debt recovery action against the subjects of the investigations.

3.1.19 This is a direct financial loss to the Council as a result of fraud. It is not possible in all cases to impose a legal sanction, for example if there is insufficient evidence for a realistic prospect of conviction, if it is not in the public interest to prosecute or the subject of the investigation cannot be traced.

3.2 Performance 3.2.1 As outlined within the previously presented Counter Fraud Plan, the Shared

Service had a target of achieving 68 proven cases within the year. The team exceeded the target and achieved 92 proven cases.