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Certification Report to
those charged with
governance 2010/11
Certification
Report (2010/11)
Report to those
charged with
governance
The Members of the Audit Committee
Council Offices
Holt Road
Cromer
Norfolk
NR27 9EN
07 February 2012
Ladies and Gentlemen
Subject: Certification Report (2010/11)
We are pleased to present our Annual Certification Report summarising the results of our 2010/11
certification work. We look forward to presenting it to members on 6 March 2012. The purpose of this
report is to provide a high level overview of the results of certification work we have undertaken at North
Norfolk District Council on 2010/11 claims and returns that is accessible for members and other
interested stakeholders. Fees for 2010/11 certification work are summarised in Appendix A.
Results of Certification work
During the period June to November 2011 we certified three claims and returns worth a total of
£54,607,028. Of these, one required amendment following certification work undertaken and a
qualification letter to set out significant issues arising from the certification of the claim. We set out
further details in the attached report.
We ask the Audit Committee to consider:

the adequacy of the proposed management action plan with respect to issues identified in
2010/11 set out in Appendix B, and;

the matters arising from the certification work qualification letter set out in Appendix C.
Yours faithfully,
PricewaterhouseCoopers LLP
PricewaterhouseCoopers LLP, The Atrium, St Georges Street, Norwich, NR3 1AG
T: +44 (0) 1603 615244 F: +44 (0) 1603 631060 pwc.com/uk
Table of Contents
Introduction..............................................................................................................5
Scope of work ............................................................................................................5
Code of Audit Practice and Statement of Responsibilities of Auditors and of Audited
Bodies ..................................................................................................................5
Statement of responsibilities of grant-paying bodies, authorities, the Audit
Commission and appointed auditors in relation to claims and returns...............5
Results of Certification Work .................................................................................. 8
Claims and returns certified..................................................................................... 8
Issues arising ........................................................................................................... 8
Weaknesses in internal control ................................................................................. 8
Non compliance with regulations/ terms and conditions ......................................... 9
Appendix A.............................................................................................................. 12
Certification Fees .................................................................................................... 12
Appendix B.............................................................................................................. 13
2010/11 Management Action Plan .......................................................................... 13
Appendix C.............................................................................................................. 16
Matters arising from the certification work ............................................................ 16
PwC
3
Introduction
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4
Introduction
Scope of work
Grant-paying bodies pay billions of pounds in grants and subsidies each year to local
authorities and often require certification, by an appropriately qualified auditor, of the
claims and returns submitted to them. Certification work is not an audit but a different
kind of assurance engagement. This involves applying prescribed tests, as set out
within Certification Instructions (“CIs”) issued to us by the Audit Commission, which
are designed to give reasonable assurance that claims and returns are fairly stated and
in accordance with specified terms and conditions.
The Audit Commission is required by law to make certification arrangements for
grant-paying bodies when requested to do so and sets thresholds for claim and return
certification, as well as the prescribed tests which we as local government appointed
auditors must undertake. We certify claims and returns as they arise throughout the
year to meet the certified claim/return submission deadlines set by grant-paying
bodies.
We consider the results of certification work when performing other Code of Audit
Practice work at the Authority, including for our conclusions on the financial
statements and on value for money.
Code of Audit Practice and Statement of
Responsibilities of Auditors and of Audited
Bodies
In March 2010 the Audit Commission issued a revised version of the ‘Statement of
responsibilities of auditors and of audited bodies’. It is available from the Chief
Executive of each audited body and on the Audit Commission’s website. The purpose
of the statement is to assist auditors and audited bodies by explaining where the
responsibilities of auditors begin and end and what is to be expected of the audited
body in certain areas. Our reports and management letters are prepared in the context
of this Statement. Reports and letters prepared by appointed auditors and addressed
to members or officers are prepared for the sole use of the audited body and no
responsibility is taken by auditors to any member or officer in their individual capacity
or to any third party.
Statement of responsibilities of grant-paying
bodies, authorities, the Audit Commission
and appointed auditors in relation to claims
and returns
In November 2010 the Audit Commission updated the ‘Statement of responsibilities of
grant-paying bodies, authorities, the Audit Commission and appointed auditors in
relation to claims and returns’. This is available from the Audit Commission’s website.
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5
The purpose of this statement is to summarise the Audit Commission's framework for
making certification arrangements and to assist grant-paying bodies, authorities, and
the Audit Commission’s appointed auditors by summarising their respective
responsibilities and explaining where their different responsibilities begin and end.
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6
Results of
Certification Work
Results of Certification
Work
Claims and returns certified
A summary of the claims and returns certified during the year is set out below. In one
an amendment was required following certification of the claim and a qualification
letter was required to set out significant issues arising from the certification of the
claim.
Claims and returns certified in 2010/11
CI Reference Title
Form
Original
Value (£)
Final Value
(£)
Amendment
Qualification
BEN01
Housing and
Council Tax
Benefit
Subsidy
MFP720A
33,578,347
33,578,096
251
Qualification
letter issued,
see Appendix
C
HOU21
Disabled
Facilities
Grant
DFG2010D3 345,000
345,000
-
-
LA01
National Non- NNDR3
domestic
Rates Return
20,683,932
-
-
20,683,932
Issues arising
Significant issues were identified which are discussed below.
Weaknesses in internal control
In addition to the issues noted in the qualification letter, see Appendix C, the
following weaknesses were noted.

The Authority did not comply with all required deadlines for submission of
claim forms.
The risks of not addressing these issues and our recommendations for improvement
are set out in the table below.
Internal control issues
Claim/Return
(deadline)
Issue
Risk to the
Authority
Recommendation
Housing and
Council tax
benefit subsidy
BEN01
(30 Nov 2011)
The Authority did
not comply with all
required deadlines
for submission of
claim forms to the
Failure to
comply with
deadlines can
result in
delayed
All claims and returns
should be submitted
promptly and by the
stated deadline.
PwC
8
Claim/Return
(deadline)
Disabled
facilities
HOU21
(31 Oct 2011)
Issue
Risk to the
Authority
grant paying bodies
and appointed
auditor as specified
in the relevant
certification
instructions.
payment of
claims, and
fines for noncompliance.
Recommendation
Similar issues were
raised in the prior
year Annual
Certification Report
2009/10.
Non compliance with regulations/ terms and
conditions
Our work on the Housing and Council Tax Benefit subsidy (“BEN01”) (certification
deadline 30 November 2011) was conducted in accordance with the relevant
certification instructions which requires observations, to be reported within a
covering qualification letter. A copy of the letter can be found in Appendix C.
Whilst fewer matters were noted compared to 2009/10, we did identify a number of
issues requiring attention. The risks of not addressing the issues identified in the
qualification letter and our recommendation for improvement is summarised in the
table below. We have not sought to duplicate the detailed findings which are set out
in the qualification letter here.
Compliance issues
Claim/
Return
(deadline)
Issue
Risk to the
Authority
Recommendation
Housing and
council tax
benefits
subsidy
(BEN 01)
(30 Nov
2011)
Errors were identified
including:
These errors
could have a
financial
impact on
the subsidy
amount
receivable
from the
DwP.
We recommend that
the Authority
considers the
reasoning behind why
the errors identified in
our testing occurred
on a case-by-case basis
and puts in place
appropriate corrective
measures. Such
measures may include:


Expenditure
misclassification;
and
Data input
incorrectly into the
calculation of
benefit
Similar issues were
raised in the prior year
Annual Certification
Report 2009/10.
PwC
Due to the
errors
identified, we
have been
required to
perform
additional

Liaising with
the housing
benefit system
provider
(current and
new provider
9
Claim/
Return
(deadline)
Issue
Risk to the
Authority
Recommendation
testing which
impacts on
the grant
certification
fee.


PwC
when
applicable) to
improve
system
overpayment
identification;
Improving
benefit
assessor
training; and
Increasing the
frequency of
internal
quality review
checks.
10
Appendices
Appendix A
Certification Fees
The fees for certification of each claim/return are set out below:
Claim/Return
2010/11 (£) 2009/10 (£)
BEN01 – Housing and
Council tax benefit
subsidy
55,500
60,000
Fewer errors were identified during
testing in 2010/11 compared to the
previous year. Costs were therefore
reduced as less time was spent
undertaking additional testing,
quantifying extrapolated errors and
reporting the error results.
Comments
HOU21 – Disabled
facilities
1,000
975
-
LA01 – National nondomestic rates return
4,500
2,600
We are required to undertake full
testing (both parts A and B of the
Certification Instruction tests) at least
once every three years. Additional time
has therefore been spent in 2010/11
undertaking part B testing.
Total
61,000
63,575
These fees reflect the Authority’s current performance and arrangements for
certification. It may be possible to reduce fees should the Authority improve its
performance by:
•
Review: improving accuracy of claims/returns submitted for certification
requiring independent review;
•
Documentation: improving working papers and quality of evidence
available to support the claim/return; and
•
Access: improving staff availability during the certification process.
We are happy to discuss how we may assist further with your improvement, for
example we can perform specific focussed, risk-based work in this area should that be
required.
PwC
12
Appendix B
2010/11 Management Action Plan
Claim/Return
(deadline)
Issue
Recommendation
Management response
Responsibility
(Implementation
date)
Housing and
Council tax
benefit subsidy
BEN01
(30 Nov 2011)
The Authority did not comply
with all required deadlines for
submission of claim forms to the
grant paying bodies and
appointed auditor as specified in
the relevant certification
instructions:
All claims and returns should be
submitted promptly and by the
stated deadline. We accept that
in the case of the BEN01 claim
the Authority were awaiting
“fixes” from the software
provider.
BEN01 - as stated the
authority was waiting fixes
from the software supplier
that impacted on the
accuracy of the subsidy
return. Fixes were not
received until 9/6 these had
to be loaded, tested, run on
live and then individual
accounts reviewed and
amended.
31 May 2012
Revenues & Benefits
Manager
Disabled facilities
HOU21
(31 Oct 2011)


BEN01, received 16 June
2011 (deadline 31 May
2011) ; and
HOU21, received 12
August 2011 (deadline 30
June 2011).
Similar issues were raised in
the prior year Annual
Certification Report 2009/10.
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The Benefits software is to
be replaced in 2012/13
which should mitigate such
issues for the 2012/13 return
but not the 2011/12 return
which will be run on the
existing software.
13
Claim/Return
(deadline)
Housing and
Council tax
benefit subsidy
BEN01
(31 Nov 2010)
Issue
Recommendation
Our certification work identified
errors including:


Expenditure
misclassification;
and
Data input incorrectly
into the calculation of
benefit.
Similar issues were raised in
the prior year Annual
Certification Report
2009/10, however overall the
number of issues identified in
2010/11 is a reduction on the
previous year.
PwC
We recommend that the
Authority considers the
reasoning behind why the errors
identified in our testing occurred
on a case-by-case basis and puts
in place appropriate corrective
measures. Such measures may
include:



Liaising with the housing
benefit system provider
(current and new when
applicable) to improve
system overpayment
identification;
Improving benefit
assessor training; and
Increasing the frequency
of internal quality review
checks.
Management response
Responsibility
(Implementation
date)
HOU21 – Diary reminders
have been added to outlook
calendars for both staff
inputting claims information
and those responsible for
final authorisation of the
claim to ensure that the
required timescales are met
for 2012.
Completed
The Benefits software is to
be replaced in 2012/13. The
replacement system deals
more effectively with
overpayment classification.
It is generally a more user
friendly system reducing the
need to re key information
which will reduce errors.
May/June 2012
Project Plan
The system will not impact
the subsidy return for
2011/12. Additional training
on overpayment
classification has been
provided.
Completed
Internal quality reviews will
June/July 2012
Revenues & Benefits
14
Claim/Return
(deadline)
PwC
Issue
Recommendation
Management response
Responsibility
(Implementation
date)
be reviewed as part of the
implementation of the new
system.
Manager
15
Appendix C
Matters arising from the certification work
Matters Impacting the Housing Benefit & Council Tax Benefit Subsidy
Claim form
1. Cell 011: Rent Rebate – Non-HRA -Total expenditure (Benefit
Granted)
Cell Total: £34,253
Cell Population: 52
Headline Cell: £34,253
Testing of the initial sample identified:

8 cases where the Authority had incorrectly used the two room rate
deduction for ineligible fuel service charges (£28.30) rather than the one
room rate (£15.40) as per Table 8.2 of the Guide to Housing Benefit and
Council Tax Benefit 2010-11 (Error Type 1).
This error is dealt with below.
Underpaid benefit (Error Type 1)
Testing of the sample of 12 cases, selected at random from cell 011, identified 8 cases
(total value £4,935.18) where the Authority had incorrectly applied the two room rate
deduction for ineligible fuel service charges (£28.30) as opposed to the one room rate
(£15.40) as per Table 8.2 of the Guide to Housing Benefit and Council Tax Benefit
2010-11. The effect of this error is to understate cell 011 by £455.19, cell 012 by
£300.39, and cell 013 by £154.80.
In accordance with HBCOUNT module 1 guidance for error type 1 “where the error
identified will always result in an underpayment of benefit: additional testing in
this case is not required” as this error will only lead to an understatement additional
testing is not required and has not been performed. The Authority maintains this
error has occurred because the housing department provided the benefits
department with the incorrect allocation.
As there is no eligibility to subsidy for benefit which has not been paid, the 8
underpayments identified do not affect subsidy and have not, therefore, been
classified as errors for subsidy purposes.
Issues with the application of ineligible service charges have not previously been
reported in our qualification letters.
2. Cell 094: Rent Allowances – Total expenditure (Benefit Granted)
16
Cell Total: £24,846,179
Cell Total: £9,405,533 – sub population
Cell Population: 7,662
Headline Cell: £24,846,179
Testing of the initial sample identified:


1 case where the Authority had overpaid benefit as a result of incorrectly
assessing the claimant’s weekly rent liability (Error Type 3); and
1 case where the Authority had incorrectly allocated subsidy to cell 102 when
the landlord was not a registered provider of social housing (Error Type 4).
Each of these error types is dealt with separately below, along with the results from
additional testing.
Overpaid benefit (Error Type 3)
Testing of the initial sample of 20 cases selected at random from cell 094, identified1
case (total value £566.72) where the Authority had overpaid benefit as a result of
incorrectly assessing the claimant’s weekly rent liability. The effect of this error is to
overstate cell 102 by £56.16, with a corresponding understatement in cell 108 of
£56.16; there is no impact on cell 094.
Given the nature of the population and the error found, additional testing was
performed on an appropriate sub population of cases selected from cell 094. The
issue identified in the case described above, occurred because the tenant moved
properties during the period and the rent for a particular Housing Trust was not
correctly selected from the detailed housing rents spreadsheet. We therefore isolated
the sup population to the particular Housing Trust cases.
Testing of an additional random sample of 40 cases from the sub population
identified a further case (total value £1,738,36) where the Authority had incorrectly
assessed a claimant’s weekly rent liability. The effect of this error is to understate
cells 094 and 102 by £799.24 (error type 1). As there is no eligibility to subsidy for
benefit which has not been paid, the underpayment identified does not affect subsidy
and has not, therefore, been classified as an error for subsidy purposes.
The results of our testing are set out in the table below:
Sample:
Movement / Original
brief note
cell total:
of error:
- Sub
populatio
n
(£)
[CT]
Initial
sample - 20
cases
Cell 102 is
overstated
cell 108 is
understated
Additional
No further
sample – 40 overpaid
cases
benefit
exceptions
Samp Sample
le
value:
error (£)
:
(£)
[SE]
[SV]
9,405,553*
56
49,123
9,405,553*
0
122,383
Percenta
ge error
rate (to
three
decimal
places):
Cell
adjustme
nt:
(£)
Revised
cell total
if cell
adjustme
nt
applied:
[SE/SV]
[SE/SV
times CT]
[RA]
17
identified
Combined
Incorrect
9,405,553
56
171,506
sample – 60 assessment
*
cases
of weekly
rent
liability
Adjustment Combined
9,405,553*
(56)
171,506
0.033%
(3,104)
sample. Cell
102 is
overstated.
Correspondi Combined
9,405,553*
56
171,506
0.033%
3,104
ng
sample cell
adjustment
108 is
understated
* Note: This is the total population for the Housing Trust payments made during the year
The percentage error rate in my sample reflects the individual cases selected. The
value of the error found is £56 and the benefit period is 7 weeks. Similar findings
have been included in previous qualification letters.
Given the nature of the population, it is unlikely that even significant additional work
will result in amendment to the claim form that will allow me to conclude that it is
fairly stated.
Expenditure misclassification (Error Type 4)
Testing of the initial sample identified 1 case (total value £2,682.86) where the
Authority had incorrectly allocated subsidy to cell 102 when the landlord was not a
registered provider of social housing. The landlord is a private landlord and the
tenancy commenced prior to 15 January 1989, therefore the subsidy should be
allocated to cell 095 in accordance with helptext guidance. The effect of this error is
to overstate cell 102 by £2,682.86 with a corresponding understatement in cell 095;
there is no impact on cell 094.
The Authority has run a system report to identify any other claims in cell 102 with
this same landlord, and it was determined that this is an isolated exception. No
amendments to the claim form have been made for this issue.
3. Cell 142: Council Tax Benefit – Total expenditure (Benefit Granted)
Cell Total: £9,702,747
Cell Population: 11,162
Headline Cell: £9,702,747
Testing of the initial sample identified:

1 case where the Authority incorrectly assessed benefit as a result of
incorrectly assessing a claimant’s weekly income.
This error is dealt with below.
Exceptional item
Testing of the initial sample identified1 case (total value £1,112.49) where the
Authority had misclassified expenditure. The effect of this error is to understate cell
148 by £2.14 with a corresponding overstatement in cell 144; there is no impact on
cell 142.
18
This claim was unique in that it was an extremely complex claim. The claim was
updated on 8 different occasions during 2010-11 and a further 4 in 2011-12 as work
continued making all necessary adjustments to the claim. It was identified on a
review form received from the customer 23/11/2010 that there had been several
changes to the customer’s circumstances for which the Authority had not been
notified. These were predominantly around wages and tax credits. The Authority
made enquiries to establish all changes and when they had occurred, including
undeclared employment. As a result of this the Authority adjusted income on the
claim back to 31/08/2009. Following this the customer continued to supply further
information regarding their wages to notify the Authority when amounts increased or
decreased. Once all work had been completed, the Authority had re-assessed periods
of the claim a total of 51 times in 2010/11 and received 111 documents from the
customer and third parties to support the income changes. This case is particularly
unusual due to the number of changes which occurred in the customer’s
circumstances, including those previously undeclared, requiring the claim to be
investigated and adjusted accordingly upon receipt of evidence required. The claim
continues to be assessed in 2011/12 and as investigations are ongoing we do not deem
this to be an exception for subsidy purposes in 2010/11 providing the Authority
process the correct adjustments next year.
4. Cell 148: Council Tax – Eligible Error Overpayments (Current Year)
Cell Total: £138,278
Cell Population: 2,313
Headline Cell: £9,702,747
Testing of the initial sample identified:


1 case where the Authority had classified an overpayment associated with the
claim as eligible error rather than Local Authority and technical error (Error
Type 4); and
1 case where the Authority had applied the incorrect dates to an overpayment
(Error Type 4).
These errors are dealt with separately below.
Expenditure misclassification (Error Type 4)
Testing of the initial sample identified:

1 case (total value £987.16) where the Authority had classified an
overpayment associated with the claim as eligible error rather than Local
Authority error. The effect of this error is to overstate cell 148 by £10.01 and
cell 149 by £3.13, with a corresponding understatement in cell 147 of £13.14.
There is no effect on cell 142; and

1 case (total value £1,376.06) where the Authority had applied the incorrect
dates to an overpayment. The effect of this error is to overstate cell 148 by
£0.66 with a corresponding understatement in cell 144 of £0.66; there is no
effect on cell 142.
Given the nature of the population and the errors identified testing of an additional
sample of 40 random cases, selected from cell 148, was performed to confirm correct
19
classification of overpayments and accurate start date of overpayments. This
additional testing identified a further 17 cases (total value £534.38) where the
Authority had incorrectly classified an overpayment associated with the claim as
eligible error rather than Local Authority error or technical overpayments, or had
applied the incorrect dates to the overpayment. The effect of these errors is:

Incorrect classification (net exception): cell 148 is overstated by
£175.07 and cell 147 is overstated by £5.29, with a corresponding
understatement in cell 149 of £180.36; there is no impact on cell 142.

Incorrect dates (net exception): cell 148 is overstated by £3.58, with
a corresponding understatement in cell 144; there is no impact on
cell 142.

Total net exception: cell 148 is overstated by £178.65, cell 147 is
overstated by £5.29, cell 149 is understated by £180.36, and cell 144
is understated by £3.58. There is no impact on cell 142.
The results of our testing are set out in the table below:
Sample:
Movement / Original Sampl
brief note
cell total: e
of error:
(£)
error:
(£)
[CT]
Initial
sample - 20
cases
Initial
sample - 20
cases
Initial
sample - 20
cases
Initial
sample - 20
cases
Additional
sample – 40
cases
Additional
sample – 40
cases
Additional
sample – 40
cases
Additional
sample – 40
cases
Combined
sample – 60
cases
Adjustment
Adjustment
[SE]
Sample
value:
(£)
[SV]
Percenta
ge error
rate (to
three
decimal
places):
Cell
adjustme
nt:
(£)
Revised
cell total
if cell
adjustme
nt
applied:
[SE/SV]
[SE/SV
times CT]
[RA]
Cell 148 is
overstated.
138,278
(11)
18,202
Cell 149 is
overstated.
138,278
(3)
18,202
Cell 147
understated.
138,278
13
18,202
Cell 144 is
understated.
138,278
1
18,202
Cell 148
overstated.
138,278
(179)
1,771
Cell 147
overstated.
138,278
(5)
1,771
Cell 149
understated.
138,278
180
1,771
Cell 144
understated.
138,278
4
1,771
Combined
sample. Cell
148
overstated.
Combined
sample. Cell
147 is
understated.
Combined
sample. Cell
149 is
138,278
(190)
19,973
138,278
8
19,973
0.040%
55
138,278
177
19,973
0.886%
1,225
20
Sample:
Movement / Original Sampl
brief note
cell total: e
of error:
(£)
error:
(£)
[CT]
Adjustment
understated
Combined
sample. Cell
144
understated.
Cell 148 is
overstated
[SE]
138,278
Sample
value:
(£)
[SV]
Percenta
ge error
rate (to
three
decimal
places):
Cell
adjustme
nt:
(£)
Revised
cell total
if cell
adjustme
nt
applied:
[SE/SV]
[SE/SV
times CT]
[RA]
5*
19,973
0.025%
35
Correspond
138,278
(190)
ing
Adjustment
* Rounded up so corresponding adjustments balance
19,973
0.951
(1,315)
The percentage error rate in the sample reflects the individual cases selected. The
value of the errors found range from £0.01 to £54.69 and the benefit periods range
from 1 day to 13 weeks. Similar findings have been included previous qualification
letters.
Given the nature of the population and the variation in the errors found, it is unlikely
that even significant additional work will result in amendment to the claim form that
will allow me to conclude that it is fairly stated.
Other matters
5.
In year reconciliation cells
Per paragraph 22 of the Certification Instructions, cells 037, 076, 125 and 160 should
agree to the entries in cells 011, 055, 094 and 142 respectively. The following
differences are noted:
Claim cell:
094 – Rent
Allowance
£ amount:
Claim –
reconciliation
cell:
24,846,179
125
£ amount:
£ Difference:
24,846,177
2
We have been informed by the Authority that the difference is due to system
rounding.
6. Module 2 – Parameter checks
Per paragraph 12 of the Certification Instructions, we are required to complete
HBCOUNT Module 2. The Authority uses standardised percentage increases to
uprate the parameters within the benefit system on an annual basis. As a result, we
have been unable to confirm that all parameters have been uprated to the amount
specified in Module 2. During testing of individual claimants we agreed all applied
applicable amounts to Module 2 with no exceptions noted. For the claimants tested
therefore, we have assurance that the parameters used in the benefit calculations are
in accordance with Module 2.
21
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