Response HFMA UK
From: Anna Green [mailto:anna.green@hfma.org.uk]
Sent: Thursday, September 19, 2013 7:41 AM
To: Vincent Tophoff
Cc: Carruthers, Ian
Subject: RE: Good Governance in the Public Sector – Consultation for an International Framework
Dear both,
As promised, our Governance and Audit Committee looked at your consultation draft when we met on
Tuesday. Due to time constraints and the overall size of our agenda, we focussed our discussion very
much on the status of the Framework and on the key principles. A number of comments were made that
we hope will be helpful to you as you finalise your guidance:
1. We were unsure about how participating countries are expected to use the framework and
what status it has generally – we assume this will be made clear in the final version.
2. We have concerns that the Framework is too ‘finance focused’ with insufficient attention paid to
quality and ethical behaviour generally.
3. Principle A: We thought it strange to refer to there being a ‘strong commitment’ to the rule of
law as where the law is concerned, compliance is non-negotiable.
4. Principle A: We would expect to see the word ‘honesty’ used in addition to ‘integrity’.
5. Principle E: We felt uncomfortable with the phrase ‘developing the capacity’ as this appears to
us to encourage growth – something we are not convinced is relevant to the public sector. We
acknowledge that the accompanying guidance refers to ensuring that organisations are ‘fit for
purpose’ and would suggest that this terminology is used instead.
If you would like to discuss any of these points in more detail please feel free to get in touch,
Best wishes,
Anna
Anna Green
Technical Editor, hfma
Tel: 01233 820519
Fax: 01233 820519
Website: www.hfma.org.uk
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