Comhairle nan Eilean Siar Internal Audit Review MANAGEMENT OF SICKNESS ABSENCES. Final Report 2013/14-18

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1 Comhairle nan Eilean Siar Internal Audit Review Final Report 2013/ st July 2013

2 CONTENTS Page SECTION 1 - EXECUTIVE SUMMARY 1-8 SECTION 2 - DETAILED FINDINGS AND RECOMMENDATIONS 9-27 SECTION 3 - ACTION PLAN APPENDIX A - RESPECTIVE RESPONSIBILITIES OF MANAGEMENT 31 AND INTERNAL AUDIT APPENDIX B - ISOLATED EXCEPTIONS TO EXPECTED PROCEDURES 32 Date of Visit May & June 2013 Draft Report Issued 13 th June 2013 Management Response Received 26 th June 2013 Final Report Issued 01 st July 2013 Issued to: Director of Finance & Corporate Resources Chief Executive Chief Executive s Department External Audit Robert Emmott Malcolm Burr Katherine Mackinnon Karen Jones 01 st July 2013

3 SECTION 1: EXECUTIVE SUMMARY Introduction 1.1 This report has been prepared following an internal audit review of the Management of Sickness Absences and as part of the operational annual internal audit plan for 2013/14. The purpose of this report is to provide an overview of the historical, current and planned performance in relation to the management of sickness/absenteeism. Background information 1.2 The Comhairle s sickness absences have been on a steady increase according to submitted performance indicators. In 2008/09 sickness absences for non-teaching staff were 10.5 days, 2009/10 were 9.5 days, 2010/11 were 13 days, 2011/12 were 13.8 days and in 2012/13 were 10.4 days. 1.3 Audit Scotland rated the Comhairle in 2007/08 as having the lowest levels of sickness across all Scottish local authorities. The underlying cause of this increase is not known to the Comhairle, although there have been a number of possibilities highlighted by the Unions. The Comhairle agreed as part of the budget setting process for 2013/14 that it intended to make savings of 100,000 as a result of reduced sickness levels. Internal audit objective 1.4 In accordance with the remit outlined within the operational annual internal audit plan for 2013/14 and further documented within the agreed terms of reference, our internal audit work was designed to obtain assurance that the Comhairle s arrangements for the Management of Sickness Absences were appropriate and operating as expected. In practice, we assessed whether the overall objective was being achieved by confirming that:- The organisation demonstrates VFM in all the services provided/supported and evidences that alternatives have been adequately considered, where available and appropriate. In addition, benchmarking is undertaken with other similar bodies, services and private sector; To ensure the reliability and adequacy of management information and that management action/consider information that is provided; To ensure adherence to management policies and directions and statutory requirements; To determine whether a sickness management policy and procedure has been adopted by the Comhairle; 01 st July

4 SECTION 1: EXECUTIVE SUMMARY (CONTINUED) To determine whether there are suitable support policies in place such as a well-being policy; To determine whether there are appropriate assessments operating within the Comhairle such as risk assessments/surveys for work-related illnesses; To determine whether there are appropriate assessments operating within the Comhairle such as screening at recruitment and selection stages; To determine whether there are health awareness programmes operating within the Comhairle; To assess what initiatives or actions to reduce staff turnover exist within the Comhairle; To review the absence data collection and supporting analysis and ascertain if it is provided to relevant Directors; The authority has formulated an Improvement Plan that details plans to reduce the sickness absence levels and improve the impact of initiatives and programmes; To proactively review Employee Surveys/Questionnaires and determine whether there are links between low or poor responses to higher than normal absenteeism, and Where there is evidence of repeated abuse of sickness absence arrangements, appropriate and targeted action is taken on a formal basis and has this resulted in a reduction in absences. 01 st July

5 SECTION 1: EXECUTIVE SUMMARY (CONTINUED) 1.5 Areas of good practice Introduction of better monitoring and provision of manager information which will hopefully focus managers attention on potential problem areas; A dedicated nurse on a pilot basis for the purpose of help and support for those on sickness leave; and There appears to be more of an emphasis on a corporate approach to sickness management, monitoring and intervention. Concluding remarks Our detailed findings are included in the body of this report. We would point out that the most significant issues arising from our review which require management attention are: Then need to implement processes and procedures for the extraction, collation and quality assurance of sickness absence data which forms statutory reporting requirements; (paragraph 2.6) The need to correct identified errors in the 2010/11 and 2011/12 performance indicator data published in relation to sickness absences as a result of duplication of data entries which have skewed the correct figures which have subsequently been reported and are incorrect; (paragraph 2.6) (At the time of our review this has been completed and shows a more favourable outcome) Staff who are successful at interview should not be allowed to commence work until a health screen form has been completed, returned and passed by the Occupational Nurse/Doctor, (paragraph 2.14) and There is concern that established policies in relation to sickness absences and reporting along with back to work interviews are not being applied consistently and correctly across departments and in some cases sections, creating inconsistent approaches. (paragraphs 2.7, 2.8, 2.9, 2.11 & 2.16) 01 st July

6 SECTION 1: EXECUTIVE SUMMARY (CONTINUED) 1.7 We have graded our detailed findings and recommendations, based on the likelihood of the identified weakness occurring and the impact on the Comhairle if it should occur, using the following criteria: Grade 1 - Critical High likelihood, High impact (HH) The weakness is almost bound to happen or is already happening (likelihood) and could have a significant impact on the Comhairle s services, reputation, control, financial position, statutory, regulatory or constitutional compliance if not contained Grade 2 - Contingent/Insurable Risk - Low likelihood, High impact (LH) The weakness is unlikely to happen, but would have a significant impact on the Comhairle s services, reputation, control, financial position, statutory, regulatory or constitutional compliance if it did occur Grade 3 - Housekeeping High likelihood, Low impact (HL) The weakness is almost bound to happen or is already happening but is unlikely to have a material impact on the Comhairle s services, reputation, control, financial position, statutory, regulatory or constitutional compliance, and can be contained Grade 4 - Value for Money High likelihood, Value for money impact (HV) The weakness is almost bound to happen or is already happening but if contained would have a positive impact on economy, efficiency and effectiveness in the use of resources Where we have identified isolated exceptions in our sample testing, and we consider that: - They are unlikely to recur; and Would have no significant impact if they should occur, we have classified them as low likelihood and low impact (LL), discussed them with relevant officers and detailed them in Appendix B to this report. 01 st July

7 SECTION 1: EXECUTIVE SUMMARY (CONTINUED) 1.8 Our recommendations can be summarised and prioritised as follows: Recommendation 2.1 The Director of Finance & Corporate Resources monitor the savings generated on a regular basis and continue to assess the likelihood of the savings to materialise. Overall grading The Organisational Development Manager provide those managers who receive staff sickness statistics with guidance on what should and shouldn t be concluded, together with potential pitfalls from misunderstanding or wrongly applying the use of the data. 2.3 The Organisational Development Manager should consider looking at repeated short term absences both to identify the possibility of non-genuine sickness absences but also to try and identify the possibility of poor work practices which could be contributing to regular sickness absences within the Comhairle. 2.4 The Organisational Development Manager should obtain advice from the Comhairle s Legal section in relation to the level of information that can be provided to departments without compromising sensitive and confidential data. The Organisational Development Manager should make it clear to staff, possibly via the staff newsletter, what the purpose of recently introduced sickness management/monitoring arrangements are and what duties the nurse will provide. 01 st July

8 SECTION 1: EXECUTIVE SUMMARY (CONTINUED) 1.8 Our recommendations can be summarised and prioritised as follows: Recommendation 2.5 The Organisational Development Manager consider using local trends and comparing these with national and private sector trends to establish appropriate levels of benchmarking and making these available to senior managers. Overall grading The Organisational Development Manager implements written procedures for staff undertaking such analysis which will be used in reported performance indicators in order to reduce the risk of a repeat. The figures reported for 2010/11 and 2011/12 should be revisited and recalculated to identify the true sickness statistics for the Comhairle. The Organisational Development Manager in consultation with External Audit determine the process of resubmitting the figures to Audit Scotland. 2.7 The Head of Human Resources advises all Directors that managers must follow up staff who have not submitted a sickness absence form as soon as reasonably possible. The Head of Exchequer Services monitors any delays in the Payroll section processing completed sickness absence forms. 2.8 The Head of Human Resources advises all Directors that managers must require staff who are off sick to complete the necessary sickness form and submit it as soon as reasonably possible for authorisation and processing. 01 st July

9 SECTION 1: EXECUTIVE SUMMARY (CONTINUED) 1.8 Our recommendations can be summarised and prioritised as follows: Recommendation 2.9 The Head of Human Resources advices all Directors of the need to comply with the sickness management policy and return to work interviews should be undertaken and recorded. Overall grading The Director of Finance & Corporate Resources considers alternative system based processes which calculate sickness pay for variable hour staff The Head of Human Resources should instruct all Directors to comply with the management of sickness absence policy contained within the Employment Handbook Consideration be given to staff surveys in areas where there is concern over high absenteeism in order to identify if there are underlying causes for absence. Consideration be given to the approach taken and whether a more encompassing method could be considered which will benefit all staff. Consideration be given to the need for appropriate vaccination for this group of employees The Head of Human Resources consider the staffing needs of the section and determine whether additional resources are necessary to allow fulfilment of the needs of the authority to be achieved. 01 st July

10 SECTION 1: EXECUTIVE SUMMARY (CONTINUED) 1.8 Our recommendations can be summarised and prioritised as follows: Recommendation 2.14 The Head of Human Resources advise all Directors that managers must not authorise successful candidates to start employment until the appropriate health screen has been received and passed by the Occupational Health section. Overall grading Consideration be given to the development and approval of a Health and Wellbeing Policy The Head of Human Resources should advise all managers of the importance of exit interviews to the organisation and that every effort should be made to hold an exit interview. 1.8 We would like to thank all staff for the co-operation and goodwill we received during the course of our internal audit fieldwork. For Comhairle Nan Eilean Siar Internal Audit Section Internal Audit Comhairle Nan Eilean Siar Sandwick Road Stornoway Isle of Lewis HS1 2BW 01 st July st July

11 SECTION 2 - DETAILED FINDINGS AND RECOMMENDATIONS 2.1 Control objective 1: The organisation demonstrates VFM in all the services provided/supported and evidences that alternatives have been adequately considered, where available and appropriate. The Comhairle has agreed as part of the 2 Will be considered as part of budget setting process for 2013/14 and quarterly reporting in 2013/ /15 that 100,000 will be saved via With effect from September the reduction in sickness leave These targets are ambitious and will require close monitoring on an ongoing basis to track any variations. H L The Director of Finance & Corporate Resources monitor the savings generated on a regular basis and continue to assess the likelihood of the savings to materialise. The difficulty with setting such savings is that not all reductions in sickness levels will directly correlate, in fact, only areas where there is not a specific need to provide replacement staff will attract such a saving. There is a risk that the savings outlined in the budget setting may not fully materialise resulting in savings having to be made in alternative ways. This is further compounded by the overstatement of sickness figures reported in the Comhairle s Performance Indicators. 01 st July

12 2.2 Control objective 1: The organisation demonstrates VFM in all the services provided/supported and evidences that alternatives have been adequately considered, where available and appropriate. The increases in sickness rates can indicate 3 Organisational Development a number of issues both at work and home. will develop guidance to It is often difficult to narrow down the support the implementation of exact causes, however, where sections quarterly sickness absence within the Comhairle have clear pockets of reports; this will also cover sickness across a number of staff could be data protection issues. an indication of an organisational issue. It is important that when managers are provided with sickness statistics there is a need to consider both the pitfalls and benefits of having such data. H L The Organisational Development Manager provide those managers who receive staff sickness statistics with guidance on what should and shouldn t be concluded, together with potential pitfalls from misunderstanding or wrongly applying the use of the data. Managers should be provided with some guidance in relation to what can and cannot be reasonably concluded from the figures provided. This will help to allow a consistency of application of thought and allow reasonable conclusions to be drawn from the data. 01 st July

13 2.3 Control objective 1: The organisation demonstrates VFM in all the services provided/supported and evidences that alternatives have been adequately considered, where available and appropriate. A key element of managing absence H V The Organisational Development 4 The first quarter sickness effectively is accurate measurement and Manager should consider looking absence reports to Departments monitoring. An organisation must assess if at repeated short term absences are due in July it has a problem with absence, its extent both to identify the possibility of Organisational Development and the best way to tackle it. Regular non-genuine sickness absences patterns that emerge such as regular but also to try and identify the absences on Mondays or Fridays may possibility of poor work practices indicate that the sickness absence is not which could be contributing to genuine. regular sickness absences within the Comhairle. The Bradford Factor identifies persistent short-term absence for individuals, by measuring the number of spells of absence, and is therefore a useful measure of the disruption caused by this type of absence. are currently working on the layout of these and will consider the definition of, and addition of repeated short term absence. OD will not interpret the results or draw conclusions regarding employees on behalf of managers. Long term sickness is often easier for managers to address, this is less so for repeat short term absence which often have a direct effect on the provision of a service. It is therefore important that such absences are investigated as these can also be a sign of a variety of issues such as poor management, stress, over-load and a lack of support. 01 st July

14 2.4 Control objective 3: To ensure adherence to management policies and directions and statutory requirements. The Employment Act 2002 and the L H The Organisational Development 2 Organisational Development Employment Act 2002 (Dispute Manager should obtain advice will obtain advice from Legal Resolution) Regulations 2004 and as from the Comhairle s Legal Services on this matter. amended, provide the main legal tools for section in relation to the level of facilitating absence management. information that can be provided However, numerous other pieces of to departments without legislation also have an impact on absence compromising sensitive and management. Employers must be careful confidential data. not to breach the Data Protection Act 1998 (DPA) when they collect, use and store H L The Organisational Development 3 Progress with sickness absence information about their employees Manager should make it clear to monitoring and its implications absences. Details of an employee s health, staff, possibly via the staff for employees will be included either physical or mental, are categorised newsletter, what the purpose of in the September 2013 as sensitive personal data under the DPA. recently introduced sickness newsletter. The DPA also requires openness. Staff management/monitoring should know what information about their arrangements are and what duties health is being collected and why. the nurse will provide. It is therefore important that data collected and distributed should be advised to staff and compliant with DPA. 01 st July

15 2.5 Control objective 1: The organisation demonstrates VFM in all the services provided/supported and evidences that alternatives have been adequately considered, where available and appropriate. As part of the Comhairle s key H V The Organisational Development 4 Human Resources are Performance Indicators, sickness absence Manager consider using local undertaking work to is reported both for teaching and non- trends and comparing these with benchmark all business units teaching staff. national and private sector trends within the Comhairle and this Whilst trends can be built up for the to establish appropriate levels of includes sickness absence data. Comhairle over a number of years, it may benchmarking and making these also be beneficial if these are compared available to senior managers. with national trend and also compared to the private sector. Whilst there is some evidence of comparison; some of this information tends to be very historic. This additional information will allow the Comhairle to compare trends with other local authorities and also benchmark with the private sector average. 01 st July

16 2.6 Control objective 1: The organisation demonstrates VFM in all the services provided/supported and evidences that alternatives have been adequately considered, where available and appropriate. As part of our review we looked at the statistics produced in terms of national reporting in relation to sickness absences. We noted a surprising increase in the figures from 2008/2009 to that reported in 2009/10 and 20010/11. The reported figures show a significant jump sickness of 3,395 days in 2010/11 and a further 92 days in 2011/12. This is despite the fact that there was a reduction in staffing of 176 recorded against full time equivalent staff. These changes usually indicate a statistical error as such dramatic changes rarely follow. In discussion with HR, it become clear that the management reports used to extract the information could provide duplicate figures. (Continued) 01 st July

17 2.6 Control objective 1: The organisation demonstrates VFM in all the services provided/supported and evidences that alternatives have been adequately considered, where available and appropriate. Con t. L H The Organisational 2 Development Manager This happens in the case where a member implements written procedures of staff has more than one job within the for staff undertaking such Comhairle, in such circumstances any analysis which will be used in absences are recorded against all jobs reported performance indicators rather than only the post where the in order to reduce the risk of a absences occurred. In effect there is likely repeat. to have been double accounting and in H H 1 some circumstances triple accounting of these figures. This has resulted in the skewing of figures reported and showing an abnormally high reported sickness rate. 10/11 11/12 12/13 Reported (days) Corrected to L H The figures reported for 2010/11 and 2011/12 should be revisited and recalculated to identify the true sickness statistics for the Comhairle. The Organisational Development Manager in consultation with External Audit determine the process of resubmitting the figures to Audit Scotland. 2 With the additional resources allocated to the HR Resourcelink project over the past nine months, a large data cleanse of the HR/Payroll system has been undertaken. This has enabled HR to utilise the database in a completely new way and to have full confidence in the system data for the first time. As part of this project, historic data, as well as current data has been reanalysed to ensure that moving forward, HR is able to respond to requests for information on previous years as well as current data. It is through this data cleanse and subsequent rechecking that these inaccuracies have come to light. 01 st July

18 2.7 Control objective 3: To ensure adherence to management policies and directions and statutory requirements. In reviewing submitted sickness forms by L H The Head of Human Resources 2 Human Resources will develop staff, we noted that there were delays in advises all Directors that a succinct guidance document both departments processing sickness managers must follow up staff for managers on relevant returns and also albeit to a lesser extent the who have not submitted a Comhairle policies to fit processing of these forms once in the sickness absence form as soon as alongside developments in the Payroll section. In addition, we noted reasonably possible. Resourcelink project. incorrect figures being entered. It would appear that processing of sickness can take up to two months to appear on staff payslips. H L The Head of Exchequer Services monitors any delays in the Payroll section processing completed sickness absence forms. 3 No proposals to take any additional action as the problem relating to delays is with the departments and not the Payroll Section 01 st July

19 2.8 Control objective 3: To ensure adherence to management policies and directions and statutory requirements. We identified an isolated case where it L H The Head of Human Resources 2 Human Resources will develop appeared that a member of staff was taking advises all Directors that a succinct guidance document sick leave and not completing appropriate managers must require staff who for managers on relevant documentation to record such absences. In are off sick to complete the Comhairle policies to fit effect such absences were not processed in necessary sickness form and alongside developments in the accordance with the sickness policy or submit it as soon as reasonably Resourcelink project. expected procedures which are clearly possible for authorisation and outlined to staff. processing. There is a risk that if sicknesses are not reported as per the organisations procedures, this could not only fail to trigger the system of additional monitoring but also not be recorded statistically or on the payroll system. There is also an assumption that staff are automatically entitled to six months sick pay. This is not the case and depends on service with the authority. 01 st July

20 2.9 Control objective 3: To ensure adherence to management policies and directions and statutory requirements. All staff who are absent from work due to sickness should Upon return to work following sickness absence the line manager should arrange to meet privately with the employee, ideally during the first day back or at least within three days of the return to work or as soon as reasonably practicable. The purpose of this meeting will be to welcome the employee back to work, ensure that there is an accurate record of the absence and appropriate certification and update the employee on work issues. The manager will wish to establish if there was an occupational factor which contributed to the sickness and assure the employee that any work-related issues will be addressed. The manager should give assurances of their concern for the employee s welfare, balanced with their concerns about service delivery and the impact on other team members. A record should be kept of the meeting and placed on the personnel file; a copy should be given to the employee. Continued 01 st July

21 2.9 Control objective 3: To ensure adherence to management policies and directions and statutory requirements. Con t L H The Head of Human Resources 2 HR will develop a succinct There is risk that the sickness management advices all Directors of the need guidance document for arrangements outlined within the to comply with the sickness managers on relevant Employment Handbook are not been management policy and return to Comhairle policies to fit applied either at all or inconsistently work interviews should be alongside developments in the throughout the Comhairle. undertaken and recorded. Resourcelink project. 01 st July

22 2.10 Control objective 2: To ensure the reliability and adequacy of management information and that management action/consider information that is provided. The calculation of HCW s sickness pay is L H The Director of Finance & 2 Under review through the Care more complex due to variable hours which Corporate Resources considers Scheduling Strategy Group. can be often mixed with contracted hours. alternative system based We are advised that in relation to variable processes which calculate hours, an average is taken over a 13 week sickness pay for variable hour period which then indicates what the HCW staff. should be paid in terms of sickness. This calculation is undertaken by staff within Social & Community Services and then sent to the Payroll section for processing. This manual process may increase the risk of errors occurring and not being detected at source, together with being uploaded onto the main Payroll system without further checks occurring. 01 st July

23 2.11 Control objective 3: To ensure adherence to management policies and directions and statutory requirements. We noted as part of our testing that in 4 L H The Head of Human Resources 2 HR will develop a succinct cases out of a sample of 24 staff had not should instruct all Directors to guidance document for completed a FIN6 form on their return. In comply with the management of managers on relevant such cases the dates on the doctor s fitness sickness absence policy Comhairle policies to fit to work certificate were used for Payroll contained within the alongside developments in the purposes. Employment Handbook. Resourcelink project. The Comhairle s Employment Handbook states in relation to sickness absence management that If the employee is absent from work for more than seven days then a doctors statement of fitness to work must be submitted to cover the absence beyond the seven days. The employee must also complete and return the sickness absence certificate FIN6 which will be issued by the Department when the employee s report his/her fourth day of absence. 01 st July

24 2.12 Control objective 6: To determine whether there are appropriate assessments operating within the Comhairle such as risk assessments/surveys for work-related absences. There are no post-employment health H L Consideration be given to staff 3 HR will work with Directors to surveys to identify pockets or areas of surveys in areas where there is support intervention in areas concern. However, there are referral forms concern over high absenteeism identified as having high levels for those staff or managers who have in order to identify if there are of sickness absence. concern about staff. This increases the risk underlying causes for absence. that incidents of illness, stress and absenteeism may not be fully explored. Consideration be given to the The Comhairle is a large employer and approach taken and whether a undertakes a number of health awareness H L more encompassing method 3 initiatives which are run by the could be considered which will Occupational Health section. In addition benefit all staff. the Comhairle have applied for Healthy Working Lives status which is awarded in bronze, silver and gold. Different locations are working towards differing levels of award but bronze and silver have been awarded. The difficulty is that is appears to be location based rather than across the whole of the Comhairle. Well North also undertake assessment and screening for those over 40 and the last event was in May 2012 and is undertaken every 5 years. Continued. 01 st July

25 2.12 Control objective 6: To determine whether there are appropriate assessments operating within the Comhairle such as risk assessments/surveys for work-related absences. Con t Whilst the scheme is beneficial and good practice, there may be gaps of approach within the Comhairle where not all staff benefit from the scheme. Whilst Home Care Workers do not undertake medical duties, they can come into contact with body fluids as part of their duties and this may increase the risk to their health. There is concern however that not all potential risk related areas are covered such as Home Care Workers. L H Consideration be given to the need for appropriate vaccination for this group of employees. 2 HR will work on the development of a Wellbeing Strategy for employees which will encompass these areas of concern. 01 st July

26 2.13 Control objective 3: To ensure adherence to management policies and directions and statutory requirements. There are currently two occupational H V The Head of Human Resources 4 Additional resources have been nurses employed for the Comhairle on a consider the staffing needs of the allocated to assist Departments part-time basis for undertaking:- section and determine whether in the implementation of the 1) Pre-employment assessments additional resources are sickness absence policies. This 2) Health Monitoring/screening necessary to allow fulfilment of provision will be reviewed on a 3) Health promotion/advice the needs of the authority to be value for money basis before 4) Health referrals and advice achieved. March ) Ensuring employers aware of adjustments to comply with DDA 6) Training managers to manage attendance, prevent or mitigate physical or mental illness 7) Identifying work related disease The fulfilment of these duties throughout the geographical area of the Comhairle will be challenging and given the current resources may not be possible. 01 st July

27 2.14 Control objective 6: To determine whether there are appropriate assessments operating within the Comhairle such as risk assessments/surveys for work-related absences. All pre-appointed staff must complete a H H The Head of Human Resources 1 HR will develop a succinct health screening questionnaire which is advise all Directors that guidance document for used by the occupational health section to managers must not authorise managers on relevant assess whether the individual can successful candidates to start Comhairle policies to fit undertake the duties of the post. We noted employment until the alongside developments in the that in some instances, departments do not appropriate health screen has Resourcelink project. always wait for the results of this been received and passed by the assessment before allowing the individual Occupational Health section. to start work. It must be emphasised that whilst this occurs in few cases, there is nevertheless the risk of a serious problem to occur for both the Comhairle and individual in terms of personal wellbeing and liability in the event of injury or unsuitability for the post due to medical reasons. 01 st July

28 2.15 Control objective 5: To determine whether there are suitable support policies in place such as a well-being policy. The Comhairle has a number of policies in H V Consideration be given to the 4 HR will work on the place which would contribute to the basis development and approval of a development of a Wellbeing of a Health and Wellbeing Policy. Health and Wellbeing Policy. Strategy for employees which However, there is currently no policy in will encompass these areas of place. Given the current documentation in concern. place such a policy would be relatively straight forward to prepare. The policy sets out the organisations commitments and responsibilities, and also those of the senior management team, line managers and staff. In terms of best practice organisations the size of the Comhairle should have a clear policy and statement in relation to Health and Wellbeing. 01 st July

29 2.16 Control objective 8: To assess what initiatives or actions to reduce staff turnover exist within the Comhairle. When staff intend to leave the Comhairle, L H The Head of Human Resources 2 HR will develop a succinct part of the process involves a questionnaire should advise all managers of guidance document for which should be completed by the member the importance of exit interviews managers on relevant of staff and submitted/discussed with line to the organisation and that Comhairle policies to fit managers to allow the Comhairle to every effort should be made to alongside developments in the consider areas for improvement. hold an exit interview. Resourcelink project. We reviewed the last 24 members of staff leaving the Comhairle and found that only 7 had evidence of such an interview on file or a completion rate of 29%. 01 st July

30 SECTION 3 - ACTION PLAN Ref. RECOMMENDATION RESPONSIBLE OFFICER 2.1 The Director of Finance & Corporate Director of Finance Resources monitor the savings generated on a & Corporate regular basis and continue to assess the Resources likelihood of the savings to materialise. DATE OF IMPLEMENTATION September The Organisational Development Manager provide those managers who receive staff sickness statistics with guidance on what should and shouldn t be concluded, together with potential pitfalls from misunderstanding or wrongly applying the use of the data. 2.3 The Organisational Development Manager should consider looking at repeated short term absences both to identify the possibility of nongenuine sickness absences but also to try and identify the possibility of poor work practices which could be contributing to regular sickness absences within the Comhairle. 2.4 The Organisational Development Manager should obtain advice from the Comhairle s Legal section in relation to the level of information that can be provided to departments without compromising sensitive and confidential data. The Organisational Development Manager should make it clear to staff, possibly via the staff newsletter, what the purpose of recently introduced sickness management/monitoring arrangements are and what duties the nurse will provide. 2.5 The Organisational Development Manager consider using local trends and comparing these with national and private sector trends to establish appropriate levels of benchmarking and making these available to senior managers. Organisational Development Manager Organisational Development Manager Organisational Development Manager Organisational Development Manager Organisational Development Manager November 2013 November November September Already Underway. New benchmarking data in August

31 SECTION 3 - ACTION PLAN Ref. RECOMMENDATION RESPONSIBLE OFFICER 2.6 The Organisational Development Manager Organisational implements written procedures for staff Development undertaking such analysis which will be used Manager in reported performance indicators in order to reduce the risk of a repeat. The figures reported for 2010/11 and 2011/12 should be revisited and recalculated to identify the true sickness statistics for the Comhairle. Organisational Development Manager DATE OF IMPLEMENTATION The Resourcelink Project Officer has commenced this work. Completion of all guidance for the Resourcelink system will be alongside completion of the project. The Organisational Development Manager in consultation with External Audit determine the process of resubmitting the figures to Audit Scotland. 2.7 The Head of Human Resources advises all Directors that managers must follow up staff who have not submitted a sickness absence form as soon as reasonably possible. The Head of Exchequer Services monitors any delays in the Payroll section processing completed sickness absence forms. 2.8 The Head of Human Resources advises all Directors that managers must require staff who are off sick to complete the necessary sickness form and submit it as soon as reasonably possible for authorisation and processing. 2.9 The Head of Human Resources advices all Directors of the need to comply with the sickness management policy and return to work interviews should be undertaken and recorded The Director of Finance & Corporate Resources considers alternative system based processes which calculate sickness pay for variable hour staff The Head of Human Resources should instruct all Directors to comply with the management of sickness absence policy contained within the Employment Handbook. Organisational Development Manager Head of Human Resources Head of Exchequer Services Head of Human Resources Head of Human Resources Director of Finance & Corporate Resources Head of Human Resources Document developed by October 2013 Sickness absence through Resourcelink March No action proposed by Management. Document developed by October 2013 Sickness absence through Resourcelink March Document developed by October March Document developed by October

32 SECTION 3 - ACTION PLAN Ref. RECOMMENDATION RESPONSIBLE OFFICER 2.12 Consideration be given to staff surveys in areas Head of Human where there is concern over high absenteeism Resources in order to identify if there are underlying causes for absence. Consideration be given to the approach taken and whether a more encompassing method could be considered which will benefit all staff. Head of Human Resources DATE OF IMPLEMENTATION Survey conducted after 1 year of increased sickness absence monitoring. By July Outcomes of increased monitoring by July Consideration be given to the need for appropriate vaccination for this group of employees The Head of Human Resources consider the staffing needs of the section and determine whether additional resources are necessary to allow fulfilment of the needs of the authority to be achieved The Head of Human Resources advise all Directors that managers must not authorise successful candidates to start employment until the appropriate health screen has been received and passed by the Occupational Health section Consideration be given to the development and approval of a Health and Wellbeing Policy The Head of Human Resources should advise all managers of the importance of exit interviews to the organisation and that every effort should be made to hold an exit interview. Head of Human Resources Head of Human Resources Head of Human Resources Head of Human Resources Head of Human Resources Vaccination programme reviewed by 1 October Value for money assessment made by March Document developed by October Policy in place by 1 st April Document developed by October

33 APPENDIX A: RESPECTIVE RESPONSIBILITIES OF MANAGEMENT AND INTERNAL AUDIT Responsibility in relation to internal controls It is the responsibility of the Comhairle s management to maintain adequate and effective financial systems and to arrange for a system of internal controls. Our responsibility as internal auditors is to evaluate the financial systems and associated internal controls. In practice, we cannot examine every financial implication and accounting procedure within an activity, and we cannot substitute for management s responsibility to maintain adequate systems of internal controls over financial systems. We therefore may not identify all weaknesses that exist in this regard. Responsibilities in relation to fraud and corruption The prime responsibility for the prevention and detection of fraud and irregularities rests with management. They also have a duty to take reasonable steps to limit the opportunity for corrupt practices. It is our responsibility to review the adequacy of these arrangements, but our work does not remove the possibility that fraud, corruption or irregularity may have occurred and remained undetected. We nevertheless endeavour to plan our internal audit work so that we have reasonable expectation of detecting material fraud, but our examination should not be relied upon to disclose all such material frauds that may exist. 31

34 APPENDIX B: ISOLATED EXCEPTIONS TO EXPECTED PROCEDURES AND CONTROLS ITEM ISOLATED EXCEPTION RESPONSIBLE OFFICER AGREED Y/N DATE OF DISCUSSION 32

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