AUDIT COMMITTEE REVIEW & AMENDMENT TO THE CURRENT RECOVERY OF PAYROLL OVERPAYMENTS POLICY

Transcription

1 1 AUDIT COMMITTEE REVIEW & AMENDMENT TO THE CURRENT RECOVERY OF PAYROLL OVERPAYMENTS POLICY Meeting Date: 20 th July 2017 Author: Sponsoring Executive Director: Report Presented by: Committee/Group who have received or considered this paper: Claire Bowden, Interim Deputy Director of Finance Mark Osland, Executive Director of Finance & Informatics Claire Bowden, Interim Deputy Director of Finance Trust Consultation Trust Resolution to: (please tick) Approve: Endorse: Discuss: Note: Recommendation: The Audit Committee is asked to approve the attached policy, noting the amendments outlined in this paper. This report supports the following Trust objectives as set out in the Integrated Medium Term Plan: (please tick) Equitable and timely services Providing evidence based care and research which is clinically effective Supporting our staff to excel Safe and reliable services First class patient /donor experience Spending every pound well This report supports the following Health & Care Standards: Governance Leadership and Accountability Page 1

2 2 1. Introduction / Background 1.1. The current Recovery of Payroll Overpayments policy requires review and amendment as appropriate A redrafted policy was issued in January 2017 with a small number of comments being received by the Interim Deputy Director of Finance The policy has been further redrafted to take account of those comments and is attached to this paper for review & approval by the Audit Committee. 2. Timing: 2.1. This policy is due for review. 3. Description: 3.1. This policy applies to all Trust staff, currently or previously employed, including Medical staff and those on Honorary Contracts. It also includes others who have or will receive a payment from the Employment Service provided by the NHS Wales Shared Services Partnership on behalf of Velindre NHS Trust A small number of comments / suggested amendments were received during the consultation process. These have been adopted where appropriate. The majority of comments were raised by the Financial Accountant with responsibility for the Trust s collection processes, and the Payroll Department In addition to the small changes suggested in the consultation process, the following have been made since and should therefore be noted by the Committee: An equality impact assessment has been undertaken and is referred to in section 8. A further example of a case and its outcome has been included in appendix Example letters from the payroll team are included to add clarity to the process of notification and recovery of any overpayments Where the process differs for current and ex employees this has been made clearer The process has been tightened to enable recovery where no response is received from an individual, eg if no response is received to the first letter sent to an employee, a second letter is sent stating that as no response was received within the timeframe, deductions from salary will then commence Ex employees now only receive one letter (rather than two) in addition to the invoice. They will be asked to make payment or the debt will be pursued in line with the Trust s debt recovery procedure. 4. Financial Impact: 4.1. There is no financial impact identified in the actual review of this policy It is hoped that the small amendments made to the policy will result in the recovery of payroll overpayments being clearer and more effective, leading to an increase in the amount of overpayments recovered and enabling them to be made in a shorter timeframe. Page 2

3 3 5. Quality, Equality, Safety and Patient Experience Impact: 5.1 The equality impact assessment undertaken in respect of this procedure found that there was no impact to the equality groups mentioned. 6. Considerations for Board / Committee: 6.1. Engagement on this policy has taken place during January / February 2017 via the formal Trust Consultation process. An Equality Impact Assessment took place in March The Audit Committee are asked to approve the attached policy, noting the amendments outlined in this paper. 7. Next Steps: 7.1. Once approved this policy will be published on the Trust intranet site and circulated to the policy distribution list. Page 3

4 Velindre NHS Trust Recovery of Payroll Overpayments Policy Policy Lead: Director of Finance & Informatics VELINDRE NHS TRUST REF: BLACK 58 Trust Policy THE RECOVERY OF PAYROLL OVERPAYMENTS POLICY Policy Lead: Director of Finance & Informatics Ref: Black 58 Issue Number: xxx Approved by: Trust Board Page 1 of 21 Effective Date: xxx

5 Velindre NHS Trust Recovery of Payroll Overpayments Policy Policy Lead: Director of Finance & Informatics EXECUTIVE SUMMARY The Recovery of Payroll Overpayments Policy Overview: The purpose of this policy is to ensure that all monies due to the Trust are recovered on a timely basis from the member of staff and/or ex-employees of the Trust. Who is the policy intended for: The policy will apply to all Trust staff, currently or previously employed, including Medical and those on Honorary Contracts. It also includes others who have or will receive a payment from the Employment Service provided by the NHS Wales Shared Services Partnership on behalf of Velindre Trust. Key Messages included within the policy: Policy Statement The principle purpose of the Trust s payroll systems and procedures is to ensure that employees are paid the correct amount at all times, however, on occasion this may not be the case. Incorrect payments could result in either an over or underpayment to an employee and it is the Trust s aim to deal with both in a timely and efficient manner. This policy is focused on those situations where overpayments have occurred. The Trust has a legal right to recover any overpayment where it arose from a mistake of fact. Whatever monies are to be recovered, the Trust will aim to do so in a fair and reasonable manner. These payments are made in good faith and are deemed to be correct at the time of issue. Mistakes of fact are where the payment was inconsistent with the facts (eg through clerical error, computer input, or procedural errors). Money paid out under a mistake of fact is recoverable by law. In accordance with this policy statement and Welsh Government guidance, the Trust must pursue the recovery of all amounts due to it as a result of an overpayment. The Trust must ensure that all Trust employees / ex-employees are treated fairly. All debts must be recorded by the Trust regardless of whether an agreement of repayment has been reached with the debtor. The Trust will ensure a consistent approach in line with the provisions of the policy is taken when dealing with recovery of an overpayment. PLEASE NOTE THIS IS ONLY A SUMMARY OF THE POLICY AND SHOULD BE READ IN CONJUNCTION WITH THE FULL POLICY DOCUMENT Ref: Black 58 Issue Number: xxx Approved by: Trust Board Page 2 of 21 Effective Date: xxx

6 Velindre NHS Trust Recovery of Payroll Overpayments Policy Policy Lead: Director of Finance & Informatics Contents 1. Introduction 4 2. Scope 5 3. Aims and Objectives 5 4. Roles and Responsibilities 5 5. Prevention 7 6. Recovery Procedure 7 7. Additional Requirements Equality 10 APPENDICES Appendix 1 11 Appendix 2 12 Appendix 3 13 Appendix 4 14 Appendix 5 15 Appendix 6 16 Appendix 7 18 Ref: Black 58 Issue Number: xxx Approved by: Trust Board Page 3 of 21 Effective Date: xxx

7 Velindre NHS Trust Recovery of Payroll Overpayments Policy Policy Lead: Director of Finance & Informatics THE RECOVERY OF PAYROLL OVERPAYMENTS POLICY 1. INTRODUCTION Velindre NHS Trust s overriding aim in paying its staff is to make payment promptly and accurately. However, there will be occasions where for various reasons this may not have been possible. This could result in both over and underpayments to staff. This policy relates solely to situations where members of staff have been overpaid. The Trust accepts that there may be occasions when a member of staff or exemployee will be in a situation where they owe the Trust money following an overpayment of salary and/or expenses. The purpose of this policy is to ensure that all monies due to the Trust are recovered on a timely basis from the member of staff or ex-employee of the Trust. The policy will apply to all Trust staff, currently or previously employed, including staff on Honorary Contracts. It will also include others who have or will receive a payment from the Payroll Services Department of NHS Wales Shared Services Partnership who are hosted by the Trust. This policy takes into account The Employment Rights Act 1996, section 13 which states that one of three conditions has to be met for the employer to lawfully make deductions from an employee s salary. These are that the deduction is either: required or authorised by statute authorised by a relevant provision of the contract of employment and the employee has received a copy of the contract and/or appointment letter, prior to the deduction being made or prior permission in writing has been given by the employee before the deduction is made The Employment Rights Act 1996 however, also states in section 14, that section 13 does not apply in the situation where an employer makes a deduction from an employee s wages to recover an overpayment of wages, which was made by the employer to the employee, for any reason unless, the employer has led the employee to believe that the money was rightfully his, and the employee relies on spending the money or entering a financial commitment, and the overpayment was not the worker s fault. The current Velindre NHS Trust Contract of Employment (NHS Wales Employment Contract) states in section 15 that: Where certain charges for lodgings, meals, beverages, telephone charges, car parking, etc. are payable under the conditions of employment, they will be deducted from your salary. Ref: Black 58 Issue Number: xxx Approved by: Trust Board Page 4 of 21 Effective Date: xxx

8 Velindre NHS Trust Recovery of Payroll Overpayments Policy Policy Lead: Director of Finance & Informatics Velindre NHS Trust reserves the right to withhold salary and benefits, or make deductions from salary/wages in respect of unauthorised absence from work, over-payment of salary and/or expenses. Furthermore Velindre NHS Trust also reserves the right, following investigation, to withhold payment or deduct a day s pay for each day of any unauthorised absence. Velindre NHS Trust will manage any necessary deductions in a sensitive manner and before any deductions are made you will be consulted and a discussion will be undertaken as to the most appropriate method and timescale for such a repayment to be made. 2. SCOPE This policy outlines the process for managing the recovery of Payroll overpayments. 3. AIMS AND OBJECTIVES The Trust has a legal right to recover any overpayment where it arose from a mistake of fact. Whenever monies are to be recovered, the Trust will aim to do so in a fair and reasonable manner. These payments are made in good faith and are deemed to be correct at the time of issue. Mistakes of fact are where the payment was inconsistent with the facts (e.g. through clerical error, computer input, or procedural errors). Money paid out under a mistake of fact is recoverable in law. In accordance with this policy statement and Welsh Government guidance, the Trust must pursue the recovery of all amounts due to it as a result of such overpayments. The Trust must ensure that all Trust employees / ex-employees are treated fairly. All debts must be recorded, by the Trust, regardless of whether an agreement of repayment has been reached with the debtor. The Trust will ensure a consistent approach within the provisions of this policy is taken when dealing with each recovery of overpayment. 4. ROLES AND RESPONSIBILITIES Velindre NHS Trust Staff It is the responsibility of all Trust staff to ensure that they receive and then check their paper or on-line pay-slips to confirm that they are being paid correctly and at the correct rate/pay band. On checking the paper payslip, or viewing it on-line, where an individual identifies that he/she has been or may have been overpaid, then he/she has a duty to contact the Trust and inform the Payroll Department and their Line Manager of the possible overpayment. When dealing with the request for repayment of outstanding monies, a claim of ignorance, by the member of staff, in that he/she did not receive or check any pay-slip, Ref: Black 58 Issue Number: xxx Approved by: Trust Board Page 5 of 21 Effective Date: xxx

9 Velindre NHS Trust Recovery of Payroll Overpayments Policy Policy Lead: Director of Finance & Informatics whether provided on paper or made available on-line, will not be accepted in its own right as a reason for not repaying the Trust. Staff should also be aware that the salary payment received each month on 21 st (or working day prior to the 21 st if that falls on a weekend / bank holiday) is in respect of salary for the whole of that month. For example - salary paid on 21 st April is for the period worked 1 st 30 th April (not for the period 21 st March until 20 th April). Staff leaving the employment of the Trust between the 21 st 30 th of the month may receive an overpayment if the processes to terminate their employment are not actioned prior to the processing of that month s pay which is undertaken during the first week of the month. They should therefore be extra vigilante in checking any final payslip received by the Trust and raising any queries immediately. Managers It is the responsibility of all Managers to process the appropriate pay related documentation promptly, to meet payroll deadlines. They should also ensure that all Timesheets, Termination Forms, Staff Changes Forms, On-call claim forms and/or expense forms have been completed appropriately and relevant information entered onto the Electronic Staff Record (ESR) system as soon as possible. Such documentation should be appropriately verified and authorised. As monthly salary payments are prepared by the Payroll Department during the first week of the month, any delay in a Manager processing changes or terminations could result in an overpayment to a member of staff. The Line Manager will also co-ordinate the recovery of overpayments by supporting the Payroll Department with explanations of overpayments and in the first instance discussing the repayment requirements with the employee. Repayment plans should be agreed between the employee and their line manager within a month of them becoming aware of the overpayment. The line manager should notify the Payroll Manager and the Deputy Director of Finance of the basis of the agreement in order that the appropriate charges can be made. Any decision to write off a debt should only be made in exceptional circumstances and on an individual case of need basis. Any write off will be authorised and actioned as detailed in the Trust Standing Orders & Standing Financial Instructions. Payroll Department The Payroll Department will manage any deductions from salary for the recovery of payroll overpayments. The Payroll Department will maintain an accurate log of all overpayments, providing information to the Line Manager and the employee or exemployee. The Payroll Department will also provide general guidance on how pay information is displayed on a payslip, to assist staff in checking and/or understanding the entries on their payslip. The calculation of any overpayment identified must be taken from the originating date of the overpayment and not the date that it was identified. Ref: Black 58 Issue Number: xxx Approved by: Trust Board Page 6 of 21 Effective Date: xxx

10 Velindre NHS Trust Recovery of Payroll Overpayments Policy Policy Lead: Director of Finance & Informatics Where Payroll have identified that an employee or former employee would have reasonably known that an overpayment has occurred, and no agreement can be achieved with respect to repayment the case may be referred to the Trust s Nominated Local Counter Fraud Specialist for advice. It may also be referred to the Trust s debt collection agency to pursue the debt on behalf of the Trust. Workforce & Organisational Development (OD) Department The Workforce & OD department will assist the Payroll Department and Line Managers, by providing advice and support in the event of any dispute. Accounts Receivable (AR) Team The Trust s AR team will take responsibility for recording the debt in the Trust s Financial Accounts and provide the relevant invoices to the member of staff. The AR team will also liaise with any debt collection agency if required. 5. PREVENTION In order to take measures to prevent an overpayment occurring, it is necessary to reduce the possibilities for the occurrence in the first instance. The main reason for overpayments occurring within the Trust is the late notification of information to the Payroll Department, ie late termination or changes of circumstances after the effective date. The payroll department calculate the salary payable during the first week of each month and therefore any changes made after that time will not impact on the next salary payment made. The responsibility for the supply and action of such information lies with the employee s Manager/Supervisor. It is, therefore, of the utmost importance that the completed documentation is received in the appropriate department or input onto the ESR system in ample time for action to ensure that the overpayments do not arise. Preventative measures are: Termination Information should be notified to payroll.terminations@wales.nhs.uk or entered onto ESR as soon as the termination date of the employee is known. Usually this would be when the employee hands in their resignation to their manager. This should not be delayed until the last working day of the employee. Changes Information should be completed in paper form or entered onto ESR as soon as that change is known. This should be actioned by the line manager on or before the date the employee works to the changed terms and conditions. 6. RECOVERY PROCEDURE The Payroll Department will, in the following pay period, automatically deduct in full any overpayment that is identified before, on or 1 day after the stated pay day. The individual will be notified, by telephone and in writing of any deduction together with a Ref: Black 58 Issue Number: xxx Approved by: Trust Board Page 7 of 21 Effective Date: xxx

11 Velindre NHS Trust Recovery of Payroll Overpayments Policy Policy Lead: Director of Finance & Informatics brief explanation of how the overpayment occurred. In the case of an employee, the person s Line Manager will also be advised of the overpayment by letter (see Appendix 1). For Current Employees: Where an overpayment of salary is identified by the Trust, after the stated pay day, a letter (see Appendix 2) will be sent to the employee/individual by the Payroll Manager detailing: How the overpayment occurred; A breakdown of the overpayment, including an explanation of the error; Suggested repayment period and amount; and Deadline for the response, and who the individual should contact. The Payroll Manager will send a copy of the letter to the employee s manager and the Accounts Receivable team. The Accounts Receivable team will then raise an invoice to record the debt in the Trust s accounts. The employee can request all documentation relating to the alleged overpayment, and further explanation from the Payroll Department or their Line Manager. In cases, where an employee receives a payment for any arrears and therefore would not be expected to be able to calculate the final amount due, any overpayment that arose, as a result, would be dealt with by letter from the Payroll Manager as with any normal overpayment of salary and not immediately deducted. Should no communication be received from the employee within 14 days of the initial correspondence, a second reminder letter (see Appendix 3) will be sent to the individual from the Payroll Department, stating that the Trust will commence deductions as outlined in their previous letter. Once the employee has agreed a repayment plan, or no response has been received following the second reminder letter, the Payroll Department will commence deductions from the next pay period. Repayments should normally be made in one single payment. However, this may be extended to a maximum period to not exceed the original overpayment period. Where the employee has responded to the letters and no agreement can be reached, then a meeting must be arranged to take place between the employee, his/her Line Manager, a representative from the Workforce & OD team, together with the Payroll Manager or nominated deputy. The employee will have the right to be accompanied at this meeting by a Staff Representative or a friend/colleague, not acting in a legal capacity. In accordance with this, the contract of employment and Section 14 of The Employment Rights Act 1996, the AR Department will not action any collection process until this meeting has taken place, and the outcome known. The Payroll Manager will advise the AR department that the meeting has taken place and the outcome of the meeting. Ref: Black 58 Issue Number: xxx Approved by: Trust Board Page 8 of 21 Effective Date: xxx

12 Velindre NHS Trust Recovery of Payroll Overpayments Policy Policy Lead: Director of Finance & Informatics The invoice detailing the amount owed to the Trust, plus any relevant backing documents detailing how the overpayment occurred, must be given to the employee prior to any such meeting taking place. Where there is no response or no agreement has been reached with an employee, then the debt may be considered pursuable in accordance with the Trust s Debt Recovery Procedure, which is attached at Appendix 6. This decision will be made by the Director of Finance on the recommendation of the Divisional Director or Hosted Service Chief Officer. For Ex Employees: Where an overpayment is made to an ex employee of the Trust, a letter (see appendix 4) will be sent to the line manager notifying them of the overpayment. A letter (see appendix 5) will then be sent to the individual detailing: How the overpayment occurred; A breakdown of the overpayment, including an explanation of the error; How to make payment; and Who to contact with any queries. The Payroll Manager will send a copy of the letter to the employee s manager and the Accounts Receivable team. The Accounts Receivable team will then raise an invoice to record the debt in the Trust s accounts. The individual can request all documentation relating to the alleged overpayment, and further explanation from the Payroll Department or their previous line manager. If the payment is not forthcoming the debt will be pursuable in accordance with the Trust s Debt Recovery Procedure. In the case of current or ex-employees, if the overpayment case has been referred to the Trust s Nominated Local Counter Fraud Specialist for further investigation into the circumstances surrounding the overpayment, then the individual concerned will be informed, in writing by the Payroll Manager. The letter will include reference to the fact that by receiving and retaining money from the overpayment, that he/she was not entitled to and also that he/she had made no effort to contact the Trust to stop the payments being made or notify the Trust of the overpayment, it was therefore being considered that he/she may have committed the criminal offence of Retaining a Wrongful Credit, contrary to Section 24 of the Theft Act In such circumstances where it is subsequently proven that prima facie evidence of fraud exists, Velindre NHS Trust is within its rights to demand payment in full of monies owed. The 1968 Theft Act says "A person is guilty of theft if he dishonestly appropriates property belonging to another with the intention of permanently depriving the other of it". It goes on to say "A person is guilty of an offence if - (a) a wrongful credit has been made to an account kept by him or in respect of which he has any right or Ref: Black 58 Issue Number: xxx Approved by: Trust Board Page 9 of 21 Effective Date: xxx

13 Velindre NHS Trust Recovery of Payroll Overpayments Policy Policy Lead: Director of Finance & Informatics interest; (b) he knows or believes that the credit is wrongful; and (c) he dishonestly fails to take such steps as are reasonable in the circumstances to secure that the credit is cancelled." Examples of cases and their outcomes are detailed in Appendix ADDITIONAL REQUIREMENTS All correspondence in relation to salary overpayments must be retained by the Payroll Manager and if an official Trust invoice has been raised, then copies of any correspondence relating to the outstanding debt must be retained by all departments (ie Payroll Services, Accounts Receivable team and line manager) in strict chronological order. Where an individual who has been overpaid terminates employment, then the matter must be referred immediately to the AR team, by the Payroll Manager, to ensure that all outstanding debts are recovered, in full, in accordance with the process set out in this policy. All outstanding salary overpayments are included in a monthly aged debt report prepared by the AR team and circulated to Trust Finance Managers. 8. EQUALITY The Trust is committed to ensuring that, as far as is reasonably practicable, the way it provides services to the public and the way it treats its employees reflects their individual needs and does not discriminate against individuals or groups. The Trust has undertaken an Equality Impact Assessment (EQIA) and received feedback on this policy and the way it operates. The Trust wanted to know of any possible or actual impact that this procedure may have on any groups in respect of gender (including maternity and pregnancy as well as marriage or civil partnership issues) race, disability, sexual orientation, Welsh language, religion or belief, transgender, age or other protected characteristics. The assessment found that there was no impact to the equality groups mentioned and this policy will have a neutral impact on all of the protected characteristic groups. Where appropriate the Trust will make plans for the necessary actions required to minimise any stated impact to ensure that it meets its responsibilities under the equalities and human rights legislation. Ref: Black 58 Issue Number: xxx Approved by: Trust Board Page 10 of 21 Effective Date: xxx

14 Velindre NHS Trust Recovery of Payroll Overpayments Policy Policy Lead: Director of Finance & Informatics Appendix 1 Letter from Payroll Department advising Manager of Overpayment made to Existing Employee 4 th Floor Companies House Crown Way Cardiff CF14 3UB Enquiries to: [Name of Payroll Officer] [Date] Direct Line: [Tel number] [Name of Line Manager] [Contact details of Line Manager] Dear [Name of Line Manager} Ref: [Name of Employee & Payroll Number] I wish to advise you that due to late notification of a reduction in hours, [name of Employee] has been overpaid. A letter will be sent in due course to [name of Employee] detailing the calculation of the overpayment, together with a proposal of repayment. All overpayments are currently being monitored so that appropriate actions can be taken to try and reduce overpayments caused by late or incorrect information being received by Payroll. I trust that your assistance in this trying to resolve this problem can be relied upon. Yours sincerely [Name of Payroll Officer] Ref: Black 58 Issue Number: xxx Approved by: Trust Board Page 11 of 21 Effective Date: xxx

15 Velindre NHS Trust Recovery of Payroll Overpayments Policy Policy Lead: Director of Finance & Informatics Appendix 2 Letter to Current Employee Advising of Overpayment Enquiries to: [Name of Payroll Officer] 4 th Floor Companies House Crown Way Cardiff CF14 3UB [Date] Direct Line: [Tel number] [Name of Employee] [Contact details of Employee] Dear [Name of Employee] Ref: [Payroll Number] I regret to inform you that an overpayment has occurred in the salary you received on [date]. [Details of how overpayment arose and period of overpayment.] The gross overpayment amounts to [ ] which, after refunds of Pension Contributions [ ]), National Insurance [ ] and Tax [ ] leaves a net overpayment of [ ] outstanding. An invoice for this amount will follow shortly for your records. The request for payment in 14 days detailed on this invoice is not applicable if you agree to the overpayment being deducted from your salary. Unless I hear to the contrary, within 14 days of this letter, I propose to recover this over a period of [ ] months, commencing with the salary you will receive on [date]. You may however wish to repay this amount in full by following the instructions on the invoice. If you choose this option please would you contact me so that I can stop the deduction from your salary. If you have any other queries please do not hesitate to contact me and I will be able to discuss the overpayment with you in more detail and explain the repayment procedure. Please accept my sincere apologies for any concern and inconvenience caused. Yours sincerely Ref: Black 58 Issue Number: xxx Approved by: Trust Board Page 12 of 21 Effective Date: xxx

16 Velindre NHS Trust Recovery of Payroll Overpayments Policy Policy Lead: Director of Finance & Informatics [Name of Payroll Officer] cc Accounts Receivable Team cc Manager Appendix 3 Letter to Current Employee following no Response to Previous Letter (appendix 2) Enquiries to: [Name of Payroll Officer] 4 th Floor Companies House Crown Way Cardiff CF14 3UB [Date] Direct Line: [Tel number] [Name of Employee] [Contact details of Employee] Dear [Name of Employee] Ref: [Payroll Number] I refer to my letter dated [date], regarding the overpayment of [ ] in your salary. As I have not heard from you within the 14 day timescale, as set out in the above letter, I write to confirm that the Trust will commence deductions from your [date] salary. If you have any further queries please do not hesitate to contact me. Yours sincerely Ref: Black 58 Issue Number: xxx Approved by: Trust Board Page 13 of 21 Effective Date: xxx

17 Velindre NHS Trust [Name of Payroll Officer] Recovery of Payroll Overpayments Policy Policy Lead: Director of Finance & Informatics cc Accounts Receivable Team Ref: Black 58 Issue Number: xxx Approved by: Trust Board Page 14 of 21 Effective Date: xxx

18 Velindre NHS Trust Recovery of Payroll Overpayments Policy Policy Lead: Director of Finance & Informatics Appendix 4 Letter Advising Manager of Overpayment to an Ex Employee 4 th Floor Companies House Crown Way Cardiff CF14 3UB Enquiries to: [Name of Payroll Officer] [Date] Direct Line: [Tel number] [Name of Line Manager] [Contact details of Line Manager] Dear [Name of Line Manager} Ref: [Name of Employee & Payroll Number] I wish to advise you that due to [reasons] the above named employee has been overpaid. A letter will be sent in due course to [name], detailing the calculation of the overpayment, together with contact details for the Finance department, to facilitate repayment. All overpayments are currently being monitored so that appropriate actions can be taken to try and reduce overpayments caused by late or incorrect information being received by Payroll. I trust that your assistance in this trying to resolve this problem can be relied upon. Yours sincerely [Name of Payroll Officer] Ref: Black 58 Issue Number: xxx Approved by: Trust Board Page 15 of 21 Effective Date: xxx

19 Velindre NHS Trust Recovery of Payroll Overpayments Policy Policy Lead: Director of Finance & Informatics Enquiries to: [Name of Payroll Officer] Appendix 5 Letter Advising Ex Employee of Overpayment 4 th Floor Companies House Crown Way Cardiff CF14 3UB [Date] Direct Line: [Tel number] [Name of Employee] [Contact details of Employee] Dear [Name of Employee] I regret to inform you an overpayment has occurred in the salary/ies you have received from [date] to [date]. [Details of how overpayment arose and period of overpayment.] The gross overpayment amounts to [ ] which, after refunds of Income Tax [ ] and National Insurance ( [ ] leaves a net amount of [ ]. An official invoice will be issued in due course and you should follow the repayment instructions on this invoice. If you wish to discuss the repayment please contact the Accounts Receivable Team on Should you have any further queries regarding the calculation of this overpayment please contact me on the direct line above. Please accept my sincere apologies for any concern and inconvenience caused. Yours sincerely [Name of Payroll Officer] cc Accounts Receivable Team cc Manager Ref: Black 58 Issue Number: xxx Approved by: Trust Board Page 16 of 21 Effective Date: xxx

20 Velindre NHS Trust Recovery of Payroll Overpayments Policy Policy Lead: Director of Finance & Informatics APPENDIX 6 1. DEBT RECOVERY PROCEDURE 1.1 The Accounts Receivable (AR) team must raise an invoice in respect of any overpayment or amount owing to the Trust upon receipt of the relevant information from the Payroll Department. The invoice detailing the amount owed to the Trust must be sent to the Debtor. If the overpayment relates to a current employee then the account should be placed on hold until notification is received from the Payroll Department to continue with the Debt Recovery Procedure. If the overpayment relates to an ex-employee, then the debt will be pursued by the AR team under the Debt Recovery Procedure. 1.2 If the invoice remains outstanding at the end of the month following the month of invoice, then it will go forward to be included in the collection process, unless the Payroll Department have notified the AR team of any issues or repayment plans in place. A reminder letter will be sent by the AR team requesting payment and notifying the Debtor that if payment is not made within 14 days of the date of the letter the debt will be referred to the Trust s Debt Collection Agency. 1.3 Should the Debtor at any time query the invoice, dispute the charge, or promise to make payment, then the collection process must be put on hold until either the query or dispute has been resolved or payment has been made. If the payment has been promised, but not made then the collection process must be resumed. It is imperative that all queries must be noted by the AR team in order to evidence discussions and agreements. All correspondence in relation to debts must be retained by the AR / Payroll Department. 1.4 If there has been no success in collecting the debt either by the Trust or the Debt Collection Agency, then consideration must be given to instigating court proceedings. Recommendation for court action for current employees must be made in writing to the AR team by the respective Departmental Manager or Director of Service. If court proceedings are recommended then representatives from the employing department and/or the Payroll Department should accompany the AR representative to court to support the case. 1.5 If on termination of employment with the Trust, there remains an outstanding balance on the debt and it has previously been partly recovered by payroll deduction the AR team will contact the Debtor to arrange continuation of the deductions by Standing Order. 2. WRITE OFF Ref: Black 58 Issue Number: xxx Approved by: Trust Board Page 17 of 21 Effective Date: xxx

21 Velindre NHS Trust Recovery of Payroll Overpayments Policy Policy Lead: Director of Finance & Informatics 2.1 If attempts to collect the debt either by the Trust or the Debt Collection Agency is unsuccessful and Court Action is not feasible or has failed, then a proposal should be prepared to request write off of the debt. 2.2 Recommendations for the write off of debts must be made by Senior Divisional staff. 2.3 Requests to write off debts will be considered and actioned in line with the Trust s Standing Orders & Standing Financial Instructions. Ref: Black 58 Issue Number: xxx Approved by: Trust Board Page 18 of 21 Effective Date: xxx

22 Velindre NHS Trust Recovery of Payroll Overpayments Policy Policy Lead: Director of Finance & Informatics APPENDIX 7 EXAMPLE 1 Mr A is notified, in July, by his employer that his current post is to be revised as Band 4, due to his failure to comply with professional registration requirements. However, due to a clerical error, he continues to be paid at Band 6, which is clearly shown on his payslip, but Mr A is aggrieved at the decision to lower grade and so Mr A decides to spend the money ( 5000) and does not inform his employer at any time. The error continues for a further 10 months until a payroll officer finds the error and notifies Mr A, but in reply Mr A, whilst accepting that he has been overpaid, claims that he has spent the money and now can only afford to repay the amount by instalments ( 25 per month x 200 months). Decision Payroll/Accounts Receivable The individual is contacted and requested to repay the amount in one instalment, however, with discretion to allow re-payment over the same period as the overpayment. (i.e. 500 x 10 months) Counter Fraud The case should also be referred, by Payroll Department or Accounts Receivable, for further enquiries to be made as part of a potential criminal investigation, since the onus was clearly on the individual to have notified his employer when his salary payments were not correctly adjusted and it would have been reasonable for him to have known that he was being overpaid. EXAMPLE 2 Miss T notifies her Line Manager that she wants to reduce her hours from 37.5hrs to 20hrs per week. However, due to a clerical error, she continues to be paid full time (37.5hrs) which is clearly shown on her payslip, but Miss T does not spend the money and then informs her Line Manager and payroll immediately of the error in writing. However, the Payroll Department do not receive the correspondence. This continues for a further 10 months until Miss T decides to write to her employer again giving a specific date by which the employer should recover the money, but the date passes and Miss T then goes and spends the money, which she now considers to be her own. Ref: Black 58 Issue Number: xxx Approved by: Trust Board Page 19 of 21 Effective Date: xxx

23 Velindre NHS Trust Decision Recovery of Payroll Overpayments Policy Policy Lead: Director of Finance & Informatics Payroll/Accounts Receivable The individual has done everything reasonable, with her employer, to secure that the credit is cancelled and therefore should have the right to treat it as her own and then spend the money accordingly. Counter Fraud No action for same reason given. EXAMPLE 3 Mrs H works a number of rostered shifts including weekends and as a result receives salary payment of the enhancements, a month in arrears, for this work. In June, the ward on which she worked stopped all weekend work and therefore, she was not required to work, however, due to a clerical error, in July and for the following 3 months, she continued to receive recurring payments, which were clearly shown on her payslip, but Mrs H did not regularly check her payslip and spends the money ( 1000). The payroll officer finds the error and then notifies Mrs H, but in reply Mrs H does not accept that she has been overpaid as she claims that she does not find it easy to check her on-line payslip and also has now gone and spent the money. Decision Payroll/Accounts Receivable The individual is contacted and requested to repay the amount in one instalment, however, with discretion to allow re-payment over the same period as the overpayment. (i.e. 666 x 3 months) Counter Fraud The case should also be referred, by Payroll or Accounts Receivable, for further enquiries to be made as part of a potential criminal investigation, since the onus was clearly on the individual to check her payslips and to have notified her employer when she identified that her salary payments had not reduced as a result of a change in circumstances (i.e. no weekend shifts) and therefore it could be considered for it to be reasonable for her to have known that she was being overpaid. EXAMPLE 4 Miss J works a number of rostered shifts including weekends and as a result receives enhancements, a month in arrears, for this work. However, due to a clerical error, she continued to receive one recurring payment a month for 10 months, but whilst Miss J does regularly check her payslip, she expected to regularly receive enhancement payments and therefore did not notice the error and spends the money ( 500). Ref: Black 58 Issue Number: xxx Approved by: Trust Board Page 20 of 21 Effective Date: xxx

24 Velindre NHS Trust Recovery of Payroll Overpayments Policy Policy Lead: Director of Finance & Informatics The payroll officer finds the error and then notifies Miss J, but in reply Miss J states that she did not notice the error and has spent the money. Decision Payroll/Accounts Receivable The individual is contacted and requested to repay the amount in one instalment, however, with discretion to allow re-payment over the same period as the overpayment. (i.e. 50 x 10 months) Counter Fraud No action as this is considered to be a drip feed overpayment in that it would have been reasonable for the individual to have expected to receive regular monthly enhancements and wouldn t necessarily have noticed that she was being overpaid, but Miss J would still have a duty to repay any monies to her employer that she had been overpaid, as a result of the error. EXAMPLE 5 Mr R hands in his letter of resignation to his employer on 27 th March stating that he wishes to leave the Trust on 21 st April. His manager agrees to this termination date, and then goes on annual leave, actioning the termination on ESR upon his return on 14 th April. Mr R receives a full month s salary on 21 st April as the notification to the payroll department was done after the pay for that month had been calculated. An overpayment for the period 22 nd 30 th April has therefore been made to Mr R. Decision Payroll/Accounts Receivable The manager is contacted by the payroll department and asked to ensure terminations are processed in future on the date the resignation is received from the member of staff. The manager asks that any written communication sent to Mr R be sent in font size 22 as Mr R has restricted sight. The payroll department contacts Mr R in the format requested by the manager, and requests that he repays the amount in one instalment. Counter Fraud No action as it would have been reasonable for the individual to have expected their final salary to be calculated correctly as they notified their manager on 27 th March. However, Mr R would still have a duty to repay any monies to his employer that he had been overpaid, as a result of the error. Ref: Black 58 Issue Number: xxx Approved by: Trust Board Page 21 of 21 Effective Date: xxx

25 1 [Report Title] Audit Committee Procurement of personal radiation dosimetry materials Meeting Date: 20 th July 2017 Author: Sponsoring Executive Director: Report Presented by: Arnold Rust, Head of Radiation Protection Service Andrea Hague Arnold Rust Committee/Group who have received or considered this paper: Trust Resolution to: (please tick) Approve: Endorse: Discuss: Note: Recommendation: This report supports the following Trust objectives as set out in the Integrated Medium Term Plan: (please tick) Equitable and timely services Providing evidence based care and research which is clinically effective Supporting our staff to excel Safe and reliable services First class patient /donor experience Spending every pound well This report supports the following Health & Care Standards: Health Promotion, Protection and Improvement 2.1 Managing Risk and Promoting Health and Safety 2.9 Medical Devices, Equipment and Diagnostic Systems 3.1 Safe and Clinically Effective Care Page 1

26 2 [Report Title] 3.3 Quality Improvement, Research and Innovation 1. Introduction / Background 1.1. The Radiation Protection Service purchases personal radiation dosimetry materials for use by Velindre NHS Staff and for provision via Service Level Agreements to all NHS Wales organisations using ionising radiations and a portfolio of non-nhs clients across the UK using the corporate identity RPS Cardiff. These materials are best known as the badges and rings worn by radiation workers in order to measure the radiation dose received during the course of their work as a means of determining whether legal dose limits are being observed Dosimetry materials are purchased from Landauer, a company based in the United States with a presence in the UK. Dose meters are prepared in the US and forwarded to the UK for onward direct distribution to RPS Cardiff customers. Dose meters are returned to the radiation protection service after being worn by the individual monitored for logging and onward forwarding to Landauer in the UK for processing in the US. Results are supplied in bulk format to the Radiation Protection Service for sorting into individualised reports for the customer Dosimetry materials are supplied on the basis of a contract, awarded to Landauer subsequent to a competitive tender launched in October 2010, with the contract starting in October The contract was awarded on the basis of a (five year in total) arrangement, the final phase of which expired in October To enable continued supplies of dosimetry materials, the contract was then extended at risk until 31 st March 2017, which was in breach of Trust Standing Financial Instructions A further extension for six months with an option for a further six months has been secured (signed by CEO on 26 th May 2017) on the basis that this time is required for a review of the personal radiation dosimetry service model to take place and for the radiation protection service and procurement department to undertake the necessary work before proceeding to a formal tender. 2. Timing: 2.1. Preparations for a new tendering exercise, to include a complete re-work of documentation in response to changes in the procurement framework since the previous exercise, began during spring 2016, but were hampered by two main factors; shortage of staff within the Velindre NHS Trust Procurement Department and consequent lower level of support than was needed, and lack of capacity within the Radiation Protection Service, due to shortage of staff caused by the retirement of a senior member of the group. The combination of these factors meant that progress with the procurement was too slow and the deadline for launching a tender to enable a new contract to be in place for October 2016 was missed As a pragmatic approach to ensuring continuation of supply, a six-month extension was put in place with Landauer at short notice covering the period October 2016 to March Matters were overtaken by events during January 2017 with the announcement from Landauer that an internet data breach had taken place and the personal information of Page 2

27 3 [Report Title] most of the RPS Cardiff customer base comprising several thousand individuals had been compromised. This diverted significant resource from Procurement Department and Radiation Protection Service in providing input to resolution of this declared Major Incident and no further progress was made with the tendering process. 3. Description: See above. 4. Financial Impact: 4.1. The financial impact of placing the two short term contracts was nil beyond the costs that would normally have been incurred whilst running the contract for this period. The materials needed to be purchased in order for the Radiation Protection Service to discharge its service level agreement obligations with its customers and to preserve income from this source Inability of the Radiation Protection Service to deliver personal radiation dosimetry materials to the customer base would have had an immediate and significant financial impact in terms of loss of revenue and margins from the ongoing operation and potentially jeopardise the commercial viability of the service. 5. Quality, Equality, Safety and Patient Experience Impact: 5.1. The inability of the radiation protection service to deliver personal radiation dosimetry materials as a consequence of not seeking the short term extension of the contract with Landauer would have resulted in i) Inability of Velindre NHS Trust and the RPS Cardiff customer base to undertake personal radiation dosimetry of their staff as required by the Ionising Radiations Regulations This may lead to legal and/or enforcement action by the Health and Safety Executive with potential claims for compensation from the customer base. ii) Loss of confidence in the RPS Cardiff personal dosimetry service and the possibility of customers moving to another supplier. iii) Significant loss of reputation for the Radiation Protection Service and Velindre NHS Trust. 6. Considerations for Board / Committee: 6.1. The Radiation Protection Service and other departments within Velindre NHS Trust are heavily reliant on the specialist expertise and support of Velindre NHS Trust Procurement Department staff in terms of running tendering exercises and the placement and management of contracts. It is vitally important that this key function is adequately resourced and available to the Trust as required Lack of senior staff capacity within the Radiation Protection Service at a key phase of the procurement cycle meant that insufficient resource was available to progress the tendering exercise at the rate needed to meet deadlines. Page 3

28 4 [Report Title] 7. Next Steps: 7.1. Arrangements are in hand to proceed with a further extension of the contract for supply of personal radiation dosimetry materials from Landauer. This time will be used to review the personal radiation dosimetry service model in the light of the data breach, to run a procurement exercise and allow time, if necessary, to align IT systems with a potential new supplier of personal radiation dosimetry materials. Page 4

29 1 Standing Orders Amendment to Financial Limit (R&D) Audit Committee AUDIT COMMITTEE STANDING ORDERS AMENDMENT TO FINANCIAL LIMIT (WBS Routine Wholesaling Activity) Meeting Date: 20 th July 2017 Author: Jeremy Lewis, Finance Manager WBS Sponsoring Director: Georgina Galletly, Director of Corporate Governance Report Presented by: Georgina Galletly, Director of Corporate Governance Committee/Group who have received or - considered this paper: Trust Resolution to: (please tick) APPROVE: REVIEW: INFORM: ASSURE: Recommendation: The Audit Committee is asked to endorse the proposal for submission to Trust Board approval. This report supports the following Trust objectives as set out in the Integrated Medium Term Plan: (please tick) Equitable and timely services Providing evidence based care and research which is clinically effective Supporting our staff to excel Safe and reliable services First class patient /donor experience Spending every pound well ACRONYMS This report supports the following Health & Care Standards: Page 1

30 2 Standing Orders Amendment to Financial Limit (R&D) Audit Committee 1. Introduction / Background: 1.1 A proposal to amend the delegated financial limits for the Deputy Director (WBS), Chief Executive and Director of Finance & Informatics to allow them the same 400k financial authorisation limit, restricted to wholesale products only, to ensure business continuity for the wholesale service. 2. Timing 2.1 Subject to Audit Committee endorsement, the proposal to amend the financial limits delegated to the Deputy Director (WBS), Chief Executive and Director of Finance & Informatics will be submitted to the Trust Board at their meeting on 28 th September 2017 for approval. Subject to Trust Board approval, the revised delegated limit will be implemented immediately. 3. Description: 3.1 Financial limits are awarded to Trust Officers to aid effective decision making at the most appropriate level to support operational service provision. 3.2 In December 2015 the appropriateness of the financial limits were reviewed and Trust Board approved a request to increase the revenue limit for the WBS Director, WBS Medical Director and Head of Laboratory Services. Ordering of wholesale products has been operating within the 400k authorisation limit. 3.3 WBS are required to provide a safe, secure and robust ordering system for the provision of routine wholesale products as required under a Wholesale Dealers Licence. Following the resignation of the WBS Medical Director, this has led to a lack of resilience within the ordering system for wholesale products and the service may be exposed to potential operational difficulties including delays in ordering process, with potential harm for the acute patients supported by the wholesale service. 3.4 An amendment is requested as per the attached table of financial limits, highlighted in red. 4. Financial Impact: 4.1 There are no financial consequences associated with the proposed revised financial limit. 5. Quality, Equality, Safety and Patient Experience Impact. 5.1 No adverse impact. 6. Considerations for Board / Committee. 6.1 The proposal to allow the change in authorisation limits would be a practical solution to help ensure there was no breakdown in business continuity. The Audit Committee is asked to ENDORSE the amendment to the Trust s Standing Orders in relation to the revised financial limits for the Deputy Director (WBS), Chief Executive and Director of Finance & Informatics as detailed in section 3, and endorse their onward submission to the Trust Board for final approval at their meeting in September Page 2

31 3 Standing Orders Amendment to Financial Limit (R&D) Audit Committee 7. Next Steps 7.1 The Audit Committee is asked to receive this report for ENDORSEMENT for onward submission to Trust Board for approval and implementation. Page 3

32 4 Standing Orders Amendment to Financial Limit (R&D) Audit Committee Financial Limits Revenue 000 Capital 000 Charitable Funds 000 Corporate Services: Trust Board No Limit No Limit 0 Charitable Funds Committee 0 0 No Limit Chief Executive Executive Medical Director Executive Director of Finance Executive Director of Nursing Executive Director of Workforce and Organisational Development Director of Planning Head of Estates, Environment and Capital Planning Estates Development Manager Deputy Director of Finance Management Accountants Financial Planning Accountant Delegated Budget Holders Delegated Charitable Fund Holders Chief Executive & Director of Finance & Informatics for Blood Wholesale Products Cancer Services: Director of Cancer Services, Director of Operations & Chief Pharmacist for Pharmaceuticals Director of Cancer Services Director of Operations Principal Pharmacists - for Pharmaceuticals 30 Operational Services Manager Delegated Budget Holders Welsh Blood Service: Director of Welsh Blood Service, WBS Medical Director, Head of Laboratory Services & Deputy Director of Welsh Blood Service for Blood Wholesale Products Director of Welsh Blood Service Medical Director Head of Laboratory Services Head of Welsh Transplantation & Immunogenetics Lab General Services Manager Finance Manager Other Delegated Budget Holders Page 4

33 1 [Report Title] AUDIT COMMITTEE NHS WALES INFORMATICS SERVICE GOVERNANCE PACK Meeting Date: 20 th July 2017 Author: Sponsoring Executive Director: Report Presented by: Committee/Group who have received or considered this paper: Mike Flanagan, Director of Finance & Business Assurance, NWIS Mark Osland, Executive Director of Finance Mike Flanagan, Director of Finance & Business Assurance, NWIS None Trust Resolution to: (please tick) Approve: Endorse: Discuss: Note: Recommendation: This report supports the following Trust objectives as set out in the Integrated Medium Term Plan: (please tick) Equitable and timely services Providing evidence based care and research which is clinically effective Supporting our staff to excel Safe and reliable services First class patient /donor experience Spending every pound well This report supports the following Health & Care Standards: Governance, Leadership and Accountability Staying Healthy Safe Care Effective Care Dignified Care Page 1

34 2 [Report Title] Timely Care Individual Care Staff and Resources 1. Introduction / Background 1.1. This paper introduces reports from the NHS Wales Informatics Services (NWIS) which are submitted to the Committee to provide assurance on the performance and activity of NWIS as a hosted organisation of Velindre NHS Trust. 2. Timing: 2.1. These reports cover the period from the last attendance at Audit Committee by NWIS (December 2016) to date. 3. Description: 3.1. The following reports are provided: Corporate Risk Register Hospitality Register Single Tender Action Report 3.2. The following reports are provided for information/background: Report on NWIS Activities Financial Update (Interim End of Year Position) 4. Financial Impact: 4.1. Refer to Hospitality Register, Single Tender Action Report and Financial Update. 5. Quality, Equality, Safety and Patient Experience Impact: 5.1. Refer to Corporate Risk Register and NWIS Activities Update. 6. Considerations for Board / Committee: 6.1. The Board are requested to note the contents of the reports. 7. Next Steps: 7.1. NWIS will continue produce reports for Audit Committee to provide them with appropriate assurance of activities undertaken. Page 2

35 NHS Wales Informatics Service Risk Register Status of Register Next Review Date Active -March 2017 Monthly Datix Risk Ref Risk Summary Date Risk Identified & Initial Risk Rating Rating when last assessed & Date Action agreed at last risk assessment Progress Target Risk Rating & Target Date Exec Lead for Risk Assuring Com for Risk NWIS0119 Lack of coherent approach to document management across the organisation. Teams unable to see all appropriate documentation, different mechanisms for storing information, unable to trace documents and decisions. Also unable to audit. 26/10/2011 Amber 9 14/03/2017 Yellow 6 Existing quality management systems, ITIL, use of Dolen. 14/03/17 FBA Quarterly Review JA/DC/AJS: System continues to be rolled out. Implementation and best practice guidanceis being led by the Quality Improvement Manager via the Integrated Management System. Green 3 30/06/2017 Director of Finance & Business Assurance NWIS Executive Board NWIS0192 The NWIS telephony system has several points of failure which have the potential to compromise NWIS ability to deliver 24hr support, such as: 1. being reliant on a non-resilient power supply at TGA; Single instance of Teleworker; 3. Lack of ownership of faults between Vodafone and BT; 4. The exchange is overloaded and has a single point of failure. These were previously risks 10775, 6, 7, 8. 16/05/2016 Amber 12 21/03/2017 Yellow 6 A business case has been submitted to upgrade the Blaenavon and TGA telephone exchanges to a pair of mirrored exchanges and Mitel teleworkers located in Data Centres with SIP telephone trunks that will fail over from one exchange to the other in the event of a failure. 21/03/2017 RMQIG Review - Procurement due to complete by end of Financial Year. 06/01/2017 AJS CLJ Quarterly Directorate Review - Procurement underway for resilient Mitel System following approval of the case for funding. Green 3 31/03/2017 Director of ICT NWIS Executive Board NWIS0182 Risk of data theft or corruption going unnoticed due to lack of regular pro-active monitoring of network audit logs. 22/01/2016 Red 15 21/03/2017 Red 15 Procure cyber incident monitoring analysis and reporting service. 21/02/2017 Procurement Update JA: A joint procurement with NWSSP has resulted in a Yellow 5 partial solution being in place allowing instant responses to any security incident. A further 31/03/2018 procurement is commencing which will consider All Wales requirements. RMQIG to consider de-escalation of risk. Director of Information and Communications Technology NWIS Executive Board NWIS0193 In the event of running all services through one datacentre firewall, it is likely that the firewall would not have enough RAM to be able to process traffic and this could result in a prolonged interruption to all services. An interruption (~30 mins) to services at the Blaenavon Data Centre occurred on the 16th August Investigations indicate that this was caused by the firewall at the site exhausting its RAM and not failing correctly to the standby firewall. 25/08/2016 Red 16 21/03/2017Amber 8 NWIS immediately engaged with the maintainer and with Cisco (manufacturer) and implemented some recommendations to reduce memory consumption. We did the same for the Newport Data Centre firewalls. This had a significant improvement effect and, at the moment, the memory utilisation is running at <50% on all firewalls so the problem should not re-occur in the short term. The permanent fix is to replace the firewalls with higher capacity model and also to review the rules in the firewall to determine if they can be optimised. 21/03/2017 RW/JA Update: Procurement complete and equipment due to be delivered by the end of the financial year. Once iinstalled and running, risk can be closed. Yellow 4 31/03/2017 Director of Information and Communications Technology NWIS Executive Board