Attachment E3 Croydon Borough Team Integrated Governance and Audit Committee Date: Thursday 13 December 2012 Time: 10 12 p.m. Location: Room 11.4 Leon House Minutes Present: In Attendance: Members: Maureen Glover (MG), Board Secretary Toni Letts, (TL), Non Executive Director Ben Vintner (BV), Deputy Governance (Chair) Director, CSU John Thompson (JT), Non Executive Tony Brzezicki (TB), Chair CCG Director Paula Swann, (PS) Croydon Borough Amy Page (AP), Chief Nurse, Croydon CCG Team Managing Director / Designate Accountable Officer Croydon CCG Mike Sexton (MS) Chief Finance Officer Designate Fouzia Harrington (FH), Director of Governance and Quality Designate Michael Mulligan (MM) Rebecca Chappell, (RC), Counter Fraud Nick Atkinson (NA), Internal Audit Sarah Ironmonger (SI) External Audit 1 Apologies Action Apologies were received from Karthiga 2 2.1 Terms of Reference and Standard Agenda Fouzia Harrington introduced the paper and advised that the Terms of Reference were those within the Constitution and since that time it was recognised that they reflected the Audit Committee more than the Integrated Governance Committee and they would be revisited and FH amended. 2.2 2.3 Attention was drawn to the fact that the Integrated Governance and Audit Committee (IGAC) only had one sub-committee the Finance Committee. The CCG had, therefore, given further consideration to the governance arrangements for quality and the proposal was to establish a Quality Assurance Sub Committee to look in more detail at quality and clinical risks and the management of the assurance process. Nick Atkinson said the Terms of Reference captured the essence of the IGAC. He also said the Board Assurance Framework (BAF) would be the tool the IGAC would use to seek assurance. Consideration would be given to how the BAF could be used at a strategic level to ensure that the IGAC was assured. Where the IGAC did not feel assured issues would be escalated to the Governing Body. Page 1
2.4 2.5 2.6 2.7 2.8 3 3.1 3.2 3.3 Nick Atkinson advised that other Terms of Reference he had seen included the role the IGAC would play in monitoring potential non compliance, SFIs, standing orders, etc. It was agreed that Nick Atkinson would provide some wording that could be incorporated in the Terms of Reference. Sarah Ironmonger referred to the National Commissioning Board (NCB) Terms of Reference which stated the NCB would appoint auditors to the CCG. Indications had been given about the need for continuity which was a different emphasis to the Terms of Reference. There was a discussion about quoracy and whether there should be greater GP representation. Tony Brzezicki said GPs were involved in developing policies and strategies and it would, therefore, be inappropriate to ask them to make comments for assurance purposes. It was considered that the lay consultant or chief nurse would provide the clinical assurance. Paula Swann said the IGAC would have the ability to invite representatives to the meeting as required to answer questions about internal control. It was agreed that Nick Atkinson would look at other Terms of Reference to see what CCGs were putting in place with regard to the number of lay members on the IGAC. It was noted that the IGAC had a broad remit and there was a requirement to seek assurance regarding the CSU. Reference was made to the section on attendance and consideration would be given to whether the IGAC might wish to include the option to invite representation from the CSU, as appropriate, to provide assurance. Nick Atkinson said a number of controls relied on the contract with the CSU and part of the challenge would be to identify how the CSU would provide that assurance. The amendments agreed would be made to the Terms of Reference and they would be brought back to the next meeting. The Integrated Governance and Audit Committee agreed the proposal to have a Quality Sub Committee. Internal Audit Progress Report Nick Atkinson took members of the Committee through his presentation which set out the role of the Audit Committee in the CCG. The lay members would be taken through the presentation in more detail. The paper had been brought to the meeting for information. Tony Brzezicki said the presentation was really helpful and would enable Clinical Leaders to have a greater understanding of audit. It could also be used as part of the induction programme for the lay members. Nick Atkinson offered to give a presentation to the members of the Clinical Leadership Group. Nick Atkinson then presented a document which set out the outline NA NA FH Page 2 of 7
approach and potential planned areas for internal audit for 2013/14 onwards. It was noted that there was a need to differentiate between what the CCG would look at to seek assurance as opposed to the assurance it would seek from the CSU and the detail of this would need to be worked through. It was recognised that the CSU would not want each CCG to send in internal auditors unless there were specific issues. Paula Swann and Mike Sexton had discussed this and it was noted that a lot of typical internal audit in relation to Croydon would be provided from third party assurance through the CSU internal plan. 3.4 3.5 Mike Sexton advised that Nick Atkinson was part of the internal South West London arrangement and his role was to provide support to the CCG through the transition. A paper would be presented later on the agenda with regard to the proposed internal audit arrangements for 2013/14. There was a discussion about the scope of audit in terms of the CCG being a membership organisation. It was noted that a few areas would be different, for example there would need to be an audit of the remuneration made to members for attending various meetings. There would also be a need to look at arrangements for making sure conflicts of interest were managed. Tony Brzezicki asked about conflicts of interest and what would happen when counter fraud were investigating a service the CCG no longer commissioned but where the cases might have serious clinical and financial implications for the CCG. Rebecca Chappell said this would be picked up in her paper but it was noted that national guidance was still awaited with regard to what would happen post April 2013. The Integrated Governance and Audit Committee noted the Internal Audit Progress Reports 4 4.1 5 5.1 5.2 External Audit Update Sarah Ironmonger had come to the meeting to introduce herself and said there was little she could update the IGAC on as draft proposals had not yet been received. Sarah Ironmonger said she would be working with Paula Swann and Mike Sexton but at the moment the scope and value for money element of their plan was unknown. Counter Fraud Progress Report Rebecca Chappell presented the report and advised it was an amended version of the paper taken to the SWL December Audit Committee meeting. Rebecca Chappell gave a brief overview of the documents attached to the report: A summary of the minutes from the SWL Cluster Counter Fraud meeting on 16 November 2012 which gave a flavour of the areas that were being working on or being considered. Fraud spotlight an indication of the type of awareness material that had been circulated historically. In future areas relevant to Croydon CCG would be circulated in a similar format. Page 3 of 7
National Fraud Initiative (NFI) Matched Data Working Arrangements a mandatory payroll data matching exercise was being undertaken and matches would be confirmed in January and closed down. Where it was not possible to close down, a receiver organisation post April would be identified. Counter Fraud Investigation Handover Arrangements the Head of Counter Fraud had been asked to complete a Handover Certificate for the 5 PCTs in South West London. The spreadsheet attached to the report demonstrated which certificates had been completed. It was noted that Mike Sexton had authorised the completed handover certificate for Croydon CCG but that the handover certificate for the NCB was still outstanding. 5.3 5.4 5.5 5.6 6 6.1 6.2 It was noted that the intention was to close down as much activity as possible before April 2013. Three cases were open for NHS Croydon but none of them would transfer to the CCG. Clarification was provided that new cases in the last 3 months of this year would remain the responsibility of the PCT and the cases would be progressed as far as possible. They would then be picked up by the nominated person post April. It was recognised that it would be beneficial for Rebecca Chappell to continue to be the nominated person for corporate memory and continuity. Tony Brzezicki said it was essential that the handover was formally managed and monitored. John Thompson said a lot of traditional work would not be relevant for the CCG and the Clinical Leaders Group members and the lay members would need to be aware of the Bribary Act. Rebecca Chappell advised that two meetings had been booked with regard to raising anti fraud and anti bribery awareness. It was noted that a new risk in relation to the CCG was around conflicts of interest and a certain amount of work would also be required with regard to the procurement process and tendering. A draft work plan had been prepared. This was awaiting authorisation by the CSU and would be brought to the next meeting for sign off. Independent Report on NHS Croydon Mike Sexton presented the paper which described the implications for the CCG in 2013/14 and beyond. The Independent Report on NHS Croydon had identified a number of recommendations and an action plan for implementation was attached to the report. Assurance was provided that each action had been reviewed by all of the CFOs in SWL and the destiny of each action identified i.e. whether it was the responsibility of the CCG or delegated to the CSU as part of the contract. The IGAC was advised that the CSU had been sent a side letter to the CSU contract on 30 November to countersign which stated that during the transition period it was essential that the CSU operational policies RC Page 4 of 7
and procedures reflected the recommendations from the independent report. For 2013/14 the internal audit plan for the CSU must be reconciled to the action list to provide assurance that the actions continued to be implemented. The Integrated Governance and Audit Committee noted the action plan and agreed that the 2013/14 audit plans be cross referenced to the action plan; agreed to implement actions specifically assigned to CCG Audit Committee Chairs and Members and agreed to regularly review delivery of the action plan 7 7.1 7.2 Board Assurance Framework Fouzia Harrington reflected on the comment Nick Atkinson had made earlier in the meeting that the Board Assurance Framework (BAF) would be a key tool for the IGAC in terms of identifying risks for further review, investigation and management. The BAF was presented to Governing Body earlier in the year and would be revised in January. Following feedback from the Governing Body the next version of the report would provide a risk for each sub objective as opposed to a risk for the overall objective. The IGAC s attention was drawn to the risk relating to GP involvement and engagement which had been amended to reflect the wider risk of GP engagement as opposed to being specifically related to the delivery of QIPP. Fouzia Harrington said views from members of the IGAC on the BAF would be welcome. The Integrated Governance and Audit Committee agreed the strategic risks and the management of them 8 8.1 8.2 8.3 8.4 Standard Financial Management Arrangements Prime Financial Policies Mike Sexton presented the paper which had previously been taken to the CCG s Senior Management Team to provide assurance, as part of the authorisation process, that financial management arrangements were being put in place in terms of setting up the new organisation. It was reported that the CCG would use the national financial accounting system the SBS and Oracle based Integrated Single Financial Environment (ISFE) that had been procured by the NCB on behalf of all CCGs. It was noted that SBS and Oracle systems were a tried and tested solution for Croydon CCG. It was noted that Standing Orders and Financial instructions had been adopted through Governing Body. A paper later on the agenda would set our arrangements for payroll. There was a discussion about risk sharing arrangements, which was one of the red flags on the CCG s desk top feed back for authorisation. The CCG had been seeking risk sharing arrangement with other CCGs and CFOs were looking at options. No agreement had yet been reached but it was anticipated that a conclusion would be reached at a Page 5 of 7
8.5 9 9.1 9.2 10 10.1 10.2 10.3 10.4 10.5 meeting scheduled for January. Proposals would be taken through the CCG Governing Body in January. Reference was also made to the policies that formed part of the Constitution which had been agreed through the Governing Body. It was agreed that these should form part of the induction pack for the lay members. Mike Sexton would provide clarification about the different models of procurement and whether AWP was a route that could be applied. Waiver of SFIs/SOs (agenda item 9) Losses and Compensation (agenda item 10) Mike Sexton took agenda items 9 and 10 together and provided a verbal update. He advised that, subject to the paper in the private part of the meeting, there was nothing to report. It was noted that the Waiver of SFIs and SOs and Losses and Compensation would be standard agenda items for future meetings. Quality Report Fouzia Harrington introduced the report and advised that it had been presented to the Governing Body. Feedback had been received in terms of how it should be developed. The Committee was advised that significant progress had been made with regard to the CHS CQR meetings. Premeets were being held which enabled issues to be highlighted in advance of the CQR meeting which, in turn, enabled CHS to come to the CQR meeting fully prepared. This represented a more robust process, took a month out of the cycle, provided information in a more timely way and sought to seek early resolution. It was reported that since the paper was written CHS had been asked to do a deep dive with regard to SIs and pressure ulcers. CHS had also undertaken some good work on identifying themes and had been asked to produce action plans. In terms of developing the Quality Report Fouzia Harrington said she had seen examples of the reports that were being produced in South East London and this type of reporting, together with dashboards, would be developed by the CSU for the CCG. Reference was made to the fact that a lot of quality issues in the past related to Croydon patients who went to out of borough hospitals and the question was raised about how the CCG could scrutinise this and ensure appropriate levels of quality. This level of information had historically been difficult to obtain but the CSU was working on this. As part of a collaborative agreement across South West London there was a requirement for the host organisation to put in place necessary MG MG Page 6 of 7
arrangements to ensure quality of services. It would be important to receive quality reports from each of the lead commissioners. 11 11.1 11.2 11.3 11.4 11.5 Information Governance (and compliance with FOIs) Fouzia Harrington presented the report and advised that the action plan was a first draft in terms of ensuring the CCG was putting the right information governance procedures in place as it moved forward through the transition. An assessment of the information governance tool kit had been undertaken and there was an understanding of the work that needed to be taken forward. The key issue was to ensure the implementation of key strategies to provide assurance that the CCG was safe and compliant in terms of information governance sharing information. Clarification was provided that the action with regard to appointing the SIRO Caldicott Guardian should be green as this was Fouzia Harrington. It was noted that the base line assessment was presented for information and to make sure it was aligned with the action plan. Members of the Committee were asked to provide any feedback to Fouzia Harrington. Fouzia Harrington said that risk management, information governance and safeguarding training would be carried out in the new year. 12 Any Other business There was no other business 13 Date of Next Meeting To be confirmed Page 7 of 7