Cymdeithas Tai Cantref Cyf Final Internal Audit Report Business Planning & Budgetary Control 2012/13 Date of fieldwork: October November 2012 Date of draft report: November 2012 Date of final report: November 2012 This report and the work connected therewith are subject to the Terms and Conditions of the letter of engagement dated 20 March 2009 between Cymdeithas Tai Cantref Cyf and Deloitte & Touche Public Sector Internal Audit Limited. The report is produced solely for the use of Cymdeithas Tai Cantref Cyf. Its contents should not be quoted or referred to in whole or in part without our prior written consent except as required by law. Deloitte & Touche Public Sector Internal Audit Limited will accept no responsibility to any third party, as the report has not been prepared, and is not intended for any other purpose. This report has been prepared on the basis of the limitations set out on page 14.
Contents Executive Summary 1 Section 1 Observations and Recommendations 7 Appendix A Follow-up of 2010/11 Recommendations 8 Appendix B Audit Framework 12 Appendix C Staff Interviewed 13 Statement of Responsibility 14 Cymdeithas Tai Cantref Cyf Business Planning & Budgetary Control 2012/13
Executive Summary This report details the Internal Audit of the procedures and controls in place over Business Planning and Budgetary Control at Cymdeithas Tai Cantref Cyf (the Association). The Internal Audit has been undertaken in accordance with the 2012/13 Internal Audit Plan. Our audit approach and a summary of the work undertaken are provided in the Audit Framework in Appendix B. Background Cymdeithas Tai Cantref manages properties across four Local Authority areas in West Wales: Ceredigion, North Pembrokeshire, North Carmarthenshire and the Machynlleth area in Powys. The Association manages a budget of rental income standing at approximately 5.1m over the course of the year, covering its responsibilities to over 1300 households, with a net surplus of 185,587 (amended to 182,083 as per November reforecast). Budget responsibility is devolved to individual departmental heads, with main oversight being regular monthly meetings between the Finance department and budget holders. Cantref s large capital base and revenue stream makes the budget setting and monitoring processes critical for effective management of cash and liquid assets and therefore a central part of the Association s operations. Audit Opinion Substantial While there is a basically sound system there are weaknesses which put some of the control objectives at risk and/or there is evidence that the level of non-compliance with some of the controls may put some of the systems objectives at risk. Cymdeithas Tai Cantref Cyf Business Planning & Budgetary Control 2012/13 1
Summary of findings Our key findings are detailed in the paragraphs below. Financial Management Framework Cantref has Financial Regulations in place which were last approved by the Board in January 2012. We confirmed they include a section on the business planning and budgetary control process and noted coverage on the following points: The responsibility for drawing together the annual budget; The requirement for the budget to agree to the annual Business Plan; The budget is to be agreed by Board no later than February each year; The requirement to produce a rolling 12 month forecast to the Board each quarter; The requirement for the Director of Finance to provide monthly reports to SMT and at least quarterly updates to the Board; and The requirement for the Director of Finance to provide each budget holder with a monthly report. The Association has a business plan in place which sets out Cantref's values as well as future plans and a strategic vision. The plan is high level, covers a five year period and includes a budget, income and expenditure predictions and cashflow. The Association s approach is to keep all staff aware of the business plan to create a buy to the Association s vision. This year the Board asked the Director of Finance to take a different approach to the budget setting process and zero-basing budgets. In previous years the budget has been rolled forward, based on a set percentage increase. We confirmed the zerobasing approach, and have made further reference to this later in the report. We identified that at present there are no budgetary control procedures in place to support the Financial Regulations and provide more detailed guidance to staff. However, given the size of the organisation this was deemed appropriate. It was also noted through discussions with the Director or Finance that at the next review of the Financial Regulations additional information on the business planning cycle is to be added to further strengthen the process and guidance available to staff. Cymdeithas Tai Cantref Cyf Business Planning & Budgetary Control 2012/13 2
Budget setting process The budget setting process is primarily driven through two levels of management. Firstly, the Executive Directors and other Board members define the strategic direction for the Association over the next five years, and determine those objectives which should be met within the coming year. This information is then passed to middle management such as department heads who are responsible for implementing the objectives. We obtained the five-year Business Plan setting out the Association s broader strategic aims. Testing confirmed that a detailed calculation had been undertaken to calculate the budget in two major areas of expenditure covering Payroll and Property Services (planned maintenance). In calculating the payroll budget the Director of Finance assumed that salary bands would be increased with promotions (where the individual was employed on lower than point 4 scale) as automatic promotions, and assumed a 2% pay increase would be effected. Combined with pre-existing information concerning which individuals exist within the pension scheme, and estimating which members of staff are likely to enrol on the pension scheme as it currently exists (defined benefit) before auto-enrolment comes in and defined contribution is offered, has allowed the Director of Finance to forecast payroll costs for the financial year. We noted that the 2% pay increase was planned to take effect from April 2012. It was approved by the Board in May 2012 and following agreement with staff unions the rise will be paid in November and backdated when it comes into effect; consequently, the model is expected to remain accurate at year end. The Financial Regulations state under paragraph 2.4 that "The budget is to be considered and approved by the Board no later than February each year". However, testing identified the budget for 2012/13 was approved in March. This was discussed with management who informed that this discrepancy occurred due to a change in the regularity with which the Board meet and the Regulations will be updated at their next review in December 2012. As a result no recommendation has been raised. With the introduction of component accounting, the Association s lenders have requested within the last year that capitalised repairs are deducted when calculating interest cover. The budget was established to provide adequate cover for interest covenants with the target set at 110%. At the time of the audit in November 2012, using September financial information the cover is currently 118%. Discussions with the Director of Finance confirmed the target has been achieved by making minor amendments to the Association s budget. We confirmed a paper has been prepared for the November Board meeting to facilitate discussion around this issue and the changes made. Cymdeithas Tai Cantref Cyf Business Planning & Budgetary Control 2012/13 3
During the budget setting process the Director of Finance meets with each responsible department manager to discuss their budget and the resources required to meet specific objectives. The Director of Finance is able to inform the department head whether the Association can afford the budget required. These meetings occur in January where the results for December are analysed. The budget is also compared to actual in year expenditure and an expectation is created of levels of spend so that budgets can be set. Budget allocations are calculated by departments based on their needs and discussed with the Director of Finance. We confirmed that the Director of Finance is then involved in making the underlying calculations to determine whether they have been made on an appropriate basis. Where the Association cannot meet the budget required to achieve objectives from the business plan priorities are determined by the Senior Management Team. Annual business planning cycle A number of steps are taken to plan the budget. Testing confirmed the following steps were completed for financial year 2012/13: The Board held an away day, where business plans for the coming year was defined based on known legislative changes and agreed business priorities for the Association. Following this a draft budget was produced from this; The draft budget was sent to relevant managers for review and comments; The Board met in January to discuss any comments and any amendments required; Further comments were collected and collated by members of Finance, and any amendments made to budget as required; and The Board had a final review and approved the budget at the meeting in March. We confirmed that, at the time of audit, the next away day was scheduled for the 13 th November 2012 to begin the budget setting process for financial year 2013/14. Cymdeithas Tai Cantref Cyf Business Planning & Budgetary Control 2012/13 4
Business Planning Assumptions Service Income levels are known to the Association in advance, since they are charged to tenants for shared services. Cantref management stated that the Association s houses are in high demand and therefore the rent and void levels could be assumed with some degree of accuracy. The Association has assumed a 1.5% void rate within its budget, split into 1% voids and 0.5% bad debt. These figures would appear to be prudent in comparison with prior year figures. However, we would question whether the 0.5% bad debt figure was suitable, given the pending changes to the way Housing Benefit is paid. Discussions with management confirmed the Director of Housing and Community Services is currently undertaking a Welfare Reform Action Plan project to identify those individuals that may be affected by the legislative changes and are potentially willing to downsize their property to decrease their rent. In addition Cantref plan to work with those who are not willing or unable to downsize and assist them in managing their financial position where possible. We noted the Association is also running an incentive scheme to encourage Direct Debit mandates to be signed by residents. However, at present the potential quantitative impact of the change has been calculated and we understand that this is something that is being closely managed over the coming months as it could have a large impact on the organisation s financial position. For the 2012/13 financial year we confirmed that business planning assumptions were reported to the Board in a qualitative paper presented with the budget in March 2012. Virements, Variance Analysis & Budget Monitoring There have not been any virements within the year; however, we were informed that a paper was currently being prepared for the November Board to make minor amendments to the budget, the most significant of which involve increasing the budget for Reactive & Void maintenance. Testing confirmed that a virement facility is available within Sun Accounts and access is restricted to the Finance Manager. Virements must be input by the Finance Manager and reviewed by the Director of Finance. Budget reports are produced on a monthly basis and provided to budget holders for monitoring purposes. The reports state the budgetary variance against each budget code year to date. Where variances against budget occur and these are significant, they are investigated by the Director of Finance and a note included in the management accounts to state the reason. However, we identified that no significant variances had been identified year to date. Cymdeithas Tai Cantref Cyf Business Planning & Budgetary Control 2012/13 5
Management Information Monthly outturn reports are presented to the Board. These are compiled by the Director of Finance and state the budgetary performance to date as well as any variances. A three year rolling cashflow forecast is also produced for the Board on a monthly basis. In addition, budget reports are taken to Senior Management Team meetings but these meetings are not minuted (although action points are recorded where necessary). The Finance department prepare budget statements for budget holders on a monthly basis, which are distributed by hand. Testing confirmed the existence of these reports and the method of production using the Vision system. We confirmed that a performance management meeting is held on the second Tuesday of every month; management accounts information is compiled for this meeting and a draft Income and Expenditure Statement is distributed to all managers in attendance. Acknowledgment We would like to thank the management and staff involved in the audit work for their assistance. Cymdeithas Tai Cantref Cyf Business Planning & Budgetary Control 2012/13 6
Section 1 Observations and Recommendations In order to assist management in using our reports: a) We categorise our audit opinion according to our assessment of the controls in place and the level of compliance with these controls: Full Assurance Substantial Assurance Limited Assurance Nil Assurance There is a sound system of control designed to achieve the system objectives and the controls are being consistently applied. While there is a basically sound system, there are weaknesses which put some of the system objectives at risk, and / or there is evidence that the level of non-compliance with some of the controls may put some of the system objectives at risk. Weaknesses in the system of controls are such as to put the system objectives at risk, and/or the level of non-compliance puts the system objectives at risk. Control is generally weak, leaving the system open to significant error or abuse, and/or significant non-compliance with basic controls leaves the system open to error or abuse. b) We categorise our recommendations according to their level of priority. Priority 1 Major issues that we consider need to be brought to the attention of senior management and the audit committee. Priority 2 Important issues which should be addressed by management in their areas of responsibility. Priority 3 Detailed problems of a minor nature resolved on site through discussions with local management. Cymdeithas Tai Cantref Cyf Business Planning & Budgetary Control 2012/13 7
Appendix A Follow-up of 2010/11 Recommendations Recommendation Priority Management Response Deadline Responsibility Status Further Action Required 1.1 It is recommended that the Association consider: The need for periodic zero-based budget preparations; and In periods when incremental budgeting is used, inflation within budget calculations should be formally included using either the Retail Price Index (RPI) or Consumer Price Index (CPI) basis. 2 The nature of Housing Association business is such that, year on year, there is little variation in the activities. We can estimate the Income closely as rents are pre-determined and grants are notified in advance. We then have certain obligations to fulfil to ensure that the Grant Conditions are met, and these often involve staffing levels. The other staff levels follow the agreed organisation chart which is designed to deliver optimum customer service. The other main costs are WHQS, which follow the agreed plan, and day to day maintenance, which is very difficult to predict but often follows the pattern for the previous year. N/A N/A Implemented The Association has zero-based their budget for this financial year. None Cymdeithas Tai Cantref Cyf Business Planning & Budgetary Control 2012/13 8
Recommendation Priority Management Response Deadline Responsibility Status Further Action Required 1.2 The production of monthly budget forecasts by Heads of Section as set out within the Financial Regulations should be enforced. In addition, the year-end outturn across all budget codes should be forecast on a monthly basis and reported to Board. 1.3 Each line of the Association s budget should be examined and an expected spend profile prepared to enable the budget to be accurately profiled across the financial year. 2 Agreed. October 2011 2 The only areas where this is relevant is for maintenance and this is already done. Director of Finance Implemented The Director of Finance or Finance Manager meets with all Heads of Section on a monthly basis to discuss budget performance and pending expenditure. The Director of Finance produces an updated budget forecast every six months which was considered acceptable. N/A N/A Implemented We confirmed the current budget has been profiled according to expected expenditure patterns, where possible None None Cymdeithas Tai Cantref Cyf Business Planning & Budgetary Control 2012/13 9
Recommendation Priority Management Response Deadline Responsibility Status Further Action Required 1.4 It is recommended that a Sun report is run of all budget codes after the budget has been input to the system, to ensure that each budget code balances with that of the proposed budget. The report should be signed and stored to evidence that the process has been undertaken. 1.5 Assumptions underlying the budget should be fully and formally documented and brought to the attention of the Board. 3 Agreed. July 2011 Director of Finance 2 Agreed - subject to Board approval. March 2012 Director of Finance Implemented We confirmed the Finance Manager has reconciled the budget input to Sun with the calculated budget. Implemented We confirmed budgetary assumptions were formally reported to the Board when the budget was presented for ratification in March 2013. None None Cymdeithas Tai Cantref Cyf Business Planning & Budgetary Control 2012/13 10
Recommendation Priority Management Response Deadline Responsibility Status Further Action Required 1.6 Staff with responsibility for budgets should have their budgetary performance formally considered as part of their appraisals. This should consider both qualitative and quantitative criteria, so that quantitative, annual measures do not undermine the longerterm objectives of the Association. 3 Agreed. Septemb er 2011 Senior Management Team Implemented We obtained evidence to confirm that staff members now have targets set to achieve their budget. None Cymdeithas Tai Cantref Cyf Business Planning & Budgetary Control 2012/13 11
Appendix B Audit Framework Audit Objectives The audit was designed to ensure that management have implemented adequate and effective controls over Business Planning and Budgetary Control at Cantref Housing Association. Audit Approach and Methodology The audit approach was developed with reference to the Quality Plan and by an assessment of risks and management controls operating within each area of the scope. The following procedures were adopted:- identification of the role and objectives of each area; identification of risks within the systems, and controls in existence to allow the control objectives to be achieved; and testing of controls within the systems. From these procedures we have identified weaknesses in the systems of control, produced specific proposals to improve the control environment and have drawn an overall conclusion on the design and operation of the system. Areas Covered Audit work was undertaken to cover the following areas and control objectives: There is a robust and accurate Financial Management Framework in place; Detailed processes are in place and followed for the setting of budgets; The annual business planning cycle is in place and monitored regularly; All business planning assumptions made are accurate and supported by appropriate evidence; Appropriate Budgetary controls processes are in place over virements and variance analysis, and that this information is reported regularly to budget holders; and The Association has suitable daily, weekly and monthly reporting arrangements to management, Directors and the Board or Sub Committees. Cymdeithas Tai Cantref Cyf Business Planning & Budgetary Control 2012/13 12
Appendix C Staff Interviewed Julie Jones Director of Finance Gwenan Phillips Head of Finance An exit meeting was held with the Director of Finance on 13 November 2012. Cymdeithas Tai Cantref Cyf Business Planning & Budgetary Control 2012/13 13
Statement of Responsibility We take responsibility for this report which is prepared on the basis of the limitations set out below. The matters raised in this report are only those which came to our attention during the course of our internal audit work and are not necessarily a comprehensive statement of all the weaknesses that exist or all improvements that might be made. Recommendations for improvements should be assessed by you for their full impact before they are implemented. The performance of internal audit work is not and should not be taken as a substitute for management s responsibilities for the application of sound management practices. We emphasise that the responsibility for a sound system of internal controls and the prevention and detection of fraud and other irregularities rests with management and work performed by internal audit should not be relied upon to identify all strengths and weaknesses in internal controls, nor relied upon to identify all circumstances of fraud or irregularity. Auditors, in conducting their work, are required to have regards to the possibility of fraud or irregularities. Even sound systems of internal control can only provide reasonable and not absolute assurance and may not be proof against collusive fraud. Internal audit procedures are designed to focus on areas as identified by management as being of greatest risk and significance and as such we rely on management to provide us full access to their accounting records and transactions for the purposes of our audit work and to ensure the authenticity of these documents. Effective and timely implementation of our recommendations by management is important for the maintenance of a reliable internal control system. The assurance level awarded in our internal audit report is not comparable with the International Standard on Assurance Engagements (ISAE 3000) issued by the International Audit and Assurance Standards Board. Deloitte & Touche Public Sector Internal Audit Limited South West November 2012 In this document references to Deloitte are references to Deloitte & Touche Public Sector Internal Audit Limited. Registered office: Hill House, 1 Little New Street, London EC4A 3TR, United Kingdom. Registered in England and Wales No 4585162. Deloitte & Touche Public Sector Internal Audit Limited is a subsidiary of Deloitte LLP, the United Kingdom member firm of Deloitte Touche Tohmatsu Limited ( DTTL ), a UK private company limited by guarantee, whose member firms are legally separate and independent entities. Please see www.deloitte.co.uk/about for a detailed description of the legal structure of DTTL and its member firms. Member of Deloitte Touche Tohmatsu Limited Cymdeithas Tai Cantref Cyf Business Planning & Budgetary Control 2012/13 14