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LONDON BOROUGH OF HOUNSLOW INTERNAL AUDIT PROGRESS REPORT February 2012

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Page 1: LONDON BOROUGH OF HOUNSLOW INTERNAL AUDIT PROGRESS …democraticservices.hounslow.gov.uk/documents/s67698... · Directors later this month. As mentioned previously, this is the starting

LONDON BOROUGH OF HOUNSLOW INTERNAL AUDIT PROGRESS REPORT

February 2012

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CONTENTS

PAGE

Introduction 3 Background 3 Update 3 Progress to Date 4 Definition of Assurance & Priorities 6 Priority 1 Recommendations 6 Appendix 1 - Status of Audit Work 8 Appendix 2 - Summary of Final Reports 17 Appendix 3 - Statement of Responsibility 23

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Introduction

This document sets out progress on the annual internal audit plan for the London Borough of Hounslow that was agreed by the Audit Committee at its meeting on 28

th April 2011. The purpose of

the report is to provide Audit Committee members and management with an update on the delivery of the internal audit plan and highlight any issues that should be brought to your attention.

This is Internal Audit’s third progress report to the Audit Committee for 2011/12, with the Annual Internal Audit Report and Opinion scheduled to be presented to the next meeting of the Audit Committee.

Background

The purpose of the internal audit plan is to identify the work required to achieve a reasonable level of assurance to be provided by the Council’s Internal Audit team in compliance with the Code of Practice for Internal Audit.

The fundamental role of Internal Audit is to provide senior management and Members with independent assurance on the adequacy, effectiveness and efficiency of the system of internal control, and to report major weaknesses together with recommendations for improvement. This role is fulfilled by carrying out appropriate audit work, normally in accordance with a strategic plan and an annual operational plan, as approved by the Director of Finance and the Audit Committee.

As internal audit is a major source of assurance that the Council is effectively managing the principal risks to the achievement of its corporate objectives, a key rationale for the development of the internal audit plan was the Council’s own Corporate and Service Risk Registers and how the internal audit plan can provide this assurance.

Update

Assurance Mapping and Control Risk Self Assessment (CRSA) Projects

Initial meetings have been held to discuss the Assurance Mapping project and a draft Assurance Framework has been mapped against both corporate and department risks for discussion with Directors later this month. As mentioned previously, this is the starting point for the population of the agreed Assurance Framework and we will then supplement this information with the objectives, risks and assurances coming out of the current Service and Financial Planning exercise facilitated by the Corporate Policy, Performance & Communications Unit. This, together with other assurance information derived from management, previous internal and external audit reports etc, will be used to help identify potential assurance gaps and so provide the focus for the 2012/13 Internal Audit plan in assisting management in the effective discharge of their responsibilities. In addition to supporting the IA Plan, a dashboard showing the various sources of assurance across the traditional three layers of defence would also be produced.

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We have also developed a draft CRSA template to support the production of the Annual Governance Statement (AGS) – this tool was developed using the most relevant guidance available from CIPFA and SOLACE and will enable a more complete view of individual governance arrangements in departments and will therefore better inform the AGS.

As it is our intention to use CRSA to support internal audit effort in future years, draft CRSA templates for key financial systems have also been prepared.

Progress to Date

Audit fieldwork on the 2011/12 Internal Audit Plan is progressing well and audit coverage has been in line with the plan, as shown in Appendix 1.

We have issued 8 final reports in the period since the last audit committee meeting in September and these are summarised in Appendix 2. These are:

• Council Tax • Budgetary Control – Corp Resources

• Housing & Council Tax Benefits • Edward Pauling School

• Grove Park School • Project Management

• Planning Application & Enforcement • Telecommunications

In addition, we have issued 11 draft reports where we await management’s response prior to issuing the final report. These are as follows:

• Data Quality • Budgetary Control – Environment

• Pensions Investments • Liberata – Contract Monitoring

• Southville School • Berkley School

• Green Dragon School • Western International Market

• Network Infrastructure • ITIL Assessment

• Swift Replacement

Management responses are currently being considered and the final reports will be issued shortly. The outcome of these audits will be reported to the next meeting of the Audit Committee.

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Definition of Assurance & Priorities

Audit assessment

In order to provide management with an assessment of the adequacy and effectiveness of their systems of internal control, the following definitions are used:

Level Symbol Evaluation Assessment Testing Assessment

Full There is a sound system of

internal control designed to achieve the system objectives.

The controls are being consistently applied.

Substantial

Whilst there is a basically sound system of internal control design, there are weaknesses in design which may place some of the system objectives at risk.

There is evidence that the level of non-compliance with some of the controls may put some of the system objectives at risk.

Limited

Weaknesses in the system of internal control design are such as to put the system objectives at risk.

The level of non-compliance puts the system objectives at risk.

Nil

Control is generally weak leaving the system open to significant error or abuse.

Significant non-compliance with basic controls leaves the system open to error or abuse.

The assessment gradings provided here are not comparable with the International Standard on Assurance Engagements (ISAE 3000) issued by the International Audit and Assurance Standards Board and as such the grading of ‘Full’ does not imply that there are no risks to the stated control objectives.

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Grading of recommendations

In order to assist management in using our reports, we categorise our recommendations according to their level of priority as follows:

Level Definition

Priority 1 Recommendations which are fundamental to the system and upon which the organisation should take immediate action.

Priority 2 Recommendations which, although not fundamental to the system, provide scope for improvements to be made.

Priority 3 Recommendations concerning issues which are considered to be of a minor nature, but which nevertheless need to be addressed.

System Improvement Opportunity

Issues concerning potential opportunities for management to improve the operational efficiency and/or effectiveness of the system.

Priority 1 Recommendations

Excluding schools, two priority 1 recommendations have been raised as a consequence of the final reports issued since the last Audit Committee meeting. These were as follows:

Audit Planning Applications and Enforcement

Recommendation A reminder should be issued to staff outlining their requirements to comply with the Data Protection Act, highlighting the fact that an applicant’s phone number was visible on a published document. Management should select a random sample of published applications each month to confirm this is being adhered to.

Response Agreed.

Implementation Date

November 2011

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Audit Project Management – Waste & Recycling

Recommendation There should be clarification between senior management and individual project managers concerning which activities should be carried out in accordance with the Project Management Framework.

In the event that an activity is to be run as a project this should be communicated to Project Managers. Project Managers should be made aware of the processes set out in the Programme and Project Management (P3M) Framework. and the criteria set out within the framework should be followed.

Response Management disagreed with the recommendation due to the fact that the Community Recycling Officer does not view Waste and Recycling as a distinct programme. It is viewed as a service line and therefore does not have a defined start and end date for completion of the programme. As a result, the Programme and Project Management (P3M) Framework was seen as not applicable.

Senior management should communicate with the Waste and Recycling service to clarify whether or not it is a defined programme. Only once this has been agreed, can the above recommendation be implemented.

Implementation Date

N/A

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Appendix 1 – Status of Audit Work

Audit Plan Days

Actual Days

Start of Fieldwork

Status Issue Date

Assurance Level

Recommendation Priorities

Notes

1 2 3

CORPORATE

Corporate Social Responsibility

15 5 February WIP

Business Continuity / Disaster Recovery

8 0 February

Partnerships 25 0 February Deferred to 2012/13.

Corporate Governance 8 2 February WIP

Corporate Risk Management 20 9 December WIP

Procurement 15 0 February

Value for Money – Cash Transportation

20 14 December WIP

Performance Management 12 2 February WIP

Data Quality 20 10 October Draft 24/01/12 Part 2 audit in Q4.

Construction Contracts 25 25 July Final 02/11/11 Sub / Sub 6 2

Communication & Consultation

10 0 February

Voluntary Sector Funding 12 12 August Final 09/11/11 Sub / Sub 4

Corporate Total 190 79

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Audit Plan Days

Actual Days

Start of Fieldwork

Status Issue Date

Assurance Level

Recommendation Priorities

Notes

1 2 3

FINANCE

Accounts Payable 18 18 October Draft 28/11/11

Debt Management 12 12 September Final 14/12/11 Full / Sub 1

Capital Budgeting & Accounting

10 10 April Final 07/07/11 Full / Sub 2

Council Tax 16 16 October Final 27/01/12 Sub / Sub 4

NNDR 12 12 October Draft 20/12/11

Housing & Council Tax Benefits

25 25 November Final 24/01/12 Sub / Sub 6 1

Budgetary Control 40

- Corporate Accounts 8 October Final 21/11/11 Full / Full

- Corporate Resources 8 October Final 27/01/12 Full / Sub 2 1

- Environment 8 January Draft 10/02/12

- Children’s 7 February WIP

- Community 7 February WIP

General Ledger 14 14 September Final 12/10/11 Sub / NA 1 1

Pensions Investments 8 8 January Draft 10/02/12

Pension Administration 10 10 October Draft 25/11/11

Treasury Management 15 15 August Final 03/10/11 Sub / Sub 2 1

Payroll & Staff Expenses 12 12 August Final 15/11/11 Full / sub 3 3

Cash & Banking 8 8 February Final 08/11/11 Sub / Sub 1 1

Liberata – Contract Monitoring

10 10 January Draft 10/02/12

Asset Management 12 12 April Final 07/07/11 Full / Sub 2

Mayors Fund 5 4 February WIP

Finance Total 227 224

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Audit Plan Days

Actual Days

Start of Fieldwork

Status Issue Date

Assurance Level

Recommendation Priorities

Notes

1 2 3

CHILDREN’S SERVICES AND LIFELONG LEARNING Children’s Commissioning 10 8 December WIP

Early Years 8 8 May Final 04/08/11 Sub / Sub 1 3 1

Schools – Primary: 164 150

Wellington May Final 18/07/11 Sub 5

St Lawrence May Final 21/07/11 Sub 5

Alexandra May Final 26/07/11 Sub 3

Hounslow Heath July Final 12/09/11 Sub 2

Hounslow Town July Final 14/09/11 Sub 4

Bedfont May Final 31/10/11 Sub 7

Belmont May Final 26/07/11 Sub 1

Rosary May Final 21/07/11 Sub 5

Strand-on-the-Green June Final 02/11/11 Sub 4

Crane Park July Final 12/10/11 Sub 1

Smallberry Green July Final 14/09/11 Sub 6 2

Cardinal Road May Final 18/10/11 Sub 3

Ivybridge July Final 02/11/11 Sub 3

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Audit Plan Days

Actual Days

Start of Fieldwork

Status Issue Date

Assurance Level

Recommendation Priorities

Notes

1 2 3

St Mary’s September Final 15/11/11 Sub 1 5

Cranford March

Southville November Draft 27/01/12

Spring Grove November Final 07/12/11 Sub 2

Edward Pauling November Final 11/01012 Sub 1 3

Forge Lane October Final 01/12/11 Sub 2 1

Heston March

Oriel November Final 07/12/11 Sub 3 2

Our Lady & St John November Final 21/11/11 Limited 2 3 2

Berkley November Draft 31/01/12

Green Dragon December Draft 31/01/12

Grove Park December Final 24/01/12 Sub 4

Springwell March

St Michaels & St Martins February WIP

St Mary’s (Chiswick) February WIP

Victoria February

Schools - Special 15 8

Oaklands January WIP

Lindon Bennett September Final 31/10/11 Sub 1 7

Home to School Transport 8 8 April Final 15/07/11 Full / Limited 2

Children’s Placements 10 7 December WIP

LMS 10 2 January WIP

Capital Programme – Schools Estate Management

10 10 September Final 20/11/11 Full / Sub 1

CSLL Total 235 211

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Audit Plan Days

Actual Days

Start of Fieldwork

Status Issue Date

Assurance Level

Recommendation Priorities

Notes

1 2 3

CORPORATE SERVICES

Programme / Project Management

40 40 July Final 24/01/12 Sub / Sub 1 4 1 Six reports / projects.

Equalities 12 0 March

Land Charges 8 8 July Final 09/11/11 Full / Sub 2 1

Redeployment & Redundency

12 0 February Deferred to 2012/13.

IT Procurement 9 9 May Final 12/10/11 Limited / Limited

2 6 1

Use of Consultants 12 1 February WIP

Absence Management 10 10 June Final 06/09/11 Sub / Sub 3

Health & Safety 10 10 September Final 21/11/11 Full / Sub 4 1

Facilities Procurement 15 15 July Final 18/10/11 Sub / Sub 5 2

Corp Services Total 128 93

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Audit Plan Days

Actual Days

Start of Fieldwork

Status Issue Date

Assurance Level

Recommendation Priorities

Notes

1 2 3

COMMUNITY SERVICES

Private Sector Housing Procurement

8 8 July Final 19/09/11 2 2 1

Contract Monitoring 6 0 February

Homelessness 8 8 May Final 26/07/11 Full / Sub 2

Supported Planning & Brokerage

12 0 February

Appointeeships 10 10 June Final 12/09/11 Full / Limited 1 1 1

Disabled Facility Grants 12 12 July Final 09/11/11 Full / sub 3

Petty Cash 8 8 May Final 04/08/11 Limited / Sub 1 1

Financial Assessments 18 15 November WIP

Comm Services Total 82 61

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Audit Plan Days

Actual Days

Start of Fieldwork

Status Issue Date

Assurance Level

Recommendation Priorities

Notes

1 2 3

ENVIRONMENT

Leisure Contract 12 12 May Final 07/09/11 Full / Sub 1 1

Property Management – Debt Management

8 2 December WIP

Car Parking:

- On-Street 7 6 Jan / Feb WIP

- Off Street 10 8 Jan / Feb WIP

- Enforcement 7 1 Jan / Feb WIP

Business Regulations 10 10 June Final 07/09/11 Full / Sub 3 1

Building Control 10 10 August Final 15/11/11 Sub / Sub 5

Emergency Planning 10 10 June Final 23/08/11 Sub / Sub 1 3

Planning Application & Enforcement

10 10 September Final 16/12/11 Sub / Limited 1 6 2

Western International Market

10 9 October Draft 10/02/12 Being reviewed.

Contract Monitoring – Open Spaces & Libraries

8 8 May Final 07/09/11 Full / Sub 1 1

Environment Total 102 86

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Audit Plan Days

Actual Days

Start of Fieldwork

Status Issue Date

Assurance Level

Recommendation Priorities

Notes

1 2 3

IT AUDIT PLAN

Telecommunications 15 15 December Final 13/02/12 Sub / Sub 7

Network Infrastructure 15 15 June Draft 30/09/11

ITIL Assessment 20 18 December Draft 13/02/12

Children’s Liquid Logic 10 1 January WIP Replaces ‘Change Management’.

Swift Replacement 30 16 Oct-Mar Draft 13/01/12

Revs & Bens 15 15 July Final 27/10/11 Sub / Sub 4 2

ICT Governance 15 0 March

Oracle HR & Payroll 13 13 September Final 09/12/11 Sub / Sub 3 2

IT Audit Follow-up 15 4 January WIP

Planning & Building Control 12 12 May Final 20/09/11 Sub / Limited 6 3

IT Plan Total 160 109

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Audit Plan Days

Actual Days

Start of Fieldwork

Status Issue Date

Assurance Level

Recommendation Priorities

Notes

1 2 3

OTHER

Hounslow Homes 106 81

Follow-up of Recommendations

35 26 On-going On-going

Contingency (balance) 40

- Information Governance Forum

10 7 On-going

- Overtime Investigation 14 14 May Contributed to Fraud report.

- Presentation to School Governors

2 2 September

- Temporary Agency Staffing

14 10 December WIP

TOTAL 1345 1003

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Appendix 2 - Summary of Final Reports

Brief outlines of the work carried out, a summary of our key findings raised and the assurance opinions given in respect of the final reports issued since the last meeting of the Audit Committee are provided in this section.

Council Tax

The scope covered the areas of Policy, Procedures and Legislation; Pendle Intake Process; Valuation; Tax Setting; Liability; Billing; Collection and Refunds; Recovery and Enforcement; Accounting and Systems Reconciliation; Performance Management; and Single Person Discount and Exemptions

Our assessment in terms of the design of, and compliance with, the system of internal control covered is set out below.

Evaluation Assessment Testing Assessment

Substantial Substantial

We raised four priority 2 recommendations where we believe there is scope for improvement within the control environment. These are set out below:

• Death of a tax payer.

• Authorisation of monthly write offs prepared by Liberata.

• Reconciliation of the General Ledger to the Council Tax system.

• Monitoring of Income Suspense Account.

In 2010/11 two audits of the Council Tax process were carried out, split in terms of the adequacy and effectiveness of the function and, in total, the reports raised eight recommendations. It was found that six recommendations have been implemented. However, the recommendations relating to monitoring of the suspense account and procedures being followed in the event of a tax payers death were not implemented and were therefore restated in this report.

Housing & Council Tax Benefits

The scope covered the areas of implementation of recommendations from previous audit; policies, procedures and legislation; Pendle intake process; Local Housing Allowance; administration and processing of new claims; renewals and amendments; backdated benefits; discretionary payments; payments; quality control; systems reconciliation; overpayments; and debt recovery and enforcement.

Our assessment in terms of the design of, and compliance with, the system of internal control covered is set out below.

Evaluation Assessment Testing Assessment

Substantial Substantial

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We raised six priority 2 recommendations and one priority 3 recommendation where we believe there is scope for improvement within the control environment. These relate to the following:

• Level Three Assessment Officers should ensure they complete an authorisation proforma detailing their decision to backdate benefits claims and have another Level Three officer review and agree their recommendations;

• The procedure for processing backdated benefits claims should be reviewed to ensure it complies with Council’s requirement with regard to how backdates are recorded on iWorld and made available to the relevant Assessment Officers;

• Once completed and signed, the Discretionary Housing Payment (DHP) Authorisation Form should be scanned onto the Anite imaging system;

• The Discretionary Housing Payment (DHP) spreadsheet should be annually reconciled to the DHP payments processed through iWorld to ensure correct payment;

• Reconciliation of printed cheques produced should be performed against the payment list detailing the total value of cheque payments to ensure correct payments are reflected on the printed cheques;

• System reconciliations performed by Liberata should be regularly reviewed and signed by the Client Unit as close to the time of the reconciliation as possible to ensure any issues are promptly raised with Liberata for further investigation; and

• The write off of outstanding overpayments should only be processed upon authorisation from the Chief Financial Officer.

Planning Applications & Enforcement

The scope covered the areas of Policies and Procedures; Planning Applications; Communication; Decision Making; Enforcement Action; and Complaints.

Our assessment in terms of the design of, and compliance with, the system of internal control covered is set out below.

Evaluation Assessment Testing Assessment

Substantial Limited

We raised one priority 1 recommendation, six priority 2 recommendations and two priority 3 recommendation where we believe controls can be improved. These are:

• Procedures should be developed for the enforcement process, outlining all requirements and documentation involved. The Enforcement procedures should include deadlines and targets for various stages of enforcement action to be completed by. These should also include Site Visits, Notification Letters, Delegated Officer Reports and Enforcement Notices.

• All policies and procedures should be reviewed on a regular basis, with the date of review recorded on the document.

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• The Planning Detail tool for searching and tracking the process of Planning Applications should be amended to specifically state the stages completed and remaining stages outstanding.

• All staff should be reminded that any visits should be recorded on I-Plan. Management should monitor this on a regular basis through random checks.

• The Planning Department should establish a set of performance targets to process planning applications within and these targets should be approved at an appropriate level. .Management should monitor this target through exception reporting on a regular basis, highlighting impending deadlines.

• An Action Plan should be developed to clear the backlog of enforcement actions outstanding. This plan should be monitored to confirm that targets are achievable and the backlog is being addressed.

• The Complaints icon that is available within the I-Plan system should be used to record all enforcement actions received. Once recorded, these should then be monitored and updated to ensure enforcement actions are processed within an agreed timeline to incorporate the requirement for visits to be undertaken.

• Complaints received regarding the Developmental Control Team should be resolved and responded to within the deadlines outlined in the Council’s Complaints Policy.

• Policy reminder should be issued to staff outlining their requirements to comply with the Data Protection Act, highlighting the fact that an applicant’s phone number was visible on a published document. Management should select a random sample of published applications each month to confirm this is adhered to.

Budgetary Control – Corporate Resources

The scope covered the areas of budget setting; budget monitoring and variance analysis; alterations and virements; financial and performance management reporting and the 2011/12 savings programme.

Our assessment in terms of the design of, and compliance with, the system of internal control covered is set out below.

Evaluation Assessment Testing Assessment

Full Substantial

We raised two priority 2 recommendations and one priority 3 recommendation where we believe there is scope for improvement within the control environment. These are set out below:

• A formal training programme should be designed and implemented to provide budget holders with the necessary information required to effectively manage their budgets.

• Staff should be reminded of the need to obtain authorisation and approval by the relevant budget holder with appropriate seniority before processing journals and special creditors/debtors.

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Where journal entries are constrained by time (i.e. salary miscoding), the Management Accountant/Finance Officer should, as a minimum, confirm the journal entry by way of an email notifying the budget holder of the budget adjustment.

• Authorisation and approval of virements should be obtained in accordance with the Council’s Financial Regulations. Where Executive approval for virements in excess of £100,000 is not sought, a written explanation should be maintained with the virement request form.

Consideration should be given to raising the issue of updating the Financial Regulations with the appropriate steering group to incorporate such acceptable accounting practices.

Budget allocation sheets, notifying budget holders of their allocations, are no longer required to be signed by budget holders to confirm acceptance. It was raised as a recommendation in the 2009/10 and highlighted as an accepted risk in the 2010/11 audit. It was confirmed during the course of this audit that there continues to be no requirement for budget allocations to be formally accepted as the risk is partly mitigated through the practice of monthly monitoring meetings. We have not raised a recommendation with regard to this, although would highlight that the risk has not been fully mitigated.

Project Management

We carried out an audit of Programme & Project Management as part of the 2011/12 Internal Audit Plan. Included in the sample of projects examined as part of the audit were the following:

• Waste & Recycling

• Older People’s Housing Care & Support

• ICT Security Improvements

• Savings & Transformation

• Children’s and Young People Plan

• Children’s Services and Lifelong Learning Efficiency Plan

The scope covered the areas of: management controls; benefits management; finance management; stakeholder management; risk management; organisational governance and resource management.

Whilst individual assessments were provided for each project, our overall assessment with regards Project Management in terms of the design of, and compliance with, the system of internal control covered is set out below.

Evaluation Assessment Testing Assessment

Substantial Substantial

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Across the six projects we raised one priority 1 recommendation, four priority 2 recommendations and a priority 3 recommendation where we believe there is scope for improvement within the control environment. These are set out below:

• Project Managers should be reminded that the processes set out in the Programme and Project Management (P3M) Framework should be adhered to. The Programme and Project Management (P3M) Framework should also be formally embedded across the Council to ensure that all relevant staff are aware of what processes are to be followed. The P3M framework should be communicated to all members of staff.

• The project’s risk log should be kept up to date. Mitigating actions recorded on the log should be reviewed to confirm that they have been implemented.

• A resource plan should be developed to record the time commitments of members of staff who are responsible for individual stages of the project.

• Roles and responsibilities should be clearly defined;

• A Benefits Realisation Plan should be put in place;

• The objectives of the project should be formally recorded as approved on the project’s approval log prior to the start date of the project.

Telecommunications

The scope covered the areas of Management Roles and Responsibilities, System Security, Call Restrictions, Resilience, Disaster Recovery and Maintenance, System Monitoring and Reporting.

Our audit of telecommunications found that whilst there is a basically sound system of internal control, there are weaknesses in design which may place some of the system objectives at risk.

Evaluation Assessment Testing Assessment

Substantial Substantial

We raised five priority 2 recommendations and two priority 3 recommendations where we believe there is scope for improvement within the control environment. These are set out below:

• There is currently no formal Telecommunications or ICT Strategy in place which contains adequate coverage on the technological developments of IP telephony at the Council.

• The framework of ICT policies were noted to be appropriate in content with ownership and documented version control, and adhere to areas of best practice. However, ICT policies and procedures were approved in October 2009 and have not been updated since this date.

• Logical access controls to the Cisco Unified Communication Manager (CUCM) Administration environment could be enhanced and aligned with the Information Security Policy at the Council.

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• Database backups of the Tiger 2020 call logging and management system were stated to be the responsibility of the supplier and host, as part of the service and support contract. However, at the time of the audit, this could not be verified.

• There was no telephone acceptable usage defined and developed for users at the Council.

• A formal documented Disaster Recovery Plan for the VoIP telephony network at the Council has yet to be developed.

• Formal procedures for the reconciliation of Tiger call logging and management reports with the telephony supplier billing invoices have not been developed to help ensure that the Council achieves value for money for the calls made.

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Appendix 3 - Statement of Responsibility We take responsibility for this report which is prepared on the basis of the limitations set out below.

Internal Audit February 2012

Contact Persons: Brian Welch John Clayden

Internal Audit Manager – 0208 583 2359 Internal Audit Manager – 0208 583 2359

The matters raised in this report are only those which came to our attention during the course of our internal audit work and are not necessarily a comprehensive statement of all the weaknesses that exist or all improvements that might be made. Recommendations for improvements should be assessed by you for their full impact before they are implemented. The performance of internal audit work is not and should not be taken as a substitute for management’s responsibilities for the application of sound management practices. We emphasise that the responsibility for a sound system of internal controls and the prevention and detection of fraud and other irregularities rests with management and work performed by internal audit should not be relied upon to identify all strengths and weaknesses in internal controls, nor relied upon to identify all circumstances of fraud or irregularity. Auditors, in conducting their work, are required to have regards to the possibility of fraud or irregularities. Even sound systems of internal control can only provide reasonable and not absolute assurance and may not be proof against collusive fraud. Internal audit procedures are designed to focus on areas as identified by management as being of greatest risk and significance and as such we rely on management to provide us full access to their accounting records and transactions for the purposes of our audit work and to ensure the authenticity of these documents. Effective and timely implementation of our recommendations by management is important for the maintenance of a reliable internal control system.