RCCG/GB/13/171iii) MINUTES OF THE INTEGRATED AUDIT COMMITTEE Held on Wednesday 2 October 2013 at 2.00pm Stapleford Suite, Stapleford Care Centre Church St. Stapleford Nottingham NG9 8DB Present: Sue Bishop Ian Blair Anne Greenwood Paul Johnson Dr. Clive Rix Mark Russell Mike Wilkins Lay Member for Audit, Nottingham West CCG (Chair) Lay Member, Rushcliffe CCG Lay Member for Audit, Rushcliffe CCG Lay Member for Audit, Nottingham North & East CCG Lay Member, Rushcliffe CCG Lay Member, Nottingham West CCG Lay Member, Nottingham North & East CCG In attendance: Jonathan Bemrose Hazel Buchanan Tony Crawley Dr Cheryl Crocker Gary Roe Lynne Sharp Richard Walton Kevin Watkins Director of Finance, South CCGs Assistant Director, Strategy and Planning, Nottingham North & East CCG Director, KPMG Director Quality and Patient Safety Local Counter Fraud Specialist, EMIAS Head of Governance & Integration, Rushcliffe CCG Account Manager, KPMG Associate Director, EMIAS IAC/13/031 Apologies for Absence Apologies were received from Helen Cawthorne, Jim George and Tim Thomas. ACTION IAC/13/032 Declarations of Interest There were no declarations of interest. IAC/13/033 Minutes of 2 July 2013 Meeting IAC/13/016 Internal Audit Progress Report items ii) and iii) The executive summaries of the East Midlands SHA Learning Disability Dataset Collection Tool and the Deprivation of Liberty Safeguards: Usage in Hospital were supplied at the July meeting. The minutes would be amended deleting the sentence: An Executive Summary of the report would be brought to the next meeting in both cases. With this amendment, the minutes were accepted as a correct record. IAC/13/034 Matters Arising not elsewhere on the Agenda 1
i) IAC/13/034i) GEM Audit Arrangements the update was in the Internal Audit Report. ii) iii) IAC/13/025 Counter Fraud Risk Assessment 2013/14 it was agreed that issues would be more appropriate on the risk register than on the Assurance Framework. IAC/13/017 Assurance for Contracts Co-ordinated by other CCGs Mr. Watkins highlighted that the Memorandum of Understanding for Collaborative Commissioning described the coordinating commissioner role. An audit of how well this was working in practice was in the Internal Audit Workplan and the survey sent to Governing Body Members recently was part of this work. It was important to reach an agreement where the Internal Audit reports would be shared across CCGs and the Integrated Audit Committee was an appropriate forum for this. Dr. Rix stressed that it should not be limited to the Nottinghamshire CCGs as this would not include the EMAS contract for example. This needed a wider discussion with all CCGs and a process developed. Dr. Crocker agreed to raise this with Dr. Mansford as Chair of the Collaborative Commissioning Congress. CC Mr. Watkins suggested, with regard to responding to national reports, that the relevant Directors reported on what actions there might be for the CCGs. IAC/13/035 Internal Audit Progress Report i) Since the last meeting the following reports had been issued: Member Practice Engagement for Nottingham West Member Practice Engagement for Rushcliffe Member Practice Engagement for Nottingham North and East QIPP Follow-up Report With regard to the Member Practice Engagement reports, it was felt that these should go to the separate Audit Committees for more detailed discussion. LS/HH/HB Mr. Watkins added that 360 Assurance was undertaking this review across Nottinghamshire and Derbyshire and that there would be a best practice paper issued containing benchmarking information and best practice. With regard to the QIPP Follow-up Report, it was agreed that this would be reviewed in January 2014. Ms. Bishop stressed the importance of this report strategically especially as the financial situation worsened. Mr. Bemrose added that a Transformation Plan had been developed for NNE due to the outstanding conditions from the authorisation process. It was important to develop these plans for Rushcliffe and NW now. JB With regard to dealing with the implementation of best practice reports, it would make sense for the three Accountable Officers to agree to pursue best practice together and decide how it should be done. Anything finance or quality related could be resolved by the shared Director posts. ii) iii) Work in progress included the previously mentioned audit on Collaborative Commissioning and several follow up reviews in progress now. Other developments included: 2
The merger of EMIAS and Assure had been approved to form the new organisation 360 Assurance on 1 July 2013. GEM CSU Assurance Internal Audit had met with the CFO for GEM on 26 July 2013. GEM had approached all Internal Audit services for their client CCGs to get an idea of what assurances were required from them. iv) Deloitte had been appointed as Internal Auditor for NHS England to provide the required assurances over CSU operations. It had been subsequently recognised that CCGs, as clients of CSUs would also have assurance requirements. Deloitte had proposed a process known as Service Auditor Reporting to be used to meet these assurance needs. Concern had been expressed that this process could be heavily finance focussed when many other services were commissioned from GEM. To this end it was suggested that where a CCG required a very specific requirement for assurance that access would be facilitated for the CCG s internal auditors. A further meeting was organised for the end of October for both internal and external auditors to meet with GEM CSU to discuss arrangements. Mr. Crawley added that the VFM Conclusion guidance was expected and that it might be necessary to amend the Internal Audit Plan if there were any gaps identified for External Audit requirements. This would be an agenda item for the next meeting. Mr. Watkins highlighted a number of recent publications, drawing particular attention to the following: CQC published plans to change the way health and social care was regulated CQC Guide for Working Together: The CQC and Patient Participation Groups NHS England Information Governance Bulletin 2 including Accredited Safe Havens (ASH) HB Mr. Watkins reported that the Nottinghamshire CCGs were applying for ASH and Internal Audit had been approached to bring forward the review of the CCGs IG Toolkits to inform the ASH application. In response to a question about timing of the IG Toolkit review, Mr. Watkins expected that Internal Audit may receive direction to look at specific criteria later in the year and as such would not expect to do another complete review. It was noted that SBS was working well at the moment but was not resourced to develop individual relationships with clients doing this through GEM. Mr. Bemrose agreed to pick this up in his meetings with GEM. JB In response to a question from Ms. Bishop, Mr. Watkins responded that the plan had more audits in Q3 and 4, and that it was on track to deliver. With regard to Transformational Funding, this was to be followed up in June 2013 and so was overdue. Mr. Watkins reported that Terry Allen had taken the lead in responding on behalf of all CCG CFOs. Good progress had been made and that he was just waiting for the evidence. The Integrated Audit Committee NOTED this report. 3
IAC/13/036 Quality and Contract Monitoring in Care Homes Dr. Crocker updated on the action plan reporting that good progress had been made against the quality monitoring aspect of the report and that actions were almost complete. The contract monitoring had been given limited assurance and this was being progressed by NHS Hardwick CCG who had established a Notts/Derbyshire CCG group to agree a standard contract, monitoring requirements and CQUINS. It was possible that the December 2013 completion date would slip so this item would be brought back to the January meeting. Ms. Bishop highlighted that this should be on the CCGs risk registers or assurance frameworks. HB The Integrated Audit Committee NOTED the report and action plan. IAC/13/037 Quality Monitoring in Secondary Care by CCGs: Benchmarking and Best Practice Dr. Crocker reported that she had reviewed this document with Ruby Deo from 360 Assurance. The report focused on findings that were of potential comparative benefit: Governance arrangements and quality monitoring within the contracting process Collaborative commissioning Embedding quality in the contract Triangulation of quality data A self-assessment against the future considerations had been undertaken which had highlighted some actions none of which were high risk. The Integrated Audit Committee NOTED the benchmarking report. IAC/13/038 Quality Monitoring in Secondary Care Dr. Crocker reported that the action plan was now complete. Internal Audit would undertake a follow up and report at the next meeting. HB The Integrated Audit Committee NOTED the report and action plan. IAC/13/039 Digest CCG Audit Committees Survey 2013 Mr. Watkins reported that this was a draft report only because it had not been to the HFMA Audit Committee. It was unlikely to change therefore. The outcome of this survey would be that the HFMA Audit Committee Handbook would be amended to be relevant for CCGs from the findings of this survey. The report highlighted five areas which did not conform with established guidance or where guidance was sparse: i) Membership of audit committees ii) Reporting to Governing Bodies iii) Use of shared audit committee chairs iv) Collaborative audit committee arrangements v) Number of audit committee meetings A discussion ensued with the following points noted: The Committee(s) should agree with the Governing Bodies what Minutes should be on the Governing AG/SB/PJ 4
Body agenda For Assurance not for information There should be a written summary report to the Governing Body after each Audit Committee alongside the minutes The Audit Committee should direct the Governing Bodies on what they need to know and what they need more information on and could direct the development of Governing Bodies The Integrated Audit Committee NOTED this report. IAC/13/040 Anti-Fraud, Bribery and Corruption Policy Mr. Roe presented the CCGs Anti-Fraud, Bribery and Corruption Policy. In response to a question about disseminating the policy to staff, it was agreed that the policy would be on staff intranets, would form part of induction and there would be e-learning made available on counter fraud. The NHS Rushcliffe CCG Audit Committee APPROVED the Fraud, Corruption and Bribery Policy The NHS Nottingham West CCG Audit Committee APPROVED the Fraud, Corruption and Bribery Policy The NHS Nottingham North and East CCG Audit Committee APPROVED the Fraud, Corruption and Bribery Policy Mr. Roe added that the CCG approved Counter Fraud Workplans were based on standards for providers. Guidance for commissioning organisations would be available shortly. Any changes to the plan would be discussed and agreed with Mr. Bemrose. GR IAC/13/041 External Audit Update Mr. Crawley highlighted the following issues: Guidance was awaited which would relate the international standards for audit to the CCG plans Governance leads should check the arrangements for adopting the accounts this should be the Governing Body Audit Committee Institute autumn series of healthcare seminars focussing on: - Quality Management - CCG and CSU Risk Management and Governance - Supporting Governors Nottingham date was 14 November 2013 8am. LS/HB/HH The Integrated Audit Committee NOTED the update. IAC/13/042 Integrated Audit Committee Model Review As agreed at the start of the year, a formal review of the integrated audit committee model would take place after 12 months, however members could discuss how it was progressing at any point. Ms. Bishop opened the discussion stating that it was still early days however, one question was whether the model was saving operational time or not. In addition, there was a question mark over the balance of agenda items between the separate and integrated meetings and that the default was the integrated meeting which was not always correct. Each attendee was given the opportunity to put forward their view and the following points were noted: There was a mixing up of sharing best practice and learning from each other and assurance Internal Audit should attend the separate meetings There would be cost implications for Internal Audit to attend three meetings 5
External Audit would attend separate committees as the CCGs were statutory bodies Workload in Q3 and 4 would be different so the approach might need to be different Nottingham City led on some contracts and functions and should be included in the integrated meetings Shared executives expressed concern about the time commitment for attending three separate committees and the danger of getting different recommendations from the same reports The current model was administratively intensive and time consuming It was agreed the agenda setting was key to how well the model worked. It was agreed that the three Audit Chairs would meet to discuss this further. SB The Integrated Audit Committee NOTED the following publications were received for information: IAC/13/043 Building a Framework for Board/Governing Body Assurance IAC/13/044 Severance Payments Letter from David Nicholson May 2013 IAC/13/045 Fraud in Brief: Issue 3 IAC/13/046 Any Other Business i) Action for fraud in non-nhs Providers this would be shared with contract leads KW ii) Items for the Governing Bodies: AG/PJ/SB Process for adopting the accounts Policy on Fraud, Bribery and Corruption to note or ratify IA Review of Member Practice Engagement Audit Chairs meeting on the Integrated Audit Committee model IAC/13/047 Date and Time of the Next Meeting November separate meetings in Nottingham West and Rushcliffe to be arranged The next South CCGs Audit Committees were as follows: Tuesday 14 January 2014 from 1pm Gedling Civic Centre 1. Rushcliffe separate 2. Integrated Audit Committee 3. NNE separate Wednesday 15 January 2014 2pm Stapleford Care Centre 4. Nottingham West separate Signed by Chair Ms. Sue Bishop Date 6