Comhairle nan Eilean Siar Internal Audit Review School Transport Policy Final Report 15/16-22

Transcription

1 Comhairle nan Eilean Siar Internal Audit Review School Transport Policy Final Report 15/ rd June rd June 2015

2 CONTENTS Page SECTION 1 - EXECUTIVE SUMMARY 1-6 SECTION 2 - DETAILED FINDINGS AND RECOMMENDATIONS 7-21 SECTION 3 - ACTION PLAN APPENDIX A - RESPECTIVE RESPONSIBILITIES OF MANAGEMENT 25 AND INTERNAL AUDIT APPENDIX B - ISOLATED EXCEPTIONS TO EXPECTED PROCEDURES 26 Date of Visit April/May 2015 Draft Report Issued 12 th May 2015 Management Response Received 2 nd June rd June 2015 Final Report Issued 3 rd June 2015 Issued to: Chief Executive Director of Finance & Corporate Resources Director of Technical Services Director of Education & Children s Services Principal Officer Education Resources Transport Co-ordination Officer Senior Administration Assistant External Audit Malcolm Burr Robert Emmott Iain Mackinnon Bernard Chisholm I G Smith David Smart Catriona Maciver Karen Jones 3 rd June 2015

3 SECTION 1: EXECUTIVE SUMMARY Introduction 1.1 This report has been prepared following an internal audit review of the School Transport Policy and as part of the operational annual internal audit plan for 2015/16. The purpose of this report is to provide an overview of the Comhairle s arrangements for the operation and management of the policy and in terms of the objectives noted below. 1.2 Background information Under the terms of the Education (Scotland) Act 1980, the Comhairle has a statutory responsibility to assist with the provision of transport, when certain criteria are met. The School Transport Policy sets out the circumstances under which school transport will be provided. Free school transport is awarded from the pick-up point for onward transportation: to primary pupils who live more than 2 miles from their catchment school by the shortest walking routes, and secondary pupils who live more than 3 miles from their catchment school by the shortest walking route. Entitlement to free school transport may also depend on medical conditions, additional supported needs or if the route to school is deemed to be unsafe for walking. Approximately 1695 pupils receive free home to school transport annually. The budget (2015/16) for mainstream and ASN transport provision is 3.3m. It is, therefore, of importance that there are robust procedures in place to verify the correct entitlement and to account for the income provided by the non-entitled children who also use the home to school transport. Internal audit objective 1.3 In accordance with the remit outlined within the operational annual internal audit plan for 2015/16 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 School Transport Policy and associated processes 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; Pupils requiring school transport have been allocated correctly and in compliance with the School Transport Policy (STP); Rejected transport applications have been fairly processed and in compliance with the School Transport Policy; 3 rd June

4 SECTION 1: EXECUTIVE SUMMARY (CONTINUED) The School Transport Policy is adhered to for the granting and withdrawal of concessionary places; There is a robust complaints procedure and appeals mechanism that is made readily available; A written service level agreement is in place between Education & Children s Services and the transport provider; Risk assessments are undertaken for staff involved in the Additional Supported Needs (ASN) educational transport; and Where mileage allowances are claimed appropriate checks are made to confirm pupil attendances. Documentation used School Transport Policy revised February 2011 by former Director of Education & Children s Services. Application Forms, Risk Assessments and Committee reports. Areas of Good Practice 1.4 Commitment of staff within the Education Administration section in contributing to providing a good service. Knowledge and experience of staff within the Transport section. Concluding remarks 1.5 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: Tickets are not always being collected by bus staff which may result in financial loss to the authority; Passes are not always being checked by bus staff which may result in financial loss to the authority; Some parents are faithfully abiding by the principles of the policy whilst in contrast other parents may not be, resulting in ineligible free transport; and A number of recommendations mainly identified in an investigation concerning passes/tickets in May 2014 which were accepted by management remain outstanding. We will be revisiting this area in August/September 2015 after the pupils have resumed the first term and establish how the ticketing system is being monitored and if there are any reported improvements and practices we can bring back to Management and the Committee. 3 rd June

5 SECTION 1: EXECUTIVE SUMMARY (CONTINUED) 1.6 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. 3 rd June

6 SECTION 1: EXECUTIVE SUMMARY (CONTINUED) 1.7 Our recommendations can be summarised and prioritised as follows: Recommendation 2.1 The School Transport Policy must be updated to reflect departmental responsibility for monitoring of the policy, retention of records and direction for those enforcing the policy. Overall grading Technical Services Bus Management staff must instruct all relevant staff to receive a pass or ticket for inspection in order to use the service. A penalty or a reduction in the subsidy equating to the estimated value of the concessionary tickets be applied to the private contractors for new contracts. The Principal Officer- Education Resources gives assurance that there is contingency in place to allow timely completion of the bus passes being in place for all pupils prior to the start of the new school term. The Director of Technical Services and the Director of Education & Children s Services satisfy themselves to the ability and readiness of the new SEEMIS system, together with the need to fully test the system before implementation. 3 rd June

7 SECTION 1: EXECUTIVE SUMMARY (CONTINUED) Recommendation 2.2 A Service Level Agreement should be developed between the Education & Children s Services department and the Transport section prior to the start of the academic year 2015/16. This agreement should define service standards, budgetary arrangements, procurement requirements and a monitoring requirement. Overall grading A formal agreement should be developed between the Education and Children s Services department and the external provider prior to the start of the academic year 2015/16. This agreement should define service standards, budgetary arrangements, procurement requirements and any other legal requirement. The Education and Children s School Transport section consult with the Procurement section to secure the most economical prices for the taxi service required for transporting additional needs pupils from home to school. The operation of the home to school bus passes/tickets should be monitored regularly. Service providers must be informed that procedures must be adhered to at all times. The Principal Officer - Education Resources in conjunction with the Comhairle Legal section draws up a parental agreement for parents who use their own transport for home to school journeys. 3 rd June

8 2.3 The Principal Officer- Education Resources to agree and design a standard form that specifies the claim period for mileage expenses. Claims for mileage expenses should be submitted on a monthly frequency, or within a reasonable timescale. All expenses claims must be supported by an attendance sheet that is signed off by the Head Teacher. All invoices submitted by external providers must have the correct mileage allowances applied, correct calculations and supported by signed attendance sheets prior to being processed for payment. 2.4 The Director of Education & Children Services confirms that the services provided are demonstrating VFM. 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 3 rd June rd June

9 SECTION 2 - DETAILED FINDINGS AND RECOMMENDATIONS Control Objective 2: Pupils requiring school transport have been allocated correctly and in compliance with the School Transport Policy (STP). 2.1 The School Transport Policy was drawn up in Although the policy does contain the standards which are to be achieved, there are areas that are not covered in the policy such as who has the responsibility for monitoring the scheme, retention of records, scenarios where the child does not have a fare/ticket/pass on consecutive days etc. The standard qualifying criteria for free school transport is awarded to primary school pupils who reside outwith the two mile catchment area and three miles for secondary school pupils. Where free home to school transport is not provided, pupils may take advantage of spare capacity which exists on school only and integrated scheduled bus services but will be required to buy bus passes from the Comhairle. These will be colour coded and vary in price dependant on the number required. L H The School Transport Policy must be updated to reflect departmental responsibility for monitoring of the policy, retention of records and direction for those enforcing the policy. 2 Transport policy needs to be reviewed and updated Guidelines covering procedures and appropriate sanctions for pupils who do not have a valid pass. The Home to School Transport policy will be updated to take account of the new processes required to fully implement the SEEMIS transport module. It is also proposed to request Comhairle permission to introduce a School Transport code of conduct similar to the model presented by East Lothian Council to a meeting of school transport managers arranged by Transport Scotland in Inverness. 3 rd June

10 SECTION 2 - DETAILED FINDINGS AND RECOMMENDATIONS (CONTINUED) 2.1 Control Objective 2: Pupils requiring school transport have been allocated correctly and in compliance with the School Transport Policy (STP). Data shows that there are 1695 pupils entitled to free places in their respective catchment areas and 1742 pupils who are deemed as ineligible for the free transport as defined by the qualifying criteria. (This information has been extracted from Transportation data). We sampled a number of school transport applications from data provided by the schools records for entitlement and nonentitlement following the criteria set in the policy and recording our findings in relation to this matter. All pupils are carefully categorised as to their status to qualify or not for free school transport and for those who are required to purchase passes or tickets for their journey to school all in accordance with the current eligibility criteria within the Home to School Travel Policy 3 rd June

11 SECTION 2 - DETAILED FINDINGS AND RECOMMENDATIONS (CONTINUED) Control Objective 2: Pupils requiring school transport have been allocated correctly and in compliance with the School Transport Policy (STP). 2.1 Parents whose children are entitled to free home to school transport complete an application form after checks have been made to confirm entitlement by submission of evidence such as benefits information. However, if a school is chosen outwith the catchment area there is a loss of entitlement to free transportation. Our review of this process was satisfactory. Pupils who live within two/three miles of their catchment school or are in a placement in other schools are not entitled to free home to school transport. We sampled 29 applications for completeness of forms, direct debit attachments, totals due against direct debit instalments and mileage from home to school. Our review of this process was satisfactory. 3 rd June

12 SECTION 2 - DETAILED FINDINGS AND RECOMMENDATIONS (CONTINUED) Control Objective 2: Pupils requiring school transport have been allocated correctly and in compliance with the School Transport Policy (STP). 2.1 Parents can purchase tickets on a daily, weekly or monthly basis. Where parents purchase a weekly ticket, for example, consisting of 5 return journeys, this would normally cover one week. We would have expected to find purchases repeated throughout the academic year suggesting that a seat was purchased on the bus for that individual pupil. From our sampling we identified that there are pupils ineligible for free transport who are not purchasing passes which may suggest that free trips on the school buses are occurring and remaining undetected. We have also had discussions with parents and officers of the Comhairle and the general consensus is that non-eligible children are getting free transport on the buses. We understand that a pilot was undertaken with the Transport section at the start of the school year when the bus passes/tickets were issued and we are advised that enforcement was very difficult. Examples given: A child turning up at the school bus stop daily, with no money or ticket/pass; could the child be left at the road side? 3 rd June

13 2.1 SECTION 2 - DETAILED FINDINGS AND RECOMMENDATIONS (CONTINUED) Control Objective 2: Pupils requiring school transport have been allocated correctly and in compliance with the School Transport Policy (STP). We understand that there is little or no monitoring in place by the bus drivers or Transport/Education staff on the school transport routes and also by the private contractors. This in effect will result in the Comhairle losing income. In the case of the private contractors not adhering to the scheme a penalty should be applied where this practice is continuing. We do understand that fee paying children may also be using other means of transport rather that the school bus and this would be difficult to reconcile and monitor. We are unable to determine the actual number of children that are not entitled to free transport from home to school. Income from ticket sales Budget Income 12/ ,223 13/ ,813 14/ ,540 15/ rd June H L H H Technical Services Transport Management must instruct all relevant staff to receive a pass or ticket for inspection in order to use the service. A penalty or a reduction in the subsidy equating to the estimated value of the concessionary tickets be applied to the private contractors for new contracts. 1 2 Bus operators and their drivers are informed in writing regarding the policy and advice / guidelines regarding the requirements for bus drivers to check pupils travel passes or tickets. The transport section staff carry out monitoring checks supported by Head Teachers at the start of the new school year. Posters and pupil notices are placed on all buses and within the school on pupil notice boards. Existing bus contract conditions do not include subsidy reduction penalties. This could be considered for future contracts. Some form of recourse must be available to bus drivers for pupils who refuse to show passes.

14 2.1 SECTION 2 - DETAILED FINDINGS AND RECOMMENDATIONS (CONTINUED) Control Objective 2: Pupils requiring school transport have been allocated correctly and in compliance with the School Transport Policy (STP). Historically, application forms have been sent out prior to the school year starting in August with tickets/passes being available for the new school term. We identified that passes were not activated until September for the academic year 2014/15, resulting in children not having appropriate passes and some payments not taking effect until October We understand that for the academic year 2015/16 applications will be processed in June 2015 as a new transport system SEEMIS is due to be implemented. The progress of the implementation of the system is being reported to committee on a regular basis. An from the former Director of Education to the Technical Services management pledges that there will be extra resource put in place for the rollout of the passes/tickets scheme in June We also wish to highlight that there was an issue with the school bus ticketing system in May 2014 and as a result a report was produced highlighting issues that were to be actioned. See below: 3 rd June L H H H The Principal Officer- Education Resources gives assurance that there is contingency in place to allow timely completion of the bus passes being in place for all pupils prior to the start of the new school term. The Director of Technical Services and the Director of Education & Children s Services satisfy themselves to the ability and readiness of the new SEEMIS system, together with the need to fully test the system before implementation. 2 1 Progress with implementation has led to a situation where a contingency is now in place. The new SEEMIS transport module will be fully operational by the end of June. Testing will be undertaken during final setup.

15 SECTION 2 - DETAILED FINDINGS AND RECOMMENDATIONS (CONTINUED) 2.1 Control Objective 2: Pupils requiring school transport have been allocated correctly and in compliance with the School Transport Policy (STP). An investigation was undertaken by Internal Audit in May 2014 as a result of concerns regarding the management of passes and tickets on the school transport services. Extract from the report. Three officers were interviewed and were aware of the issues surrounding the school transport bus passes/tickets. Although the exact scale of the problems were difficult to ascertain it would appear that a mixture of three issues noted below have arisen, specifically, The effectiveness of any enforcement measures is fundamentally flawed as there are no approved sanctions that are available to bus drivers or indeed the Head / Senior Teachers that can be imposed on pupils from home to school bus travel from either occasional or persistent noncompliance. Pupils having tickets and not been taken by bus drivers; Pupils having passes and not checked by drivers; and Pupils not having either a ticket or pass and allowed to use the buses free. Continued. 3 rd June

16 SECTION 2 - DETAILED FINDINGS AND RECOMMENDATIONS (CONTINUED) 2.1 Control Objective 2: Pupils requiring school transport have been allocated correctly and in compliance with the School Transport Policy (STP). This appears to have created some discord with parents who are paying for the service and others who are not, together with pupils not been appropriately challenged when the service is being accessed by the pupil. This may result in the fall of purchases of passes or tickets due to a lack of monitoring or enforcement It would appear that the issues are still ongoing and have not been dealt with as outlined in our recommendations. At present the policy and the procedures as well as appropriate staff resources are unable to enforce the bus pass issue effectively enough and that a revised protocol and collaborative approach between the relevant Comhairle departmental sections and all Head Teachers may be required to improve the pupil pass / ticket presentation on boarding the bus. All parents need to be advised that checks will be carried out periodically and appropriate measures taken if pupils continue to travel without a valid pass or ticket. Fundamentally this represents overcoming a change in culture. 3 rd June

17 SECTION 2 - DETAILED FINDINGS AND RECOMMENDATIONS (CONTINUED) 2.2 Objective 6: A written service level agreement is in place between Education & Children s Services and the transport provider. The management for Additional Supported Needs (ASN) school transport was with Technical Services until August 2014 when it transferred to Education & Children s Services. Education & Children s Services do not have a new contract in place with any of the external taxi providers (or with Technical Services). The present bus contracts will remain in place until April We understand that there is no formal agreements in place with external taxi providers who transport pupils with additional support needs to their place of learning. A historic agreement was in place when the service was managed by Technical Services but this was not renewed in August 2014 when the service was transferred to Education & Children s Services. We are advised by the Transport Adviser that the most economical tenders would have been accepted but no written agreement is in place with the provider. L L H H A Service Level Agreement should be developed between the Comhairle s Education & Children s Services department and the Transport section prior to the start of the academic year 2015/16. This agreement should define service standards, budgetary arrangements, procurement requirements and a monitoring requirement A formal agreement should be developed between the Education and Children s Services department and the external provider prior to the start of the academic year 2015/16. This agreement should define service standards, budgetary arrangements, procurement requirements and any other legal requirement. 2 2 A service level agreement will be drawn up based on the new administrative and planning tasks related to the SEEMIS transport module by August This will be defined by the legal section and included in the specification of the framework taxi contract. 3 rd June

18 SECTION 2 - DETAILED FINDINGS AND RECOMMENDATIONS (CONTINUED) 2.2 Control Objective 6 : A written service level agreement is in place between Education & Children s Services and the transport provider. We understand the Education section are in H V The Education and Children s 4 Framework contract for taxi the process of consultation with School Transport section consult services is currently being Procurement and Technical Services for with the Procurement section to developed by the Procurement coverage for the new term 2015/16 for secure the most economical Section pupils with assisted supported needs and prices for the taxi service other pupils where no bus service is required for transporting available. This would demonstrate that the additional needs pupils from most economical price is obtained by the home to school. Comhairle. Whilst the Education Department is responsible for ensuring that all children who qualify for school transport are provided with this facility, Technical Services is responsible for arranging and monitoring the contracts with the providers of these services. Contracts normally run for five years and current contracts are effective for financial years 2014/15 to 2018/19. The requirement that bus passes/tickets are monitored, should be continued in the new contracts going forward. L H The operation of the home to school bus passes/tickets should be monitored regularly. Service providers must be informed that procedures must be adhered to at all times. 2 A new approach to monitoring can start as soon as the agreed sanctions and protocol is in place and that parents and Head Teachers have been advised of the potential effect of these sanctions on the pupil without a ticket or pass being able to use school buses. 3 rd June

19 SECTION 2 - DETAILED FINDINGS AND RECOMMENDATIONS (CONTINUED) 2.2 Control Objective 6: A written service level agreement is in place between Education & Children s Services and the transport provider. Sometimes it is not appropriate or safe to allow (ASN) children to travel on school transport. Parents of these children may enter into an agreement with the Comhairle to provide home to school transport using their own vehicles. This could also apply to parents of children who live off the main bus pickup routes who would require transport to the bus pick-up point. We were provided with the parental arrangement agreements, where available. We would have expected that any form of agreement would have been established using advice from the Comhairle Legal section. We note that the letters have no consistency in the content and this could lead to terms being misinterpreted, or misunderstood. L H The Principal Officer, Education Resources in conjunction with the Comhairle Legal section draws up a parental agreement for parents who use their own transport for home to school journeys. 2 The Department will revise the format of the letter issued to parents with legal section and re-design as an agreement 3 rd June

20 SECTION 2 - DETAILED FINDINGS AND RECOMMENDATIONS (CONTINUED) 2.3 Control Objective 8:Where mileage allowances are claimed appropriate checks are made to confirm corresponding pupil attendances and that an authorised signatory has verified the claim. Parents who use their own transport are H L The Principal Officer, Education 3 The form will be re-designed to able to claim back mileage expenses. Resources to agree and design a include period of claim, We identified some housekeeping issues standard form that specifies the distance from home to school from our testing. claim period for mileage and number of trips per day We found inconsistency in the expenses. claimed. design of claim forms in circulation with differing criteria for the frequency of claiming expenses. We identified that has been under-claimed by a parent, which had been signed off as correct. The Head of Service confirms the 124 as identified in our testing as under claimed and makes arrangements to repay. The amount will be reimbursed to the parent and an apology issued. A claim for three years mileage expenses was received in Jan There is a lack of supporting attendance sheets to allow checking of actual attendance against claim. Head Teachers not signing off pupil attendance sheets. Claims for mileage expenses should be submitted on a monthly frequency, or within a reasonable timescale. All expense claims must be supported by an attendance sheet that is signed off by the Head Teacher. Monthly claim periods will now be standard. SEEMIS is used by Resources Section staff to check attendance. Printouts will now be attached for audit purposes. 3 rd June

21 SECTION 2 - DETAILED FINDINGS AND RECOMMENDATIONS (CONTINUED) 2.3 Control Objective 8: Where mileage allowances are claimed appropriate checks are made to confirm corresponding pupil attendances and that an authorised signatory has verified the claim. Taxis are also deployed in taking children from home to school. The majority of these children using this service are those with supported needs. In each case it is deemed not appropriate to use service buses and in discussion with staff from Education this is considered the most cost effective means of delivering the service. Payments to Taxi Providers Actual Budget 2015/16 13,903 67, /15 106, , /14 183, , /13 192, , /12 158, , /11 254, ,840 Historical arrangements are in place between the Taxi Operator and the Comhairle but we are informed that a tendering process will be undertaken before the start of the new school term in August 2015/16. The framework contract will determine the required content of invoices from taxi companies. SEEMIS is used by Resources Section staff to check attendance. Printouts will now be attached to invoices for audit purposes. 3 rd June

22 SECTION 2 - DETAILED FINDINGS AND RECOMMENDATIONS (CONTINUED) 2.3 Control Objective 8: Where mileage allowances are claimed appropriate checks are made to confirm corresponding pupil attendances and that an authorised signatory has verified the claim. From our sample of invoices submitted by the taxi providers we can confirm that a number of varying types of errors were identified and brought to the attention of staff. These include: Wrong number of runs calculated on some invoices Items on invoices erased, changed and not counter-signed Invoices missing from files A high number of attendance sheets missing No narrative on invoices. H L All invoices submitted by external providers must have the correct mileage allowances applied, correct calculations and supported by signed attendance sheets prior to being processed for payment. 3 The framework contract will determine the required content of invoices from taxi companies. SEEMIS is used by Resources Section staff to check attendance. Printouts will now be attached to invoices for audit purposes. 3 rd June

23 SECTION 2 - DETAILED FINDINGS AND RECOMMENDATIONS (CONTINUED) 2.4 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 report was provided to the Comhairle in December 2010 informing of the savings that could be secured if the Comhairle adopted the statutory distances for travel from home to school. It was anticipated that moving from the 1 mile rule to the 2 mile rule for primary school children would result in savings of approximately 70K. It is difficult to ascertain if there have been any savings identified from the scheme to date. However, there are areas of the service where we are advised that savings have been realised. The taxi service used for transporting ASN pupils are providing the Comhairle with value for money as a dedicated bus for this service would not be sustainable. H V The Director of Education & Children Services confirms that the services provided are demonstrating VFM. 4 Value for money is achieved in almost each area. With the introduction of the updated Home to School Travel policy, three school bus services were discontinued for Nicolson Institute pupils in the Newmarket/Newvalley area resulting in savings and with the redesigned Laxdale Primary school an overall net saving achieved. However, there are weaknesses in the processes of ensuring that all non-entitled children using the school buses are purchasing tickets. This is mostly prevalent in the Broadbay area of Stornoway where the system currently operated will be under review in the months following return to school. 3 rd June

24 SECTION 3 - ACTION PLAN Ref. RECOMMENDATION RESPONSIBLE OFFICER 2.1 The School Transport Policy must be updated Iain G Smith to reflect departmental responsibility for Principal Officermonitoring of the policy, retention of records Education and direction for those enforcing the policy. Resources DATE OF IMPLEMENTATION October 2015 Technical Services Transport Management must instruct all relevant staff to receive a pass or ticket for inspection in order to use the service. A penalty or a reduction in the subsidy equating to the estimated value of the concessionary tickets be applied to the private contractors for new contracts. David Smart Transport Manager David Smart Transport Manager 13 August From the start of any new school bus contracts The Director of Education & Children s Services gives assurance that there is contingency in place to allow timely completion of the bus passes being in place for all pupils prior to the start of the new school term. Bernard Chisholm Director of Education & Children s Services Completed. The Director of Technical Services and the Director of Education & Children s Services satisfy themselves to the ability and readiness of the new SEEMIS system, together with the need to fully test the system before implementation. Iain Mackinnon/Bernard Chisholm Directors July

25 SECTION 3 - ACTION PLAN (CONTINUED) Ref. RECOMMENDATION RESPONSIBLE OFFICER 2.2 A Service Level Agreement should be Iain G Smith developed between the Education and Principal Officer- Children s Services department and the external Education provider prior to the start of the academic year Resources 2015/16. This agreement should define service standards, budgetary arrangements, procurement requirements and any other legal requirement. DATE OF IMPLEMENTATION August 2015 A formal agreement should be developed between the Education and Children s Services department and the external provider prior to the start of the academic year 2015/16. This agreement should define service standards, budgetary arrangements, procurement requirements and any other legal requirement. The Education and Children s School Transport section consult with the Procurement section to secure the most economical costs for the taxi service required for transporting pupils from home to school. The operation of the home to school bus passes/tickets should be monitored regularly. Service providers must be informed that procedures must be adhered to at all times. Iain Cockburn Procurement Manager Iain Cockburn Procurement Manager David Smart Transport Manager October 2015 August 2015 From 13 August 2015 The Principal Officer, Education & Resources, in conjunction with the Legal section draws up a parental agreement for parents using their own transport for home to school journeys. Iain Cockburn Procurement Manager October

26 SECTION 3 - ACTION PLAN (CONTINUED) Ref. RECOMMENDATION RESPONSIBLE OFFICER 2.3 The Director of Education & Children s Iain G Smith Services to agree and design a standard form Principal Officerthat specifies the claim period for mileage Education expenses. Resources DATE OF IMPLEMENTATION August 2015 Claims for mileage expenses must be submitted on a monthly frequency or within a reasonable timescale. All expense claims must be supported by an attendance sheet that is signed off by the Head Teacher. Iain G Smith Principal Officer- Education Resources Iain G Smith Principal Officer- Education Resources August 2015 August 2015 All invoices submitted by external providers must have the correct mileage allowances applied, correct calculations and supported by signed attendance sheets prior to being processed for payment. Iain G Smith Principal Officer- Education Resources October The Director of Education & Children Services confirms that the services provided are demonstrating VFM. Bernard Chisholm Director of Education & Children s Services Ongoing. 24

27 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. 25

28 APPENDIX B: ISOLATED EXCEPTIONS TO EXPECTED PROCEDURES AND CONTROLS ITEM ISOLATED EXCEPTION RESPONSIBLE OFFICER None AGREED Y/N DATE OF DISCUSSION 26