Minutes of a Meeting of the CCG Audit Committee Held on Thursday
Transcription
Minutes of a Meeting of the CCG Audit Committee Held on Thursday
Subject to Ratification at the Next Meeting Minutes of a Meeting of the CCG Audit Committee Held on Thursday, 19 March 2015 in the Pitch View Meeting Room, Blackpool CCG Present: Mr D G Edmundson, Lay Member (Chairman) Mr C Brown, Lay Member Mrs C McKenzie-Townsend, Lay Member In Attendance: Mr G Raphael, Chief Finance Officer Mr T Cutler, Partner, KPMG LLP (UK) Mrs E A Squires, Senior Internal Audit Manager, Mersey Internal Audit Agency Mr D Davies, Anti-Fraud Specialist, Mersey Internal Audit Agency Miss L Hayton, Finance Manager Miss L J Talbot, Secretary to the Governing Body 01/15 Apologies for Absence Apologies for absence had been received from Mr Connor and Mrs Burrows. 02/15 Declarations of Interest Relating to the Items on the Agenda None relating to the items on the agenda. 03/15 Minutes of Meetings Held on 11 December 2014 RESOLVED: That the minutes of the meeting held on 11 December 2014 be approved as a correct record. 04/15 Matters Arising (a) MIAA Insight Report and Briefing Notes – Review of 17 CCG Assurance Frameworks – Mr Connor had informed Mr Edmundson outside of the meeting as to where Blackpool CCG featured on the CCG Risk Profile. (b) 101/14 (a) Anti-Fraud – Reference was made to the investigation of a potential fraud as detailed by Mr Raphael at the previous meeting. It had been referred to NHS Protect and had since been fully transferred to Fylde and Wyre CCG which is the lead commissioner for the provider. NHS Protect is working with the CSU to quantify the potential problem. NHS Protect had met with the Chief Executive of the relevant organisation to inform them that they were investigating the issue. Mr Davies reported that there could have been a potential overcharge however, through the contractual mechanisms, some of the funding would be returned. NHS Protect would then determine if any further action was required once the funds had been returned. Mr Edumundson commented that they would need to give us good reason as to why they would not follow up a potential fraud. (c) 102/14 Quality Monitoring Process – As discussed at the previous meeting, it was agreed that Ms Skerritt would write an Escalation Policy in respect of quality issues. Members were informed that there were no examples of an Escalation Policy available and this was also confirmed by internal audit colleagues. Ms Skerritt would be required to write a new policy which would be submitted to members for comment in due course. ACTION: HS 1 Subject to Ratification at the Next Meeting (d) 109/14 Losses and Special Payments – It was clarified that upon taking legal advice, special payments should be considered on an individual basis. Mr Raphael explained that the query related to a specific payment to a specific individual and he agreed to advise on this outside of the meeting once he had the relevant information. ACTION: GR 05/15 Terms of Reference and Membership of the Audit Committee The Secretary had reminded Governing Body members that the Audit Committee Terms of Reference and Membership had been reviewed and approved by the Governing Body in September 2014. In light of the recent Conflicts of Interest Policy which had been approved by the Governing Body, it was felt that reference should be made to the policy within the Terms of Reference and in line with the Audit Committee workplan. A bullet point would be added to section 6.4 regarding the committee reviewing the adequacy and effectiveness of: • All procedures and their operation in relation to conflicts of interest. RESOLVED: That members approve the amendment to the Terms of Reference and Membership of the Audit Committee which would be submitted to the Governing Body meeting on 5 May 2015 for approval. ACTION: LJT 06/15 Internal Audit (a) Progress Report - Mrs Squires spoke to a circulated report which provided an update in respect of the assurances, key issues and progress against the Internal Audit Plan for 2014/15. Discussion ensued as follows: • • • Key Financial Systems – A significant assurance level had been received with one medium recommendation and one low recommendation. It was noted that the Scheme of Delegation and the list of Oracle approvers was not consistent. Mr Brown asked if there could be management control to ensure it is monitored. Mr Raphael explained that the process for set up of Oracle is different to the Scheme of Delegation because managers have to be able to sign off invoices. Invoices can be paid once budgets are approved. Invoices tend to be for very large amounts. Mr Brown commented however, that as a principle there could be a management process that periodically we check that the two match up. It was suggested that this could be undertaken at the beginning of the year starting with the budget setting process. This was agreed and internal audit colleagues would also pick it up as part of their work. Follow Up on Recommendations - Mrs Squires reported that there were no issues on timelines in respect of the recommendations and she was comfortable with the progress made on the recommendations. Work in Progress – The following pieces of work were in progress and would be reported to the Committee following completion: - Assurance Framework - Information Governance Toolkit - Programme Management Arrangement - QIPP - Serious Untoward Incidents – The draft report had received limited assurance and was awaiting management response. This related to timeliness of information from the CSU to the CCG and there were also similar issues in respect of the complaints audit. 2 Subject to Ratification at the Next Meeting • • Request for Audit Plan Changes: - Personal Health Budgets – It had been agreed with Mr Raphael that the review would be undertaken with the auditors of Blackpool Borough Council, commencing in April 2015. MIAA Events Calendar – Mrs Squires tabled a copy of the forthcoming events for 2015/16. RESOLVED: (b) That members receive the Internal Audit Progress Report. Draft Annual Internal Audit Plan 2015/16 – Mrs Squires spoke to a circulated report which was the draft Internal Audit Plan 2015/16 and also included the Strategic Plan 2014/17. In particular, Mrs Squires drew members’ attention to the proposed internal audit plan coverage. There would be key pieces of work undertaken jointly with Fylde and Wyre CCG in respect of clinical coding (mortality). Mr Edmundson sought clarification as to what extent primary care co-commissioning and conflicts of interest should be included within the plan. Mr Raphael had had discussions with Mr Davies and had also raised this with Mr Cutler. There was lack of clarity as to who would be responsible for the audit of primary care. Once the CCG has delegated authority in respect of primary care co-commissioning it was intended that NHS England would be maintaining a Lancashire Team in respect of contracting work however, the operational details had not yet been clearly defined. Mr Cutler’s advice was that they would undertake audit on the financial statements. For internal audit, discussions would need to be held with the Director of Mersey Internal Audit Agency and organisations across the North West. It was recognised however, that two CCGs across the North West would not be taking full delegated authority which pointed to the need for a Lancashire-wide process. This issue would need to be revisited during the year. It may become a responsibility with problems. A message would be taken back to MIAA via Mrs Squires that we would want to have a quick resolution around this. It was also recognised that there would be implications in the CCG’s Annual Governance Statement. Mr Raphael had already had discussions with Mr Davies in respect of fraud investigations. Mr Raphael would raise this formally with NHS England and the Director of Mersey Internal Audit Agency. It was recognised that governance arrangements around this needed to be validated. ACTION: EAS/GR Reference was made to the risk areas to be kept under review which were contained within the plan and it was acknowledged that there needed to be a degree of flexibility during the year. Mrs Squires also informed members there was no change in the fee and it remained the same as the previous year at £31,680 and she also commented on the additional MIAA-wide pieces of work that were provided free of charge as part of the overall package provided by the Agency. It was recognised that clinical coding was an important issue and that there may be some other pieces of work which may arise out of this. Members were reminded that the joint piece of work would be undertaken with Fylde and Wyre CCG. CSU colleagues had carried out a piece of work analysing nonelective activity which showed that there was no evidence of significant changes in the way coding is undertaken. It was acknowledged however, that there were real changes in how sick people are. Mr Raphael would share the information with Mr Brown if required. The accuracy of coding for financial reasons could be considered when internal audit undertake their work and this was noted. RESOLVED: (c) That members approve the draft Internal Audit Plan 2015/16. Internal Audit Charter (Terms of Reference) RESOLVED: That members note that the Internal Audit Charter Terms of Reference remain unchanged. 3 Subject to Ratification at the Next Meeting (d) MIAA Insight/Briefings – Mrs Squires made reference to four documents presented to members: • • • • Nothing to Declare – A Review of Gifts, Hospitality and Sponsorship Registers – Members’ attention was drawn to the overall profile of the registers across CCGs which varied in terms of accepted or declined gifts, hospitality and sponsorship offers. The graph showed a number of CCGs where staff accepted gifts, hospitality or sponsorship. It was noted that there were two CCGs that reported declined gifts. A question was asked, do any of the Blackpool CCG staff decline gifts, hospitality or sponsorship? If so, do they report it? The Secretary would check the Constitution, Prime Financial Policies and Scheme of Delegation to ascertain whether declining gifts, hospitality or sponsorship is also reported. ACTION: LJT How are QIPP arrangements taking shape in CCGs? – Noted. Safe Nurse Staffing – Noted. Fit and Proper Persons Requirement in the NHS – Noted. RESOLVED: That members receive the MIAA Insights/Briefings. 07/15 External Audit (a) (b) Progress Report and External Audit Plan 2014/15 Mr Cutler took both items together. He drew members’ attention to the financial statements section within the External Audit Plan 2014/15 and in particular, the summary of response to financial statements opinion risks. He advised that there were no significant findings and colleagues had also reviewed the month nine position. Discussion ensued regarding the high significant audit opinion risks which related to management override of controls and revenue recognition however, Mr Cutler explained that it was common across a number of CCGs. He explained that there was a better system in place this year in obtaining remuneration information. Mr Cutler informed members that they would not be required to rely on the CSU Service Audit Reports as he was confident that colleagues will be able to undertake the work at the CCG which would remove the need for the Service Audit Reports. Mr Cutler then drew members’ attention to their approach in identifying any risks of value for money and the financial resilience and economy, efficiency and effectiveness. Mrs McKenzie-Townsend commented on the layout of the report and found it easily understandable. Mr Cutler informed members that from 31 March 2015, the Audit Commission would cease to be in existence and from 1 April 2015, Public Sector Audit Appointment Limited (PSAAL) would be established by the Local Government Association as an independent company which will oversee the Audit Commission’s audit contracts until they end in 2017. Members had no further comments on the External Audit Plan 2014/15 as discussion had been held at the previous meeting on the draft document. RESOLVED: That the Audit Committee approve the External Audit Plan 2014/15. 4 Subject to Ratification at the Next Meeting (c) Technical Update – Provided for information. RESOLVED: (d) That members receive the External Audit Technical Update. Confirmation of Auditor Appointment 2015/16 and 2016/17 – KPMG had been confirmed as the CCG’s Auditors to audit the accounts for the two years from 2015/16 which would cover the 2016/17 year end. A decision would be made in the summer 2015 as to whether the contract would be extended from 2017 to 2020. RESOLVED: That members note the confirmation of the auditor appointment. 08/15 Anti-Fraud (a) Progress Report - Mr Davies spoke to a circulated report. He had agreed the programme with Mr Raphael and confirmed that all of the tasks were either completed or in progress. He made reference to staff awareness informing members that a counter fraud session had been held the previous day. The Secretary commented that positive feedback had been received and that staff found the awareness session enjoyable. Other broad awareness material had been sent out to staff along with a counter fraud survey. Mr Davies would await the results of the survey and would report back accordingly. Mr Davies reminded members of the four generic areas within the progress report which related to: • • • • Strategic Governance Inform and Involve. Prevent and Deter Hold to Account. In particular Mr Davies made reference to three MIAA information alerts that had been issued to the CCG during the reporting period relating to bank mandate fraud, bogus phone calls and scam emails. Mr Davies drew members’ attention to a pro-active exercise undertaken in respect of continuing healthcare. He commented that the CCG has an established Continuing Healthcare Team that is supported by national guidelines and local policies and procedures. Whilst no issues were identified during this pro-active exercise, recommendations had been made in the report to improve existing system controls that would, if accepted, reduce the potential risk of fraud occurring. Mr Davies informed members that the team was very responsive to the recommendations and he was confident that the delivery of the plan was on track. Mr Raphael commented that Mr Davies had made a big difference to the fraud agenda ensuring staff are made aware of potential frauds and a good level of information had been sent out to staff. RESOLVED: (b) That members receive the Anti-Fraud Progress Report. Annual Workplan 2015/16 – Mr Davies spoke to a circulated document which was the Annual Workplan 2015/16. He explained that it linked in with the primary care co-commissioning and that the standards are based around the organisation. He commented that CCGs would need to put their own standards in place for counter fraud arrangements. NHS Protect would not be issuing guidance around this but would then undertake an inspection to review the CCG’s arrangements. It was also noted that another set of standards for security arrangements in provider organisations would be issued. 5 Subject to Ratification at the Next Meeting Mr Davies also reported that a piece of work would be undertaken relating to conflicts of interest, reviewing the CCG’s register and cross referencing with Companies House. Mr Edmundson commented that it appeared that the first few pages of the document could have been written for any CCG in the country. Mr Davies stated that whilst there was some generic information within the report, there were other sections regarding specific areas and he made reference to the key priorities for Blackpool contained within the report. The fee for the counter fraud work would be £8,000 and Mr Raphael had discussed it with Mr Davies previously and he was comfortable with the proposal. Mr Brown commented that timescales did not appear to be included within the plan and Mr Davies informed him that they would be translated in April into his workplan and timescales would be included in reports to the Audit Committee stating when the programmes would need to be delivered. RESOLVED: That members approve the Anti-Fraud Annual Workplan 2015/16 09/15 Annual Reports and Accounts (a) Accounts Timetable – Miss Hayton spoke to a circulated report which was a timetable for the completion of the accounts and had been produced in conjunction with the CSU. All parties were clear on their responsibilities. She informed members that as the process is being project managed by the CSU, the timetable is common across all local CCGs with local tailoring for each CCG for individual responsibilities and committee dates. Miss Hayton explained that we have also ensured there is sufficient time for the review of the accounts by the Chief Finance Officer. Miss Hayton took members through the timetable. It was noted that the submission date for the draft accounts was 23 April 2015 which was in line with the 2013/14 accounts. The deadline for the submission of the audited accounts had been brought forward by one week to 29 May 2015 however, she did not expect the shorter deadline to cause any issues. Members were reminded that the Audit Committee meeting to approve the accounts would be held on Tuesday, 26 May 2015. RESOLVED: (b) That members receive the accounts timetable. Accounting Principles and Issues for 2014/15 – Miss Hayton spoke to a circulated report which highlighted some of the main accounting issues facing the CCG in the preparation of its 2014/15 accounts. She commented that as it is the second year of operation, the CCG will have comparative data from 2013/14 included within the accounts. Members were informed that the CCG is required to disclose key accounting judgements and estimates which it has made in the preparation of its accounts. For 2014/15 they will include acute contract expenditure and prescribing. Miss Hayton also took members through other issues in relation to: • • • • Property Leases Managed by NHS Property Services Continuing Healthcare Restitution Claims CCGs Running Cost Allowance Pension Values – Information within the remuneration report would be consistent with the previous year Miss Hayton also made reference to accounting policies contained within the report. RESOLVED: That members note the accounting principles and issues for 2014/15. 6 Subject to Ratification at the Next Meeting (c) Review Draft Annual Governance Statement – The Secretary tabled the draft Annual Governance Statement which had been extracted from the draft CCG Annual Report. She asked members to provide her with comments by Friday, 27 March 2015. ACTION: ALL RESOLVED: That members receive the draft Annual Governance Statement for subsequent comment. 10/15 Audit Committee Workplan 2015/16 The Secretary sought further clarification in respect of the Audit Committee Workplan for 2015/16 and noted the amendments to be made. ACTION: LJT RESOLVED: That members agree to the changes within the Audit Committee Workplan 2015/16 noting that changes would be made throughout the year with agreement. 11/15 Midlands and Lancashire CSU Service Audit Briefing Mr Raphael spoke to a circulated report which was provided for information. Members were informed that internal audit colleagues obtain their assurance from the service audit reports. RESOLVED: That members receive the Midlands and Lancashire CSU Service Audit Briefing. 12/15 Governing Body Assurance Framework Mr Raphael spoke to a circulated document which was the Governing Body Assurance Framework. He conveyed his apologies in the lateness in sending the document out. Mr Raphael drew members’ attention to page 3 of the framework where he had included a new section regarding the level of achievement for the CCG on the Constitution standards. It had been flagged up as a high risk. Further work was taking place on the performance, finance and quality dashboards currently available. Mr Raphael had informed members that there had been an audit on the Governing Body Assurance Framework and he had covered some of the findings within the document. He had demonstrated and included within the document the links between gaps in control and action. Mr Raphael welcomed any comments particularly any areas which members felt were not covered within the framework. Mr Raphael made reference to the GP/Consultant Forum establishment which remained outstanding. It had not yet been set up and whilst some meetings had taken place, it was recognised that the Forum had not been established fully. He commented that we may want to discuss it as a CCG before it is sent out to the Governing Body and consider how they would wish to take this particular issue forward. The scoring for risk had reduced in respect of Communication and Engagement as a lot of work had been undertaken. The Public and Patient Engagement Strategy had been approved and reflected some of the work. Mr Cutler asked whether the CCG was sighted on what the risks are. Mr Raphael commented that the Governing Body Assurance Framework is submitted into the public domain and there needed to be careful and accurate wording in the document in respect of risks to services and quality provision especially our biggest risk in respect of mortality. Mr Cutler recognised the need to get the balance right 7 Subject to Ratification at the Next Meeting on describing risks whilst ensuring the CCG can be shown to be resolving them. Mr Brown asked whether there was something about residual risk. Mr Cutler made reference to the principal risk. Mr Raphael commented that he would accept any suggestions on how we phrase the risks before the next Governing Body Assurance Framework is issued. RESOLVED: That members receive the Governing Body Assurance Framework. 13/15 Standing Orders, Standing Financial Instructions and Prime Financial Policies Update Mr Raphael explained that the review of Standing Orders, Standing Financial Instructions and Prime Financial Policies was a standing item on the Audit Committee’s workplan. Both Mr Raphael and Miss Cosgrove were undertaking a piece of work on the CGG’s main financial policies and procedures. He explained that whilst the Constitution contains much of the CCG’s rules to follow, upon reviewing there are areas where we require further detail. Ms Cosgrove was currently reviewing the procurement procedures. It was recognised that information of this nature would need to be submitted more regularly through the Audit Committee and Mr Raphael asked whether it should also be submitted through the Finance and Performance Committee if relevant. Members noted that pieces of work were taking place starting with procurement and they were comfortable for Mr Raphael to determine what he feels would be appropriate that could be submitted to the Finance and Performance Committee. He also reminded members that with primary care co-commissioning coming into place, we would need more detail and clearer procedures. RESOLVED: That members note the pieces of work to be undertaken in respect of Standing Orders, Standing Financial Instructions and Prime Financial Policies. 14/15 Hospitality/Sponsorship Approvals The Secretary informed members that since the previous meeting of the Audit Committee, 23 members of staff from the CCG and GP Member Practices (along with a guest) had received hospitality through the Altogether Now Programme. There had been no applications for sponsorship approval. RESOLVED: That members note the information as outlined above. 15/15 Losses and Special Payments RESOLVED: That there was a nil return in respect of losses and special payments. 16/15 Schedule of Waivers The Secretary spoke to a circulated schedule which had identified one wavier received since the previous meeting in respect of the GP detailed care record cover and extended support for 12 months cover. There were no alternative quotes available due to the bespoke nature of the system to facilitate multiple user systems. The accumulated cost to the payee at the end of the waiver period was £37,722. Further clarification was required on the detail of the waiver. Mr Raphael commented that it was the integration of systems to undertake the MIG between secondary and primary care systems however, he would clarify this further outside of the meeting and would inform members accordingly. ACTION: GR RESOLVED: That members receive the Schedule of Waivers. 8 Subject to Ratification at the Next Meeting 17/15 Claims Update RESOLVED: That there was nil return in respect of claims. 18/15 CCG Risk Register (a) High Risks (Scores 15 and Above) – Members noted the high risks scoring 16 as contained within the CCG’s Risk Register relating to: • • Financial Issues A&E Waiting Times and Referral to Treatment Waiting Times The Secretary reported that the same high risks had been reported to the CCG Governing Body meeting held in public on 3 March 2015. Mr Brown made reference to risk scoring on mortality, which had recently been discussed at the Quality and Engagement Committee. It was commented that a lot of descriptions of the risk levels do not appear to be geared to commissioning risks. It was noted that they are mainly geared to providers. The outcome at the Quality and Engagement Committee was to retain the scoring as it was for the time being. Whilst it was recognised that the issues were not being addressed at pace, we would need to ensure that all of the actions are addressed. As the CCG is a commissioning organisation, it was felt that it was reasonable to change some of the definitions and further work would need to take place in looking at the five levels of consequence from a commissioning point of view. Mr Raphael informed members that a review of the risk register process and detail would be held the following week. The Secretary would ensure that colleagues from the CSU provide examples of risk registers more geared to commissioning. ACTION: LJT RESOLVED: That members note the risks scoring 16 as outlined above. (b) Items for Inclusion on the CCG Risk Register – No items for inclusion. 19/15 Items for the CCG Governing Body Meetings The Secretary noted the following items for inclusion on agendas: ACTION: LJT (a) 31 March 2015 – To approve the CCG Budgets for 2015/16. (b) 5 May 2015 – Terms of Reference and Membership of the Audit Committee and Risk Register discussion. 20/15 Any Other Business There were no issues. 21/15 Declaration of Confidentiality RESOLVED: 22/15 That with the exception of any agreed items to be submitted to the CCG Governing Body meeting held in public, all of the items should be regarding as confidential. Dates, Times and Venues of the Next Two Meetings • • Tuesday, 26 May 2015 at 11.30 am in the CCG Boardroom, to approve the accounts (colleagues from Internal Audit and Counter Fraud were not required to attend the meeting). Thursday, 17 September 2015 at 9.30 am in the CCG Boardroom. 9