Financial Comptroller General Office Assessment on Internal Audit Reform Final Report Consultant Suvod Associates Chartered Accountants Shankhamul, New Baneshwor, Kathmandu-34 Falgun-2071 Table of Content S.N 1. 2. 3. 4. Contents Chapter - 1 1.1. Background 1.2. Legal Provision 1.3. Term of Reference and objective of Consulting Service Chapter - 2 2.1. Importance of study 2.2. Objective of Assessment 2.3. Assessment Methodology and Limitation 2.4. Scope of Assessment and Limitation Chapter - 3 Situation Analysis 3.1. Size of Public Sector and Work Load 3.2. Recommendation of Various Studies 3.2.1.Report of AdministrativeReform commission,2070 3.2.2. Nepal portfolio performance review 2014 3.2.3. Auditor General’s Annual report 2070/2069 (2013 & 2014) 3.2.4. Country Financial Accountability Assessment 2002 3.2.5. Report of Public Accounts Committee on Public Account and Audit,2066 3.3. Analysis of Legal and Policy Arrangement 3.3.1. Provisions of Legislation 3.3.2. Independence 3.3.3.Scope of Internal Audit 3.4. Quality of Internal Audit 3.5. Internal audit organization and internal audit process 3.6. Internal Auditing Standards 3.6.1. Formulation and execution of Internal Auditing Standards 3.6.2. Code of Ethics and Internal Audit Service charter 3.7. Human Resource Management 3.7.1. Qualification and CapacityDevelopment 3.7.2. Approved Post of Human Resource 3.7.3. Lack of opportunity for capacity development of internal auditors staffs 3.8.Forms and Methods of Internal Audit financial transaction under Single Entry Accounting System(STA) 3.9.Suitability of Computer Assisted Audit Techniques in Internal Audit 3.10. Effectiveness of Internal Audit 3.11. Internal Audit Management in Different Asian Countries 3.11.1. Internal Audit Practices 3.11.2.Cooperation and suggestion by Supreme Audit Organization 3.11.3. Situation of Manpower 3.11.4 .Audit of Information and technology 3.11.5 .Status of follow up and implementation of Suggestion Chapter - 4 4.1. Quality of internal audit 4.2. Legal provision regarding internal audit & it’s scope 4.3. Independence of internal auditor Page no 1 1 2 3 4 4 5 6 7 7 7 7 7 9 9 10 10 11 12 13 14 16 16 17 18 18 18 19 20 21 22 28 28 29 29 29 29 30 32 33 4.4. Organization and human resource management 4.5. Organizational & functional model of internal audit 4.5.1. Single or In-house model 4.5.2. Co-sourced 4.5.3. Outsource with in-house management 4.5.4. Fully out sourced 4.6. Problem and Challenges Encountered by Internal Audit Chapter - 5 5. Suggestions for Improvements 5.1 Single or In-house Model for Internal Audit 5.1.1. More legal procedure 5.2. Organizational structure 5.2.1. Organizational Reforms 5.2.2. Proposed organizational structure and management 5.2.3. Proposed Structural of district based Offices 5.3. Internal Audit Standards & Review System 5.3.1. Internal Audit management & Internal Audit Standards 5.3.2. Monitoring of Internal Audit Report 5.3.3 Quality and Working Procedure of Internal Audit 5.4. Human Resource 5.4.1.Internal audit service / Group Formation 5.4.2. Capacity Development of Internal Audit 5.4.3. Review of existing approved Post and Proposed Manpower 5.5. Appropriateness of use of Information Technology auditing methods in Internal Audit 5.6. Internalization of Good Practice Chapter - 6 6. 7. 8. 9. Conclusion Chapter- 7 7.1. Suggestion for implementation Approach 7.1.1. Formation of Steering Committee 7.1.2. Formation of working Group 7.1.3. Coordination & Cooperation with Office of Auditor General 7.1.4. Co-operation with ICAN 7.1.5. Formulation of Strategic Plan 7.2. Strengthening of Internal Audit Annexure References Chapter -1 34 35 35 36 37 37 38 40 40 40 40 40 40 41 41 42 42 42 42 43 43 43 44 44 45 46 46 47 47 47 47 47 47 47 48 49 51 Introduction 1.1 Background In the past, the management of funds and accounts was carried out on adhoc basis during each government system. Particularly, after the introduction of the budgeting system during the year 2008, Comptroller General Office was established in order for checking and record keeping the budgeting system and the funds of the government. In course of the organizational development of present organization, a committee was formed under the chairmanship of Accountant General on 14thShrawan, 2031 with consultation of Ministry of finance, Office of the Auditor General and Department of General Administration. As per the recommendation of the report prepared by the Committee, the cabinet passed a decision on 16thBaisakh 2032 and established the FCGO. Under the Financial Procedure Act, 2055 (1997), this office has entrusted with the responsibility of operation and control of financial administration; issue directives for internal audit and preparation of Nepal government’s Central level Income and Expenditure Accounts. According to the Business Allocation Rules of the Government of Nepal, among the functions to be carried out by the MOF, the tasks of administration and account control of government fund as well as all the functions and duties that is stipulated by the prevailing Acts and laws should be carried out by this office. The functions of the FCGO are performed by its 4 Departments (Administration, Fund, Budget implementation and Monitoring, Evaluation and Analysis. There are 14 different Sections under these Departments. The DTCO office is located in all the 75 districts of the country. 1.2 Legal Provisions In Nepal, internal audit was started after the execution of the new accounting system (F/Y 2018/19) conducting audit of the expenditure by concerned ministry and departments of their subordinate offices. This system was transformed in 2029 by discontinuing the practice of collecting the accounts of government office in the concerned Ministry/Department and gets audited by deputing audit teams of Accountant General. Previously internal auditors were accountable towards Departmental Head or Chief Accounting Officer because of which auditing was considered as the main tool of internal control. In accordance with Government IncomeExpenditure Operation (Working Procedure) Rules, 2038, under the FCGO, the DTCOs were established in 75 districts and these offices were entrusted with the function of conducting internal audit of expenditure, revenue and deposit of government offices. The Financial Procedure Act, 1997(2055) mandated FCGO to operate and maintaining accounts of Consolidated Fund as well as carry out its internal audit. With this provision the structure of internal audit results got legitimized. As per the Rule 96 (1) of Financial Procedure Rules, 2007(2064), DTCOs are empowered to conduct the internal audit of revenue, deposit, appropriation and expenditure of operating level offices and public fund accounts established under the prevailing law which has extended the scope of internal audit. 1.3 Terms of Reference and objectives of Consulting Service As per the work order to consultant the main objectives of the assignment were to: 1. Identify the gaps of internal audit in order to develop the internal audit as a reliable tool for monitoring with respect to sufficiency of internal control system of Government of Nepal. 2. Find out quality and coverage including other area and its working practices in internal audit. 3. Recommendations for institutional arrangements, organizational and operational modalities for strengthening of internal audit. 4. Other objectives were as follows: A. To identify potential internal audit structures and modalities of internal audit of financial transactions in the context of introduction under Single Treasury Account (STA). B. To reports on application of CAAT and IT audit in internal audit. C. Assist in introducing internalization of good practice in the field of internal audit. This assessment was conducting mainly focusing on the above TOR. Chapter -2 Importance, Objectives, Methodology, Scope and Limitations of Assessment 2.1 Importance of study So far as the strengthening of professional development is concerned no in depth study has been conducted neither by the government nor by Development Partners (DPs). Internal audit is a tool which supports in the risk minimization in relation to public financial management, improvement in the internal control methods and administrative methods. It also helps in achieving the aim of an organization and fulfillment of the responsibility of management. In the reports of study on public expenditure management, instead of detailed recommendation about need of improvements in internal audit system have recommended in brief. This fact is also proved from description given for policy arrangement in Chapter 3 of this report. The main task of the internal audit is to assess compliance with financial administration, to minimize the risks factors and advice those charged with management to strengthen internal control system and aware them. The effective execution of this task depends upon different factors, but the factors given below are considered as the main basis which clarifies the role of the internal audit. • Ensure the independence of internal audit. • Communicate management appropriately and proactively • Implementation of recommendation. The present context of government public financial management also shows the importance of internal audit, proactive awareness and its contribution. However, the Chief Accountable officer and Responsible Officer have not recognized these realities. 1. Performing the task of internal audit by considering the increasing size of budget, diversity of program and their complexities. 2. Contribute in use of external source and compulsions of adherence with the conditions imposed by Donor Agencies. 3. Support minimization of increased volume of irregularities and their nature pointed out by external audit. 4. Support final audit to focus their endeavors on performance and risk based audit. 5. Create the situation of preparing the accurate Financial Statement in time. 6. Internal audit helps the management by pointing out weakness of the financial management in time in order to take reformative measures. With the increased volume of budget structure and complexities management of economy there is increased interest in transparency and accountability in the use of public resources among the stakeholders. In this situation, management of internal audit and enhancement of professionalism and capacity building of the auditors have become are indispensible. If such arrangement could be managed then the capacity of the resources as well as the effectiveness of its utilization will also insured. Similarly the internal audit can also contribute to management in minimizing the risks associated with the use of public resources and mitigate the problems; it is required for institutional restructuring and management of internal audit. A study was conducted by FCGO in 2070 (2013) and prepared report for the structural improvement of internal audit. But it was felt that the importance of the assessment may increase if such assessment is conducted by a third party audit experts in line with international practices and values that may be a basis for institutional development and make the audit more qualitative. 2.2 Objective of Assessment The FCGO conducted a study on internal audit in 2070 by forming a Working Group. The Working Group in its report has recommended to form a service group of internal audit by separating the function of budget disbursement or integrate it in Departmental structure under three different models. In this connection, this independent assessment was conducted carried out for the purpose of identifying the positive and negative aspects of three models and suggest alternatives of each model. As per the TOR mentioned in the paragraph 1.3 the consultant carried out the assessment in focusing areas as mentioned below: • • • • • • To find out the weaknesses in quality, scope, working methodology and practices of internal audit, To identify the gaps to develop the internal audit as a reliable tool of internal control system, To suggest organizational structure, management and operational modalities to strengthen internal Audit, To suggest potential system and methods of internal audit of financial transactions in the context of Single Treasury Account system (TSA), To recommend the application of CAAT and IT audit, and To Internalize of good practice in internal audit domain. 2.3 Assessment Methodology and Limitation In course of assessment, the following methods were used considering the TOR to the consultant and applied the approach as stated in overview report. 2.3.1 Reviewed available documents and records, 2.3.2 Review extant Act, Rules and organizational structure including prevailing practice of internal audit in the context of TSA system, 2.3.3 Information and statistics were collected through questionnaire from 20 government office from three geographical regions including Kathmandu valley. In this process statistics were collected from 11 offices in Kathmandu valley and 9 from outside the valley and were evaluated the information. The questionnaire used during the assessment is given in the Schedule -2 of this report. 2.3.4 Three DTCO located in valley and Account Officers of some government organization were interviewed. Due to the lack of time and cost involved only 20 offices were covered for field study. Adequate information and statistics couldn’t be obtained from the offices that were visited. Discussion couldn’t be held with some of the officers so the assessment was limited to the information whatever obtained from the offices. During the assessment, statistics of 11 offices from valley and 9 from outside valley were collected and assessed to complete the assessment. Information and statistics collected through various methods was synthesized and evaluated based on the strength and weaknesses including opportunities and challenges so as to determine the areas of improvement and suggested work plan and recommendation in the report accordingly. 2.4 Scope of Assessment and Limitation As per the agreement the this assessment covered the areas such as quality of internal audit, its weakness, methods of internal audit along with possibilities of initiating IT audit in the context of TSA system. This assessment also covered the available information for the period of 2067/68-2069/70 including 2070/71 was also covered in the scope of assessment. In the scope 6 DTCOs from valley and outside the valley and 14 other offices were also covered for assessment purposes. The information was collected from various offices through questionnaires but some of the offices did not provide the requested information due to which no assessment could be conducted of those offices. Chapter - 3 Situation Analysis 3.1 Size of Public Sector and Work Load With the increased volume of budget the income and expenditure of Nepal has also been subsequently increased in the same proportion. As a result, there is not only increase in volume of work of PFM but also the complexities and risks associated with it are also increased. Similarly the conditionality of foreign assistance to be complied with and eroding level of internal control the work load of internal audit has also increased. With the manifold increase in size of the budget the demand of the Parliament, oversight bodies, civil societies & media with respect to transparency, accountability and effectiveness in service delivery in the use of public resources has also increased. Due to this, there has been more pressure on public financial management to confirm these aspects and ensure the stakeholders. In this context, skilled and motivated staff, code of conduct, standard operational procedures (SOP) and arrangement of training and resources is required to improve this situation. With such improvement, internal audit could play significant role in timely communicating to those charged with management regarding the weaknesses with respect to compliance with Acts & Rules, uses of the resources through its report and uphold the fairness of financial administration and initiate reformative measure in effective delivery of services proactively. However, considering the prevailing laws and regulation; organization & management; working practices; manpower; and attitude of management towards internal audit, the internal audit seems unable to contribute in the aforementioned areas. With the analyses of the information given table below and the recommendation given in the Annual Reports of Auditor General; Country Financial Accountability Assessment and PEFA Assessment conducted by Development Partners (DPs); and Working Groups formed by FCGO have recommended various suggestions to strengthen internal audit. But no organizational and professional improvements are visible as expected. Fiscal year, Number of government entities & audited amount (amount in lakhs) Particulars 2069/070 Number of Audited Entities Amount of 3744 8,04,85,73 Number Government Entities Number of 92 Corporate Bodies Committees 805 and other 2068/069 Number of Audited entities amount 3708 7,42,59,43 2067/068 Number of Audited Entities amount 3796 5,27,56,08 11,36,87,67 88 9717904 69 7,78,66 69,27,31 901 62,61,56 649 37,34,81 Organizations District Development Committees 75 74,79,39 73 68,15,92 75 31,85,05 Source: Annual Reports of Auditor General In the view of increased size of budget, number of offices, expectations of stakeholders, existing organizational structure and management, manpower and available resource to internal audit it seems difficult to perform audit principally and practically the assigned task. 3. 2 Recommendations of Various Studies In order to improve the internal audit which is a major tool of internal control system of public financial management, various Commissions and Working Groups were formed in time to time and they recommended various policy prescription and suggestions in the past. The recommendations made by various Commissions and Annual Reports of Auditor General with regards to internal audit are given below. 3.2.1. Report of Administrative Reform Commission, 2070 Internal audit which is carried out by the DTCO, can be made effective by establishing the departmental structure or by forming separate sub groups The Ministry of finance should focus in capacity development of overall economy through strong fiscal and financial management for sustainability and achieving broad and high economic growth. The DTCOs should be given the task of Internal Revenue Department in those districts where the number of tax payers is trivial. 3.2.2. Nepal Portfolio Performance Review, 2014 Internal Audit –A proposal has been proposed in internal audit reform in Nepal. A three steps model is proposed by the FGCO delink same from budget release and internal audit separate audit cadre or departmentalization of audit function. A action is taken by FCGO to delink those people conducting internal audit who are engaged in budget release of the same office. 3.2.3.Auditor General’s Annual Report 2070 &2069 (2013&2014) The Annual Reports of Auditor General 2069 and 2070 mentions that Rule 96 of Financial Procedure Rules, 2064, empowers DTCOs to conduct internal audit of financial transactions of all government offices, however the internal audit has not been effective due to the following reasons. • • • • • Annual Report of Auditor General 2070 (2014 ) 2069 (2013) Inadequate manpower to conduct internal • The study conducted this year 56 DTCOs have audit adequate staff for conducting internal audit Insufficient training opportunity available • Unrestricted access to information to internal audit to the manpower who engage in audit to conduct the work The audits are carried out without Audit • Non-availability of Training opportunity to the Plans and Programs manpower who engage in internal audit Audit is not conducted in accordance with • Audit files of district level offices are not the Internal Audit Directives, 2068 maintained properly Situation of checking arithmetical accuracy • The audit is carried out without preparing entity level by final audit because the internal audit has audit plans and programs not pointed out the irregularities in • Audit is not conducted in accordance with the majority of offices Internal Audit Directives, 2068 • Lack of supervision of audit procedures applied • Audit is not carried out on trimester basis • It is noticed that mostly audit irregularities are not pointed out by internal auditors whereas final audit has pointed out irregularities • Based on the above situation internal audit seems not qualitative and reliable In addition to the above the reports mention that fully owned Committees, established under Committee Development Act, 2013, Projects and various autonomous bodies etc. hire service of external experts to carry out internal audit. But such services are taken only after the close of the fiscal year due to which the objective of the internal audit found unfulfilled. In accordance with the Self Governance Act, 2055 there is permanent mechanism in the District Development Committee in order to conduct internal audit of local bodies including DDCs itself and district level offices of devolution program. But the internal audit those entities are being done just for sake of audit due to non-application of fundamental audit procedure and lack of trained manpower. Since there is no mechanism to conduct internal audit of Community Schools a chunk of public fund remains out of the purview of internal audit and it has been difficult to develop it as a management control tool. Similarly these reports have given several suggestions with regard to internal control but the internal audit has not been able to support in making internal control effective by checking the regularity of financial transactions of the government entities. The final audit in its reports has mentioned that it is forced to confine in checking the regularity aspects due to above reasons. So it has suggested to take reformative measures such as organizational restructuring, adequate legal provisions, enhancing capacity building, methodology development etc. to strengthen internal audit. 3.2.4. Country Financial Accountability Assessment (CFAA), 2002 In course of CFAA assessment done by the World Bank in Asia and Africa during the period 2002-2005, it identified the areas of improvement in internal control and audit. The following are the details mentioned in the CFAA Report, 2002 carried out by World Bank in Nepal. • Internal audit really assess internal control or recommend improvement. Normally it examines whether or not prescribed legal provisions are being followed. • Internal audit is not effective as it might be due to large number of accounting and payment centers relative and the limit of internal and role to transaction checking. 3.2.5 Report of Public Accounts Committee on Public Accounts and Audit, 2066 Several studies have been carried out in public accounts and audit in the past. In the report it is mentioned that due to laxity in the implementation of suggestions, the expected improvement has not been made in financial management of Government of Nepal. Unless measures to develop the organizational capacity building of the bodies responsible for oversight are not undertaken by initiating sustainable efforts so as to enhance the capacity and skills of the manpower in such organizations it seems difficult to improve the public financial management. In this connection, these assessment reports have identified several problems in the PFM and recommended suggestions to make financial governance fast, updated and accountable. In connection with implementation of recommendations, initiation for amendment in the legal provisions needs to be taken by the concerned entities. But the Committee has not given detailed implementation structure by obtaining the recommendation from responsible body along with work plan. The Public Account Committee has recommended the following suggestion. • The internal audit should be delinked from the DTCO and create a separate Unit under FCGO to perform the task. • To develop career development of Internal Audit • To develop Internal Audit Standards • To develop Internal Audit as a management information system • To make Internal Audit mandatory in public sector • To settle the audit irregularities pointed out by internal audit within 2 months by related office or ministry and department • To settle the audit irregularities raised by the internal audit before the submitting the books of accounts for external audit In general, most of assessment reports have suggested undertaking the measures such as organizational restructuring including capacity development, training, extension of scope of work etc. in order to strengthen the internal audit. 3.3. Analysis of Legal and Policy Arrangement Even after the more than 3 decades of inception of internal audit system in public financial management, it has not been performed as per the spirit of the legislation. This situation has been also proved from comments revealed from the different study reports and Annual Report of Auditor General. In the view of the legal provision, internal audit management and its implementation, organization and human resource management, monitoring etc. including international practice relating to internal audit there is lot of room for improvement. The substantial difference can be noticed if the current internal audit practice is compared with the internal Auditing Standards of Institute of Internal Auditors. While categorizing different aspects of international practices of internal audit and the current practice in the country, the following weaknesses, strength, opportunity and threat can be seen. 3.3.1. Provision of Legislation Financial Procedure Act, 2055; Financial Procedure Rules, 2064; the audit procedures prescribed by FCGO; internal audit directives and Service Code of Conduct are the source of legal provisions which are related to internal audit. Strength • • There is legal provision in the FPA, 2064 of getting internal audit conducted by the entities DTCOs have been charged with the responsibility of conducting internal audit of the revenue, deposit, income and expenditure of appropriation and the operational or other public funds established in accordance with the prevailing law. • Conduct internal audit in accordance with the procedures prescribed by Internal Audit Directives • Section 16,17 and 26 of FPA, 2055 have specified to take action or penalize based on the audit finding of internal audit against the concerned person responsible for any act of loss or damage sustained by the Government of Nepal. Weaknesses: • The mandate of Internal Audit does not cover entire public sector like Municipalities, VDC, Organizations established under Development Committee Act, 2013 etc. except District Development Committee (devolution programs). • Internal audit is limited to the areas as specified in the Rule 96(2) of Financial Procedure Rules, 2064, The legislation does not specify the procedure or methods of internal audit. • • Even after the implementation of TSA the Financial Procedure Act and Rules have not been amended. • The legislation is silent about the access to information to internal audit. • In cases where the irregularities detected from the internal audit cannot be settled by procuring evidence thereof prior to the final audit for any special reason, a written explanation also setting out that mater shall be given to the final auditor. But the provision of not to take action after final audit on irregularities raised by internal audit seems against the spirit of the Act. Opportunities and Challenges: Checking of various requirements such as the compliance with the Procurement Act and Rules thereon; budgetary procedures; amendments made every year in Finance Act; conditionality of the projects implemented under external resources are some opportunities and challenged to internal audit. The prevailing FPA and Rules thereon gives authority to internal audit to conduct regularity and performance audit however, it is challenging to perform audit accordingly. The legislation gives authority to conduct audit as mentioned above but if not implemented as per the authority it cannot contribute to PFM. 3.3.2. Independence External audit is kept independent from the management objectively so as to enable them in selecting transaction,subject and have adequate access to information for conducting audit independently and free of bias. Likewise for the effectiveness ofcompliance with basic elements of internal audititrequires to be accorded organizational and functional independence from management. As IIA has defined IA in international Standards for the Professional Practice of Internal Audit has defined internal audit as “Internal Auditing is an independent, objective assurance and consulting activity designed to add value and improve an organization’s operations.it helps an organization accomplish its objectives by bringing a systematic, disciplined approach to evaluate and improve the effectiveness of risk management, control and governance process”. According to the above definition, internal auditors provide advice in the operation of organization including objective and independent assurance which enhances value of the transaction. Internal auditing supports in organization. Operational process evaluates effectiveness of risk management and control in contributing for applying disciplined approaches considering the existing organizational structure,audit practice etc. FCGO needs further improvementsin conducting internal audit independently. In the present context, the status of independence engaged by internal auditing is as follows: • • • • • Financial procedure Act, 2055 and Financial procedure Rules 2064, is silent regarding the independence of internal auditing. According to the Central level organizational Chart of FCGO and sub-ordinate office, internal audit is kept as section. Staff serving in DTCOs is engaged in dual responsibility of accountskeeping andinternal auditing. Due to the involvement of colleagues in accounting and internal auditing for a specific period, the internal auditors might unable to perform their task unbiased manner to maintain cordial relationship with each other. Laws and Directives do not clearly specify whether internal audit report is to submit to chief accounting officer or responsible person. 3.3.3. Scope of Internal Audit According to Rule 96(2) of financial procedure policy, 2064, while performing the internal auditing of income & expenditure of offices, DTCOs need to focus on the following matters: • • • • • whether the income and expenditure of Office and the accounting thereof are maintained in consonance with the prescribed procedure or not, whether the financial resources are used in an economical, efficient and effective manner or not, whether the goal as per the approved annual program has been achieved or not whether the internal control system is effective or not, Whether the financial statement give true and fair view of transaction or not Other than above mentioned matters, internal audit need to consider the process mentioned by FCGO in course of checking. The Financial Procedure Act, 2055 and Financial Procedure Rules, 2064 has specified the scope of work of DTCOs to conduct auditofthe revenue, deposit, income and expenditure of appropriation and the operational or other public funds of office established in accordance with the prevailing law. Considering the above scope of it appears that checking of accounting and compliance with process stipulated by Acts and Rules i.e. regularity/compliance audit needs to be conducted. Also, in the context of utilization of financialresources,the aspects of economy, efficiency and effectiveness is to be considered i.e. means performance audit is required to be carried out. While analyzing above scope of work specified by the legislation following types of audit needs to be under taken by internal audit. Regulatory Audit • Performance Audit • Financial Statement Audit To a large extent Internal Audit is performing regularity /compliance audit of public entities which come under the work scope butit has been conducted with the perspective of performance audit. In case of Financial Statement audit it appears satisfactory. However, internal audit has not been undertaken from the view of credibility of volume of transaction, completeness of accounting of transaction of the central accounts, Consolidated Fund loan investment which depicts overall position of financial transactions of the country In the viewoflegal provisions, practically the entire public sector does not come within the scope of internalaudit.Its main function is confined in budget release and it would have taken its nature as a basis. Although within the scope of work of internal audit of local bodies which come under Local Self Governance Act, 2055, Development Committee Act, 2013, Committees formed under Special Act and administrative decision, community school as well as government universities under District Education Office does not come under audit purview of Internal Audit. 3.4.Quality of Internal Audit In relation to internal audit management, Rule 96(2) of Financial Procedure Rules, 2064 specify to conduct internal audit of income and expenditure and focus on five points. Considering the provision of the legislation the internal audit is required to conduct the audit of regularity, performance and completeness of financial statement. In addition to this, the internal audit Directives has defined the terms such as objective of audit, methods, procedures, risk assessment, check list, reporting, follow up etc. Legally, instead of specifying the rights and duties of internal audit the CAO and Responsible Person have given duty and made them responsible for accounting of transaction and get accounts audited from internal and external auditors. Rule 45 of financial Procedure Rules, 2064 specify to see 19 points in order to assure the reliability of income and expenditure, forexample whether accounts have been maintained in prescribed format, financial transaction comply with prevailing laws, sufficient evidence of income and expenditure is kept, records of government property is complete and updated as well as appropriate use of property etc. The above mentioned points are similar to the 15 points stated in Section 4 of Audit Act 2048. The Internal audit Directives 2068suggest on checking of revenues and expenditure rather than focusing on overall audit management. The international practices suggest about the audit management but in the absence of separate Internal Auditing Standards it lacks proper management and its professionalism. In accordance with the International Auditing Standards on Internal Audit the audit management includes the following stages: • Preparation of Audit plan • Audit Execution and Evaluation • • Communicating audit result Follow up The above stages suggested by internal auditing standards are followed while conducting the audit. On the basis of internal auditing standard the aspect of the control environment of entity being audited, risk assessment, selection of audit procedure, mobilization of skilled human resources, etc. are followed in audit. Such internal audit only can provide substantial contribution to PFM in the use of public resources. But the internal audit procedure adopted by DTCOs does not meet the minimum standard of auditing. On this basis audit performed by DTCOs it is of low quality. Other fundamental aspects affecting the quality of internal auditing is described in other paragraphs. 3.5 Internal audit organization and internal audit process Audit is established as a section under a Monitoring, Evaluation and Analysis Department.Though the departmental head is assigned to officer of joint-secretary level officer, the organizational structure shows that second class gazette officer is the head of audit section. The officer level staff is transferred on the basis of civil service Act and transfer policy with the period of two years.However assistant level staff of DTCOs is found to be serving in the same office for more than the stipulated time. The audit process adopted by DTCOs is depicted in the chart below: Internal Audit Operating process Internal Audit Plan Entry Meeting Conduct of Internal Audit Submission of Internal Audit Report • • • • Selection of audit staff Issue Authority letter for audit Discussion on main issues to be audited Deadline Internal Audit execution • Meeting and discussion with organization head and accounts head. • Audit of books accounts • Prepare working paper/notes on diary • Discussion during internal audit Submit internal audit report • Prepare Draft Report • Discussion between internal audit head and audit team • Communication to Chief Treasury and Comptroller • Issue internal audit report Follow up Reply and Follow up on Internal Audit Report • Response from the audited organization • Request for Follow up (Re-verification) • Communicate audited entity about audit results • Observation reported in Internal Audit Report becomes null once final audit is conducted Although the internal audit is conducted by DTCOsby following the above process but it is not documented except limited documents such as audit authorityletter documents related to follow up audit only. No audit file is maintained regarding the audit process followed. Generally junior level staffs are deputed to carry out the internal audit of offices. But, the report is communicated to concerned offices by the officer level staffs. Records regarding the internal audit activities applied are not kept properly. So, the information regarding which auditor has performed the audit of particular office showing audit commencement and completion date, the time for submission of report after the completion of audit is not supported by any documents. When asked DTCOs regarding the frequency of internal audit conducted, two DTCOs replied internal audit is done every 2 months whereas other 5 offices told on quarterly basis. 3.6 Internal Auditing Standards According to international and national practices, separate internal and external auditing standards are formulated and implemented so as to conduct audit work professionally, to maintain quality and reliability. The main objective and use of internal audit standard can be mentioned as follows:• Establishing the fundamental principles of internal audit • Contribute to the operations and reform process of entity being audited • Establish basis for assessment made by internal audit and directs to formulating reform plan In various nations, there are separate laws, organizational and procedural arrangements are madefor conducting internal audit of public sector.In our context, except the provisions related to internal audit is specified in Financial Procedure Act and Rules thereon, the FCGO conducts audit on the basis of Directives which was formulated for the first time in 2055 which has been revised in 2063 and again in 2068.There is no national internal auditing standards in Nepal. In the process of this assessment 6 DTCOs accepted absence of internal auditing standards. 3.6.1 Formulation and execution of Internal Auditing Standards The Financial Procedure Act, 2055 and Financial Procedure Rules, 2064 have empowered FCGO the right to perform internal audit. In the view of the legal provisions, to some extent the compliance audit, performance audit and audit of completeness of accounting and financial statement based on the values and practice of public sector audit (final audit). The internal audit does not cover the entire public sector.The audit activities such as audit plan, execution, reporting, monitoring, documentation, follow up, quality assurance, etc. are not seen in the official records. The internal audit Directive does not mention the procedures of carrying out the Internal audit of the areas such as appropriation,head wise expenditure, project assisted by foreign resources,Operational Fund,accounts of inventory, revenue and deposit, etc. The Directive suggests focusing on the points regarding checking of information mentioned in Auditor General's Forms (OAG Forms) like checking of expenditure in line with budgeted head and points to be considered whileconducting audit of revenue and records maintained etc. There is neither any practice of keeping the records of internal audit activities nor maintain separate audit file for it. In the situation, where there is no national internal auditing standards developed in line with the values of international standards the audit so conducted by complying the process of the provisions of legislation and as suggested by Internal Audit Directives including checking of arithmetical correctness it is not sufficient to assure the quality of internal audit. Since internal auditing is limited to the formal provision of legislation and not conducted as per the generally accepted objectives of internal audit resulting no value addition through internal audit.The management is of the view that internal audit is unable to play collaborative role in providing quality report in time for initiating reform measures except legal backing. Due to these reasons the external audit is limited to performing audit similar to the nature of internal audit due to which it is unable to mobilize sufficient resource in high risk areas and in performance audit. 3.6.2 Code of Ethics and Internal Audit Service Charter The Civil Service (administrative service) staffs are engaged in the task of internal audit work. The staffs are transferred, promoted and action taken pursuant to the provisions mentioned in the Civil service Act and Rules thereon. There are no extra provisions for Code of Conduct for the staff engaged in task of special nature of accounting and internal audit as good practice.Section19 of Prevention of Corruption Act, 2059 stipulates that whoever, either a public servant or any other person authorized to carry out auditing in a government body or in a public institution, prepares auditing report with mala fide intention having shown the facts not done or happened in the transaction or having concealed the facts done or happened, shall be liable to a punishment of imprisonmentdepending on the degree of the offence committed. These provision are applied to public and private sector auditor hence it inspires to conduct internal audit with due care and submit fact based report. But whether the audit is conducted by complying COE and systematically is out of its scope. As per the international best practice there is provision of Service Charter for internal auditors. Mainly the rights, duties, functions of the internal audit, reporting requirements and the service provided are mentionedin the Service Charter. Internal audit has been accorded less importance in the Service Charter published by Good Governance Act, 2063 to the FCGO. 3.7 Human Resource Management Capable manpower is required for smooth & efficient operation of any organization. In order to achieve its organizational goal, and appropriate to its work nature the organization should manage skilled, capable& knowledgeable human resource. For this, the organization should develop job description for every level of staff and formulate HR plan so as to carry out capacity development activities and ensure its implementation. The following are the related points: 3.7.1 Qualification and Capacity Development From the entry to administration level in accounts department of gazette and non-gazette service, the minimum Qualification required is knowledge on management, economics, statistics and mathematics. If the applicants belong to other streams than management, then he/she should be given long training recruitment. Recruitment training facilities are available only to officer level employees not to assistant level employees. CPE for internal audit employee's annually level is a must. Due to the many like obstacles change in technology, differed expert opinion, lack of knowledge of international accounting practices internal audit is unable to provide expected service. The minimum CPE required to the staff involved in internal audit is not assigned and they hardly get morethan one training at one level. This has resulted in compromising in the quality of internal audit. For e.g. employees of the OAG should receive 18 hours of training in a year compulsorily, also as per the provision mentioned by Institute of Chartered Accountant of Nepal (ICAN) ,its members in practice must complete a minimum of 20 credit hours for their COP(Certificate of Practice) to be renewed. Internal auditors are not compelled to the above provisions. To perform the internal audit as per legal provisions and to perform work as per responsibility, internal auditor lack skill, knowledge and experience. This is all because of lack of strong provisions regarding internal audit. This can be visualized by going through the internal audit report. This is one of the main reasons that the entities being audited are negligible towards internal audit report. 3.7.2Approved Post of human resource According to the organizational structure of the FCGO, the existing number of employees in various positions is 5027 .Among them 1037 are employees posted in DTCO, out of which 313 are assistant level staff Position wise status is as follows:Position First- class Second-class Third class Assistants Total Gazetted 2 49 88 139 Non-gazetted 327 252 313 892 Total 1031 In reality the statistics of human resource engaged only for internal audit task is not available. Some of the strengths as well as weaknesses of organization and human resource management are as follows:- Strengths • As per the Annual Report, 2068 of Auditor General ,there is sufficient human resource for internal auditing • DTCO have presence and access of internal auditing in every district • Despite the absence of Internal Auditing Standards, there is availability of Internal Audit Directives Weaknesses • Majority of staff involved in internal auditing are of non-gazette position • No segregation of duties specifying the function of staff for internal audit and accounts keeping • Due to the regular transfer of staff , they are unable to develop professionalism perform in their roles respective areas • Lack of human resource planning for professional development. According to the AG’s Annual Report, 2068, the sanctioned posts in terms of number of staff in the DTCOs have available for carrying out internal audit.Availability of adequate staff in terms of number as well as qualified, capable and opportunities for capacity development are also important for quality audit. For this purpose the existing human resource management is needed to be reviewed.From conducting such review strengths and weaknesses related to human resource including duration, nature and level of training need are to be identified. In course of assessment the DTCOs were asked the about the impediments for regular internal audit and all six DTCOS are of the opinion that skilled human resource as main impediment. In this context of need assessment, the aspects related to internal audit such as objectives, legal provision , code of conduct, reward system for motivating employees also need to be taken into account seems to be . 3.7.3 Lack of opportunity for capacity development of internal auditors staffs Human resource development plan is required for capacity development. The plan should include capacity development, transfer, requirement of training of CPE credit hours for staffs etc. For this purpose government training center as well as foreign training institute and appropriate budget accordingly. The lack of skilled manpower results in less qualitative work. Theconditions given below indicate the need for capacity development of staff who is involved in internal audit. • Even though the internal audit report does not mention new irregularities but the final audit report has point out irregularities. • The internal audit report points out mainly the issues of non- compliance and recoverable however it rarely points out about system, internal control and management of office/project/program. • The mentioning about the reason for irregularities of irregularities for example amount of irregularities brought forward from last year, settled and addition in amount during the current year and it effects • The internal audit report does not give consolidated position • It does not examine economic efficiency and effectiveness of transactions. 3.8 Forms and Methods of Internal Audit financial transactions under Single Entry Accounting System(STA) The government has introduced modern fund management system in order to make financial and expenditure management including cash management function simple transparent and development financially. The main purpose of introducing STA on 15thMagh, 2065 as per the decision of Government of Nepal was to make existing public fund management effective. All the amounts collected in cash by the government can be transacted through banking channel so as to reduce the cost of loan, maximize its use and make payments of expenditure on time. Since STA is web based and it also helps government agencies to get info on revenue and expenditure immediately and easily which facilitates to prepare financial statement. It helps in effective monitoring and evaluation of budget on expenditure which can be taken as its positive aspect of this system. However,in the situation where the DTCOs are linked with the banks and interconnected with web, it is the precondition to install a powerful communication capacity and server system for accounting and reporting purposes. IT based accounting system have various risks for which skilled ITpeople only can identify the measures to address such risks.Therefore, posts should be approved posts to recruit IT staff with qualification and filled in the Accounting Service Group. Presently all the post approved in DTCO has not been filled. In such situation payment is being made simply on the request of district level officer by conducting normal checking or return for justification. Since the internal audit of the transaction is to be conducted by this office and same staff due to which there is the situation of conflict of interest. Documentary Audit is suitable for single treasury accounting system since it is web based and all the documents related to transaction are kept by the paying offices themselves. But Information Technology Audit can be used in relation to single accounting system for the budget release compilation of expenses, central account and reconcile the transactions with NRB or with other banks, etc. initiation of formulating IT audit policy is required for the use of audit software in future is appropriate in accounting and conduct internal audit based on CAAT. Under the Single TreasuryAccounting DTCO are maintaining amount of budget disbursed to various offices in computer system. This has facilitated to obtain information with respect to budget disbursed.Under the STA system, DTCOs disburse budget and collate the payments made by itself while conducting internal audit which appears to be conflict of interest, in this connection a question was asked during this assessment about such conflict of interest but all of them dispread this possibility saying check is issued on the request of entities .OAGN also agrees this statement. From this, actual expenses incurred till date can be identified. 3.9 Suitability of Computer Assisted Audit Techniques in Internal Audit It has been more than a decade since the introduction of maintaining information with regards financial transactions which requires qualified on IT systemin the FCGO. At present FCGO and DTCO are maintaining web based accounting of TSA. CAAT is considered as one of the best audit tool for computer based accounting, auditor with skills and competence as well as computer based information nature of hardware and software, preparation of report, techniques of operation, system logic under EDP environment audit, the overall objectives, scope and level is similar to general audit. But it is different in audit process.Generally CAAT includes two ordinary techniques which are: I. Audit Software II. Test Data Under this the auditor uses software to process the statistics of accounting system used by the different organizations to be audited. Under this: a. Package programmer – These are generalized computer programs designed to perform data processing functions which include reading computer files, selecting information, performing calculations, creating data files and printing reports in a format as specified by the Auditor b. Purpose-written programs- These are computer programs designed to perform audit tasks in specific circumstances. These programs may be prepared by the auditors by the organizations or by a n outside programmer engaged by the auditor. c. Utility Programmer – These are used by the organizations to perform common data processing functions such as sorting, creating and printing files. These programmers are generally not designed for audit purposes and therefore, may not contain such features as automated record count or control totals. I. Test Data These techniques are used in conducting audit procedures by entering data (e.g. a sample of transactions) into the computer system of the organization and comparing the results obtained with pre- determined results II. Other Types of CAAT Integrated Test Data Fancily Tagging and Tracing (TT) Mapping Concurrent Processing Parallel Simulation (Defining the application function, understanding the topic, executing the simulated system and calculating the derivation from the original results) Control Processing At present, CAAT is not applied in public sector auditing. But since last few years, the OAGN has started information and technology audit. International Organizations of Supreme Audit Institution has pronounced a separate audit guide for IT audit. With the introduction of IT,FCGO has also to take some initiatives to develop infrastructure for IT audit. From this FCGO can seek support and suggestion from the OAGN. 3.10. Effectiveness of Internal Audit In public financial management, budget is being allocated for carrying out development of construction project program and for their execution. However anomalies such as under spending of allocated budget, and rush in expenditure in last month of fiscal year rather than proportionate spending in each trimester, trend ofvirement at the end of fiscal year, increased volume of irregularities etc. are prevalent every year. In this context, there is room for internal audit to paly vital role by highlighting anomalies such as to aware of management in time.So it is appropriate to analyze the performance of internal audit compared to international and good practice in PFM. Internal Auditors has conducted global research on effectiveness of internal auditor. A global assessment based on the IA & Global Internal Audit Survey has identified nine elements. • Organization independence • A formal mandate • Unrestricted Access • Sufficient funding • Competent leadership • Objective staff • Competent staff • Stakeholders support • Professional Audit standards While comparing the effectiveness of internal audit performed by the DTCOs in relation to the nine elements identified by the research carried out by IIA, the scenario emerges is given below: 3.10.1. Organizational independence a) Characteristics Organizational independence allows the audit activity to work and be perceived to conduct work without inference by the entity under audit. b. Present condition Although the FCGO is a separate central level organization but internal audit is not independent due to it is not in position in providing value added service. c. Reason of weakness and Gaps Internal audit has not beenrecognizedindependent legally and administratively. Direct or indirect management interference 3.10.2. A formal mandate a) Characteristics The audit activity’s powers and entities should be established by public sector Constitution, Charter or other basic documents. Among other topics, this document would address procedures and requirement of reporting and the obligation of the audited entity to collaborate with the auditor. b) Present condition Financial Procedure Act, 2055 and Financial Procedure Rules 2064 has to some extent clarified the scope of work for internal audit. But internal audit has not been performed effectively. c) Reason of weakness and Gaps Entire public sector entities (for ex: Local Government, Committee Board, Trust etc. do not come under the jurisdiction of internal audit. 3.10.3. Unrestricted Access a) Characteristics Audit should be conducted with complete and unrestricted access to employees, property and records as appropriate for performance of audit. b) Present condition The legislation does not clearly specify about the access to records and document however the government bodies have been made responsible to provide records and documents for internal audit purposes. c) Reason of weakness and Gaps Practically, it is felt that there is no access to related files of taxpayers. 3.10.4 Sufficient funding a) Characteristics The audit must have sufficient funding relating to the size of its audit responsibilities. This important element should not be left under the control of organization being audited, because the budget impacts the audit activity’s capacity to performing its responsibility. b) Present condition There is no provision for allocating separate budget for internal audit as per the scope of work and size of the internal audit; there is no practice of conducting various kinds of audits such as system audit, pay roll, revenue audit, procurement audit and management audit. c) Reason of weakness and Gaps • Even though there is legal provision to conduct special audit but due to the lack of skilled manpower neithersuch audit are conducted nor budget is not allocated • There is no practice to estimate the audit cost • There is no practice of preparing programs wise budget and budget is not demanded to conduct audit. 3.10.5. Competent leadership a) Characteristics The leader should be knowledgeable of applicable standards, professionally qualified – preferably certified and competent to oversee and manage an audit activity. Moreover the CAE (Chief Audit Executive) should be an articulate public spokesperson for the audit activity. . b) Present condition In FCGO, the internal audit Section is headed by Under Secretary levelofficer, but it is not compulsory that suchofficer need not to have required qualification, ability and skill to conduct internal audit. There is practice of deputing staff on the basis of approved post. c) Reason of weakness and Gaps Lack of tone from the top A large numbers of assistant level staff compared to officer level. No separate Cadre of internal audit has been established. 3.10.6. Objective Staff a) Characteristics Audit staff must have impartial attitudes and avoid any conflict of interest. B. Present condition There is no situation to conduct internal audit by engaging adequate trained staff provision for training to staff to conduct internal audit in line with its objectives. There is situation of conflict of interest and impartial attitudes. C. Reason of weakness and Gaps Staffs are assigned dual responsibility of accounts keeping and internal audit. Lack of impartiality while conducting internal audit of accounts prepared by the colleagues. Job description isassigned based on the level of staff rather than work nature 3.10.7.Competent staff a) Characteristics The Audit activity needs a professional staff that collectively has the necessary qualification and competencies to conduct the full range of Audits required by the mandate. Auditors must comply with the minimum educational requirement established by their relevant professional organizations and standards. b) Present condition There is a lack of individually and collectively capable and competent staff to conducting audit and selecting audit activities based on its scope of work. c) Reason of weakness and Gaps Lack of selection of staffs to conduct the audit with desired academic qualification. There is a less participation of staff in the national and international skill development program. Lack of policy regarding capacity development. 3.10.8. Stakeholders support a) Characteristics The legitimacy of Audit activity and its mission should be understood and supported by a broad range of elected and appointed public sector officials as well as by the media involved citizen. b) Present condition Lack of support and knowledge of the elected and appointed personincluding topmanagement towards internal audit and recognize it as an important tool of public financial management. c) Reason of weakness and Gaps Lack of focus towards risk control. Lack of attitude to give importance towards observations pointed out by internal audit. Taking internal audit observations as a criticism towards the management. Non acceptance of negative comments made by internal audit. 3.10.9. Professional Audit Standards a) Characteristics Professional Audit Standards, such as the International Professional Practice Framework (IPPF)promulgated by the IIA supports the implementation of previous elements and provide a framework to promote quality audit work that is systematic, objective and based on evidence. Audit activities should conduct their work in accordance with recognized standards. b) Present condition • • • • Due to non-formulation of professional auditing standards, internal audit has not been carried out in planned and qualitative manner. Only internal audit directive have been issued The Financial Procedure Act and rules there on only specify the points to be seen while conducting internal audit. Internal auditors are not given training in relation to professional audit standards. c) Reason of weaknesses and Gaps Professional auditing standard for internal audit and Code of Conduct for the internal auditor have not been promulgated in line with international practice. Considering the above elements the existing condition of the internal audit, additional objective assessment is required so as to identify the ground situation. However, out of the above 9 elements,except a formal mandate and unrestricted access to records and information the situation of other elements appears to be poor. Therefore, the internal audit performed in our country is not in line with international values and beliefs.Additional analysis has been discussed in different paragraph. The ASOSAI has listed out following 5 elements of internal audit system in its Report on Evaluation and Improvement of Internal Audit System and relation between the internal unit and SAIs. Governance Organizational Structure Standards and Review system Human Resource Service and Role of internal auditing to financial management In course of assessment while asking some of the offices about whether the internal audit has contributed to financial management of which 10 have replied Yes whereas 3 have replied No. Similarly in reply of question about how internal audit has contributed 6 offices have mentioned that internal audit has supported in maintaining best working culture by highlighting the errors/mistakes immediately and provide opportunity to rectify them; whereas 8 offices replied that internal audit has contributed in timely in updating accounts for internal audit purposes which has helped in enhancing competence level for submitting public accounts. 3.11 Internal Audit Management in Different Asian Countries The Internal Audit is practiced in the public sector of almost all the Asian countries and havecreated separate Internal Audit Unit in the ministry/departments. But internal audit is rarely outsourced. Some of the facts regarding Internal Audit have been presented below: 3.11.1 Internal Audit Practices • Though audit manuals/guidelines have been pronounced by different countries but standards of some countries are not in line with generally accepted standards. • In case of type of internal audit, most of the countries conduct compliance and financial audit. • Lack of professional auditors is a major reason for the existing ineffectiveness of internal audit. Supreme Audit Institutions of various countries have accorded importance on the following aspects while making assessment of internal audit functions: • Organizational structure of Internal Audit unit • Compliancy of Staff • Audit plan & execution • Quality of Audit Activity • Quality of Documentation • Quality of Audit Reports • Implementation of Audit Recommendation. The above point is similar to listed as elements by Instituted of Internal Auditor. 3.11.2 Cooperation and suggestions by Supreme Audit Organizations To improve the internal audit, various countries have given various suggestions covering the areas of Internal Audit Legal Mandate, clarifying roles and responsibilities, better communication, conducting formal training etc. 3.11.3 Situation of Manpower The bodies charged with the responsibility of IA in various countries are facing shortage of staff both in terms of number and quality of staff. In Malaysia National Audit Department is providing different professional development trainings to internal audits. In case of qualification of internal auditors in some countries the eligibility criteria for auditor is bachelor degree and certificate related to audit is specified. In India, experienced auditors are given priority. 3.11.4 Audit of Information and technology The use of computer has been increasing for supporting Internal Audit. Use of CAAT has been implemented in most of the Asian countries for Audit of Information & Technology. 3.11.5 Status of follow up and implementation of Suggestion In case of implementation of the suggestions of Internal Audit is not satisfactory. However, in some countries suggestion have been accepted whereas there has been delay in their implementation was fully found in some nations. In, some countries there is no practice of follow up is done regarding implementation of suggestion. On asking the DTCO regarding the situation of addressing the observation related offices, 3 of the offices undermined the issues, 2 of them addressed 50% of the issues and only 1 office addressed the issue. Similarly, since observation become null raised by the internal audit the final audit, due to which pointed out by internal audit weren't taken seriously. When similar enquiry was done to the OAG regarding the situation of addressing the internal audit report and issues raised by it, it also replied that most of the offices neglected it. Chapter - 4 4.1. Quality of Internal Audit Regarding the quality of internal audit and issues details have been illustrated in situation the analysis chapter and these have been also given in other paragraph depending on their relevance. Despite the absence of standard in internal audit, the good international practice & final auditing standard could be taken as reference. The quality of internal audit carried out by DTCOs under FCGO as stipulated in Financial ProcedureAct, Internal Audit Directives, internal and Annual Reports of OAG and other study reports discussed with some officers when taken into consideration, following basis can be identified for quality of internal audit: Basis for quality measurement Position of internal audit 1. Legally ensure independency of internal audit • Financial Procedure Act 2055 rules is silent regarding independence of IA. 2. Moral requirement • Lack of Code of Ethics for internal audit as absence of segregation of rules& responsibility. • Same staff of account groups are performing the responsibility of internal audit & accounts keeping • Out of 600-700 staffs engaged in internal audit most of them are(non-gazetted) staff having different educational qualification, least of them have attended training’s transfer of staff in every 2 year interval as per Civil Service Act are the reason for the inconsistencies in performing internal audit 3. Relation with entities to be audited. 4. Human Resource Management 5. Audit Execution 6. Supervision • There is no practice of preparing audit plans although some DTCOs have prepared time table for the entities to be audited. • Non formulation of standards on internal audit in line with international practice but IA Directive relating to internal audit is in place. These Directives mentions about the points to be considered during checking of different heads of revenue & expenditure as well as Auditor General’s Forms. • Internal audit is mainly focused on compliance with law & regulation as reflected from internal audit report • Situation of detection of several inconsistencies by final audit which were not found by internal audit. • Lack of monitoring whether finding of internal audit were addressed or not. • No review system of quality control of internal audit during & post of audit is not done ,if done are also not properly documented • NO action is taken against responsible person regarding to non- clearance of inconsistency detected by internal audit • There is no any practice of documentation of various phases of audit activities such as pre-planning, execution reporting and follow up. • No documentation or audit file is maintained starting of internal audit, completion of internal audit, evidence of irregularities matters audited 7. Documentation However there is no basis to ensure the above mentioned working practice to confirm whether quality or audit procedure applied is appropriate. This does not ensure the quality of internal audit report &repetition of weakness in internal audit procedures. 4.2. Legal provision regarding internal audit &its Scope There is provision regarding internal audit in Section 16 of Financial Procedural Act 2055 &Rules 95 & 96 of Financial Procedure Rules 2064. Section 16 of the Act specifiesthat internal audit shall be conducted as specified by FCGO whereas Rule 96(1) to 96(8) Financial Procedure Rules 2064has authorized to DTCOs to conduct. As per the provision of the Rules, internal audit is to be carried out income, deposits and expenditure as well as other funds of office. As there is no procedure & process specified for internal audit in the relevant Acts & Rules, nonformulationstandards on internal audit and no provision for risk assessment is prescribed in Internal Audit Directives 2068, audit is to be carried out for entire transactions. Legislation is silent regarding to risk assessment & sampling. The OAG in the view of the provision made in Rule 96 of FPR it appear that FCGO is required to conduct compliance and performance audit including checking of true and fairness of financial statement. Though there is a practice of conducting compliance audited certification of financial statement but economy the audit reports does not include the three documents of performance audit , efficiency &effectiveness of transaction. Similarly the Law is silent regarding to objectives, independence and reporting of internal audit. In practice, internal audit isconfirmed to compliance aspects and reports includes cases of non-compliance rather than reporting suggestions for improvements.in course of assessment opinion of six DTCOs was solicitedtheir opinion through questionnaire about the legal arrangement of internal audit, all of them opined to amend the legal provision. OAGN also is expressed their views for amendment in legislation both the sufficiency & insufficiency of legal provision regarding to internal audit in an asked questionnaire to the people of the OAG. 4.3 Independence of internal auditor The FCGO charged with the responsibility of internal audit as Departmental under the Ministry of Finance which is headed by special class officer. There is no facilitation regarding reforms initiative such as human resource management liaison ministry etc. of FCGO because of which the quality of IA is not up to the mark. While deputing the joint FCG as leader and even FCG does not come in the priority of first class officers of administrative service due to these reasons there lack independence to IA legally and administratively. In the structures of FCGO internal audit has been kept as a section & its business is also not specified as per its objective & nature. Even if it is an independent but cannot function independently being separate entity. Following matters are to the considered to ensure the independence of internal audit as per international standard on auditing & relevant best practice.so as to function legally and administratively as independent body. • The responsibility of internal audit rests with the organization • The system of submitting the internal audit report to head of the organization • To ensure non- interferences on audit method and procedure • To follow standards to maintain consistency in audit work • To ensure unhindered access to information and records • To depute staff as per the specified procedures • To arrange Code of Conduct and Internal Audit Charter • To manage quality assurance system Lack of independence affects the biasness and credibility of internal audit performed. In relation to internal audit of public sector in Sri Lanka Financial Regulation has made provisions regarding independence to internal Audit. In Sri Lanka the Regulation stipulates the accounting head of department that is large in size and involved in development activity are required to establish internal audit unit. The Regulation has specified the objectives of audit functions of internal audit and its scope of work. The Regulation has stated that the internal auditor to submit its report directly to organizational head and also to the AG. The system of internal audit in public sector its management structure, scope of work and reporting arrangement varies from countries to countries but they all have ensured the legal and functional independence of internal audit. Different Auditing Standards has been issued by the International Organization of Supreme Audit Institutions including Lima Declaration, 1977 on independence and using work of internal audit. The significant provisions are described below:• Lima Declaration 1977 internal audit services necessary are sub ordinate to the head to the department within which they have been established. Nevertheless, they shall be functionally and organizationally independent as far as possible within their constitutional frame work. • Internal audit independence in public sector(INTOSAI GOV 9140) • Co-ordination and co-operation between SAIS and internal audit in the public sector(INTOSAI GOV 9150) • Using the work of internal auditor (ISSAI 1610) In these Declarations and auditing Standards, there is a detailed description about the independence and obtaining the objectivity of internal audit and the using work of internal audit. Internal audit is independent, organizationally and functionally based on the international practice but the present performance doesn’t reflect the independence. 4.4 Organization and Human Resource Management The organizational structure of FCGO is expanded at district level and one or more DTCOs are performing in the districts based on the work load after the execution of TSA. Among its main tasks, it is involved in budget execution, accounting and internal audit. As per the organizational structure of FCGO there is a separate Internal Audit Section. Among the five thousand staff in FCGO, there is one thousand staff performing in treasury administration of DTCO.TheDTCO staffs are involved in the internal audit of district level offices. According to international and the practice in other countries the Audit Committees are formed for monitoring and execution of suggestions of audit (internal & external). However, we have no such Audit Committee even though the OAGhas recommended establishingit. To large extent, there is adequate human resource involved in internal audit however the most of the audit is carried by junior level staff (non-gazetted) staff. There is no practice of monitoring and supervision of internal audit quality controland job description is assigned to the posts rather than on the basis nature of job.Similarly, there is lack of opportunity to develop qualification required for internal audit, lack of proper appropriate documentation to conduct internal audit in planned manner. The transfer of staff generally takes place at the interval of 2 years which hinders to develop professionalism in internal audit work. No discussion on internal audit report is held at institutional and ministerial level. 4.5 Organizational & Functional Model of Internal Audit The Financial Procedure Act, 2055 has made FCGO responsible for internal audit.Internal audit is the main tool of internal control system of anorganization; therefore its organizational and functional model differs from country to country. In some countries there is a separate internal audit department under Supreme Audit Institution. Precisely in the Commonwealth countries there is arrangement of Comptroller General. Now, in case of model or structure of internal audit is concerned the following models have been suggested for Public Sector (INTOSAI GOV9140) issued by International Organization of Supreme Audit Institute (INTOSAI.). • In-house: Employees within the organization who are not involved in any type of activities of organization are mobilized for internal audit .The internal audit of Nepal government falls in this category. Its management is done by one of the staff. • Co-sourced: The organization’s employees along with external service provider are involved in internal audit and it is managed by the organization's employee. • Out-sourced with in-house management: The internal audit is done by the external service provider however its management is done by the organization's employee. • Fully outsourced: Internal audit is carried out by the external service provider and the service provider manages the internal audit activity, however the project management is done by the organization's employee. The organizational structures, geographies, work nature, situation of internal control system, risk control management and cost of internal audit etc. need to be considered while selecting the internal audit model. Different countries have adopted different model for internal audit of public sector. Whatever be the model of internal audit, it is important condition to ensure independence required to be maintained legally and functionally. The strength and weaknesses of different models relating to internal audit are as follows: 4.5.1 Single or In-house Model As this model lies within the organization, one of the main challengesis to keep free from biasness and availability of capable human resources. Its strength and weaknesses are as: Strength • Arranged through legal provision Weaknesses • To deal with the complexity which • • • • • • • • • Separate organizational structure are encounteredby the large human resource with specific qualification & skill institution in administration Mobilization of staff as per requirement &carrying out activities. Standards should and apply it • Monotonous feeling arises due to Comparatively this model is well managed & involvement in internal audit for professional due to large base of public sector long period. As it is separate service there are service condition • Threat of independence lies in for promotional opportunities and career caseoflack of divisional structure development. Consistency in reporting and solution can be obtained with single decision through the process of legislation The use of single internal audit standard in audit results uniformity of audit process report and ease in implementation of standard due to application of single set of IA standards. Contributes to quality & capacity development through collaboration with the OAG 4.5.2 Co-sourced Although there is a separate structure of Internal Audit, a service of external service provider can be taken in the form of maintaining coordination with them. In this model, departmental work force and external service provider could be used jointly to carry out the internal audit. But it is appropriate to make legal provision seek the services of external service provider. However, under this model the management of internal audit should be donedepartmentally.Some of main strength & weaknesses of this model are:• • • • Strength Management of internal audit rests Department Can take service from external service provider in accordance with terms of reference Transfer of professional skill by service provider to Departmental staff Involvement of service provider helps in developing internal audit system and tools • • • • • • Weaknesses Risk of dependency on external service provider Cost of internal audit t increase due to fees of external service provider Lack of knowledge about PFM and management system to the external services provider To orient the external service provider about PFM and legal provisions of public sector audit and its values Risk of preparing work plan considering the availability and timing of External service provider Risk of dispute due to lack of clarity in Terms of Reference in working jointly 4.5.3. Outsource with in-house Management In this model the internal management is made responsible tocarry out internal audit activities from external service provider. That means, internal management shall lead to mobilize external service provider. The strength &weaknesses of this model are: Strength • The human resource for the internal audit purpose can be deployed according to the work plan, needs and requirements • The management can initiate action or warn for unsatisfactory performance against the external service provider as provided by contract • Certainty in getting audit work performed by capable, skilled and experienced human resource of external service provider Weaknesses • Increased dependence on external human resource • Situation of capable and departmental experienced manager might emerge • Directive can be issued for mobilization of human resource of external service provider and for quality control • Arrangement of internal structure or Committee for management and monitoring of external service provider 4.5.4. Fully out-sourced As per this model, the task of internal audit is fully conducted by external service provider .It is carried out as a Project. This model is slightly different with in-house management. The strength and weaknesses of this model are: Strength • The sole responsibility of internal audit lies with external services provider • Situation of work completion on the basis of TOR and stipulated time. Weaknesses Limited job description Increase dependency on service provider No contribution to organization’s capacity Inadequate support to internal audit from entity being audited • Risk of encouraging external auditors to violate COE from entity being audited • Difficulties in organizational and procedural arrangement with regards to regulating, monitoring and reporting of external service provider • • • • As the internal audit is a useful tool to enhance the public accountability,transparency and alerting the public financial administration, which is pre-condition whatever, the model is adopted. The geographical spread of entities to be audited, size of the budget, Financial Procedure Act, Procurement Act, number of Projects, involvement of donors in development activity, existing organizational structure of internal audit and availability of human resource etc. have to be considered while adopting the model for internal audit. In the view of above and on the matters described below including international practice, single or divisional model seems appropriateto be adopted for internal audit. • For more than 3 decades,FCGO is conducting internal audit through is institutionalized manner. • In Support in maintain consistency and facilitation process in conducting the internal audit of more than 4500 public offices of the country is done by a single body. • Although maximum number of staffs are of assistant level, about 1000 staff are involved in internal audit have experience in internal audit. • There is a room for bringing the various local bodies such as District Development Committee, Village Development Committee, bodies established by Development Committee Act, 2013, and other entities formed under Special Act and through administrative decisions under the jurisdiction of internal audit. • It is certain that to expand the scope of internal audit under federal structure in upcoming constitution. Even if the services of external service provider is arranged to conduct the internal audit,it is needed to formulate the activities such as the selection of service provider agencies, regulation and develop operational guidelines for service providers. Due to engaging external service provider, dependency on such service provider might increase. In addition to this, there might be difference in approach of government auditors and external service providers. For this a small structural and procedural arrangement is required. Doing enquiries with different DTCOs regarding with model would be appropriate among the 4 practicedinternationally 6 of the DTCOs suggested that complete outsourcing would not be an appropriate choice, where as the rest each 2 DTCOs evenly supported remaining modules. In this regard, the OAG has suggested the In-house model as an appropriate choice for internal audit. 4.6 Problem and Challenges Encountered by Internal Audit The various studies have revealed that even after the clarity in legal and organizational arrangement, internal audit performed is not qualitative. Internal Audit can provide important contribution to public financial administration although it faces different external and internal problems. This has been demonstrated through records as well as discussions and interviews with some of the officers.Asomeof the major problems encountered by internal audit are as follows: 1. Quality and effectiveness of internal audit: • Lack of independence to internal auditors fails to perform independently • Lack of credibility due to dual responsibility of Accounting and internal auditing is performed by same internal auditors • Lack of professionalism in audit management and its execution • Lack of Internal Audit Standards 2.Adequate Resources and Means: • Lack of skill and capacity development among auditors • Lack of training to auditors • Limited budget appropriation 3.Supports from Stakeholders: • Lack of importance provided to Internal Audit • Non-implementation of recommendation suggested by the internal audit report • Lack of positive attitude from audited entities towards internal auditors In course of this assessment a question regarding the problems faced during conducting internal audit was asked to some DTCOs, out of 3 of them replied that lack of independenceto the internal auditor as the main reason whereas 12 offices opined as lack of capable manpower as the main reason due to which internal audit has neither been effective nor contributed to management. There are the different problems faced by internal audit has been statedearlier, but the lack of competent manpower and audit tools are the major problems. To resolve these issues initiation has to be taken by FCGO to obtain support and cooperation of the OAG and the ICAN. Similarly, the addressing of theseissues is essentialfor the effective management of internal audit. when asked to the office of the audit general about the thoughts of organization being audited about the internal audit office of audit general has answered that there is a culture to assume that the internal auditor's are fulfilling their own responsibility. we also asked about the erasing problems the internal audit system is facing from AG office, office of Audit general answer that the problems in the system. Lack of competent human resource, lacking the implementation are the problem which internal audit is still facing. According to the above, internal audit is facing different problems among that competent human resource and required tools are the important and challenging problems. In order to solve this problem, it is beneficial that the financial comptroller office sought help and co-ordination from office of auditor general and institute of Nepal chartered Accountants. Above problems needs to be addressed for the effective management of internal audit. Chapter - 5 Suggestion for Improvement Simply a single study or assessment may not be able to suggest solution for the organizational strengthening and a separate study conducted based on the nature of work along with its sector and such sector wise studies can identify the right solution. In the view of situation analysis and result of this study relating to the public sector internal audit, it is required to amend the extant Financial Procedural Act, 2055 by making provision of independence to internal audit and expand its scope of work.. With the amendment in the legal provisions, FCGO need to be restructured including internal audit and also approve the desired posts accordingly. Along based on the approved post filled a separate HR Plan required to be formulated in order to develop capacity building and career development of internal auditors is equally important. It is most important to develop Internal Auditing Standards for maintain professional and standardization of internal audit and capacity development of staff. Arranging these activities is time consuming and costly exercise. Similarly some major issues are to be studied further by formulating strategic plan for reform and implementation which seems to be appropriate option. The possible solution of the problems identified by this assessment is recommended below. 5.1 Single or In-house Model for Internal Audit As mentioned earlier in 4.5.1 single or In house model appears to be suitable for internal audit although some legal, structural and functional infrastructure need to be dealt with. So, the following activities are suggested. 5.1.1 Additional Legal Provisions To improve the existing independence and neutrality in conducting internal audit it is desired toamend the Financial Procedural Act and Rules thereon so as to extend the jurisdiction of internal audit. This will support to increase scope of work and enhance the level of internal audit. 5.2 Organizational structure 5.2.1 Organizational Reforms Organization and management survey is to be undertaken to decide whether the FCGO is to be kept under the Ministry of Finance or create separate Department could be an option. Present organizational structure also requires some changes so as to carry out internal audit independently. 5.2.2 Proposed Organizational Structure and Management As per the current organizational of FCGO,there exists Audit Section at central level and Section/Unit at operational level of DTCO.In FCGO officer leads the Section. As mentioned in paragraph 4.5with regard to internal audit, among the 4 models whichever model is adopted it is appropriate to restructure and reorganized the present organizational structureand management of FCGO. Every model has its own strength, weaknesses and challenges. There is a situation to deal with organizational structure & managementof each and every model in its own way. Likewise, once the model is adopted it seems appropriate to conduct organization and management survey in detail. Therefore, an attempt has been made to mention the approach regarding organization structure in this report. In the present context, it is appropriate to adopt inhouse model considering facts such as the number of entities to be audited, geographical spread, size of the national budget, scope of work and its nature as stipulated by FPA, 2055 and Rules 2064 , available manpower, prevailing situation of poor internal control system of entities ,expectation of stakeholders etc. For this purpose, the existing organizational structure and management of FCGO required to be restructured as mentioned below for adopting in-house model. It is suggested to establish following functional Department or Division within the structure of FCGO. Economic and Administrative Sector Section/Wing Social Sector Section/Wing Methodology Development and System Section/Wing Internal Governance Section/Wing Central Accounts and Consolidated Fund Section/Wing The scope of work, roles and work description of above Sections/Wing should be clearly specified. Extension or merger of Sections can be undertaken based on the requirement. 5.2.3Proposed Structural of district based Offices: Currently internal audit of district based offices are being performed by the DTCOs which is required to be restructured by creating Section as below seems appropriate:Create two Sections at Central level with Sector wise Section for internal audit under the DTCO appears to beappropriate. • Internal Audit Section ( Financial & Administrative sector) • Internal Audit Section (Social sector) • Internal Audit Co-ordination Section ( Financial Statement / Project Account) For the coordination of District offices, Section/ Branch with central Division /Section, an internal audit Co-ordination Section would be appropriate. To maintain co-ordination with central level Division and with all Section other department would be an appropriate to assign the tasks of Internal Audit Co-ordination Section. 5.3 Internal Audit Standards & Review System 5.3.1 Internal Audit Management & Internal Auditing Standards Irrespective of legal mandate to internal audit, internal auditing standards, Audit Directives and tools are desired for management of internal audit and maintaining its quality. But presently, due to non-formulation of internal audit standards as well as lack of necessary tools, additional efforts are essential to maintain the reliability of internal audit. For instance, Internal Auditing Standards have been issued and arebeing implemented in public sectors of United Kingdom. The details have been mentioned under Annexure- 1. 5.3.2 Monitoring of Internal Audit Report The Internal Auditing Standards specify about the monitoring of internal audit as well asits quality control, but its procedures are specified in the Audit Directives managed through administrative arrangement.Presently, Internal Audit Directives has mentioned the monitoring process in brief but not in detail. Audited entities are to be made more responsible for settling the audit observations raised in internal audit report and situation of monitoring results need to be included in next year’s report. Therefore, their solution is necessary. 5.3.3 Quality and Working Procedure of Internal Audit Auditing Standards is the main tool for maintaining quality and credibility of audit. The FCGO has issued Directives for internal audit but has not yet formulated Auditing Standards for internal audit of public sector. Furthermore, shortage of qualified manpower, lack of capacity developmentactivities and Code of Ethics for Auditors are some issues to be dealt with so as to carry out internal audit independently. No internal audit files are kept for audit performed. In this situation it is difficult to assure that audit has been conducted in a professional, planned and standardized manner. In the context of private and public sector audit which is being conducted in accordance with the Auditing Standards are alsoquestioned in time to time but internal audit conducted without applying auditing standards and competent staff; it is difficult to measure the standard level of internal audit conducted. So, whichever model is selected for internal audit, the following issues must be addressed on time. • To formulate Internal Auditing Standards by forming a Working Group or work jointly withthe OAG or ICAN • To prepare Code of Ethics for Internal Auditorsis essential. • To formulate or revise the Internal Audit Directive in line with Internal Auditing Standards. • To develop HR Development Plan to activities for career development and capacity building. • To take initiative for amendment in Civil Service Act and Rules thereon in order to create an Internal Audit Group for the career development of staff. To maintain the quality of internal audit issues other than those mentioned above are discussed in other Chapter need to be considered. 5.4 Human Resource 5.4.1 Internal audit service / Group Formation Currently there is a provision of separate Accounts Group for recruitment of staff, transfer and promotion of staff underCivil Service (Administration). In order to perform internal audit independently and impartially, there are two alternatives, either forming a separate Account Service and internal audit service or forming an internal audit group similar to AccountsGroup. The amendment in the Civil Service Act essential to create additional posts of post of gazetted 1st level officers in accounts and internal audit service commensurate with the size of total staff for the career development of staff. There is a provision of audit & accounts service in India at central level. 5.4.2 Capacity Development of Internal Audit One of the major problems of internal audit facing is that the negligible opportunity for capacity development of the staffserving in this field of internal audit. Due to non-formulation of Internal Auditing Standards internal audit has not been carriedout as per the audit values and principles. Also there is no facility of internal training under the FCGO for the internal audit staff. The Revenue Administration Training Center is conducting entry level training, in service training and refreshment training for accounting staff for their capacity development .But such training does not focused on internal audit within PFM. With some exceptions one or two batches of long and short term trainings no other training have been conducted. Similarly adequate books and study material is available related to internal audit.An understanding can be made between OAGN and FCGO for the capacity development of internal auditors under staff exchange program for a short period. Therefore it is necessary to address these problems. 5.4.3 Review of existing approved Post and Proposed Manpower Presently out of one thousand staff involved in internal audit, a large number of staff covered by non-gazette staff out of that also half of them are support staff. Therefore approved post required to be reviewed so as to maintain the proportion of gazette 1st 2nd and 3rd class officers and assistant level staff. This will not only help to improve the performance but also open the room for career development of staff. Similarly the role and responsibility need to be specified in job description of staff. This will solve the problem of dual responsibility of accounts keeping and conducting internal audit by the some staff. This will also support specialization of staff. As per the proposed structural approach the internal audit manpower to be mobilized as follows: Particulars Proposed number of staff and level Gazetted 1 Gazetted 2nd Gazetted 3rd Non-Gazetted Class Class Class 1 1. FCGO (Central office) 5 10 15 Internal Audit Department/Division Chief Section Chief 2.DTCO (district office) Internal auditor Section Chief Terai and large hilly district 20 40 60 Remaining hilly district 55 165 495 st • • • • Terai hill and number of offices in regional headquarters, budget size, etc. should be considered while determining numbers and grades of officer level staff and adjustment of posts in terms of number for internal audit. But, while increasing the number of manpower officer level staff should be added. 5.5 Appropriateness of use of Information Technology auditing methods in Internal Audit Despite being electronic recording of income & expenditure under single accounting system, the supporting and basic documents are maintained manually in hardcopies. As a result, these don't create any differences and problems in conducting regularity audit through internal audit of those transactions. In the context of maintenance of accounts in IT system, the risk areas to be considered in audit include maintenance connectivity, security, data backup, use of software capacity, security control system completeness of information and its creditability, and availability of staffs and training etc. required to be analyzed and tested. As all offices are not integrated with information technology network, use of CAAT cannot be applied since CAAT is complex task in which auditors needs to be initiate various steps. There is a need for proper examination & study on fairness and completeness certification of Financial Statements for which staff with adequate knowledge base on Information Technology should be deputed for internal audit. Following arrangement can be made. 5.5.1 In case of non-availability of adequate and skilled staffs to conduct the system audit/IT audit which have adopted IT based accounting system, service of external service provider can be taken for conducting Compliance audit. 5.5.2There is need of co-ordination and cooperation from the OAG & Internal Audit for IT Audit or to audit jointly which could result in skill development of both organizations. 5.5.3 As such there is no such vast difference between IT auditing & Financial Auditing in general but auditors needIT knowledge. In addition to these following arrangement is needed for IT auditing. • Need for development of Guide, Directives and other Audit Tools. Initiation is required to develop such Guides, Directives so as to support to conducting IT by internal auditors. • It is appropriate to establish separate of Information Technology Section/Unitunder organizational structure for internal audit. Such arrangement in organizational helps bringing specialization of InternalAudit and open the avenues of career development of staff having IT qualification. 5.6 Internalization of Good Practice There is huge professional gap in the audit performed 3 decade since initiation of Internal Audit of public sectors by the FCGO. The reason behind it isnon-availabilityof internal audit standards and lack of capable and skill situation manpower is main reason behind this. In order to improve the existing conditions there is need to make arrangement of seeking cooperation and advise from Office of the Auditor General (OAG) & the Institute of Chartered Accountants of Nepal (ICAN). Also in this connection it is appropriate to initiate obtaining technical and advisory services from the external consulting service providers of development of internal audit. Chapter -6 Conclusion:Legal provision have important role in public administration so, there is clear provisionin Financial Procedure Act, 2055 and Financial Procedural Rules, 2064 about internal audit. As per the FCGO's organizational, 75 DTCOs have been established across the country for Treasury Management and Internal Audit.For the purpose of Treasury Management and carry out internal audit more than 700 posts of different levelshave been approved. Under the FCGO,DTCO are conducting internal audit of government entities since last three decades and have institutional experience on it, the FCGO has issued Internal Audit Directive for proper management of internal audit and enhance its standard. This directive has been updated in time to time. The above mentioned facts are positive aspects in internal audit, but there is some weak aspects also. Internal Audit has not been legally and administratively independent. In order to carry/perform internal audit in other words internal audit is not free from management pressure &un biasness. Moreover the internal auditors are also involved in accounting works which result conflict of interest and situation of biasness while conducting internal audit. Since the internal audit standards major audit tool for conducting internal audit but it has not been formulated till date in line with the International Practices. As a result its difficult to assure on reliability and quality of audit. Due to limited opportunity of capacity development staff involved in Internal Audit, it has direct impact over the quality of Internal Audit and lack of which audit has not been performed in planning manner. Audit observation raised by internal auditor is also not given importance by audited entity management. Because of these reasons internal audit has been unable to contribute in maintaining sound financial administration. Since last few years there has been big challenge to internal audit with the increase in size of government budget, increased number of project and programs and compliance with conditions to be abided by projects supported by Development Partners. Similarly with the implementation of TSA, it has rapidly increased use of Information Technology by FCGO; initiation of implementing accounting standard in public sector in line with International Practice and use of CAAT has further created both opportunity and threat for Internal Audit. Therefore, by considering the above situations,existing organizational structure of internal audit along with human resource management has to be restructured through legal & administrative measures for strengthen it as mentioned in various Study Reports, reports of the Office of the Auditor General. Otherwise it seems difficult to maintain professionalism in audit and legitimize the financial activities in the name of internal audit. Chapter -7 7.1 Suggestion for implementation Approach In connection with strengthening of internal audit the areas of improvement identified by the assessment for their implementation are given in work plan along with specific activities. But further homework is required to implement the suggested activities. Thus it is appropriate to follow the method mentioned below: 7.1.1 Formation of Steering Committee It is appropriate to form a Steering Committee in FCGO to strengthen Internal Audit. Such Committee must be represented by OAGN. 7.1.2. Formation of Working Group One or more working group need to be formed for pre-planning and implementation of suggestions. For instance form a Group to conducting organizationandmanagement surveyfor the organizational restructuring of internal audit and a separate group for developing Internal Audit Standards. 7.1.3. Coordination & Cooperation with Office of Auditor General In connection of reinforcing and enhancing credibility of internal audit it seems useful to coordinate with the Audit General Office. 7.1.4. Co-operation with ICAN The internal auditors should co-ordinate with the ICAN which is established under Nepal Chartered Accountants Act-2063 in seek support in the areas of formulation of internal Audit Standards joint work for capacity development activities of internal auditors, for this it seems appropriate to initiate formally for mutual agreement or understanding. . 7.1.5. Formulation of Strategic Plan It is appropriate to formulate 3-5 years strategic standards plans for the strengthen of internal auditors rather than performing activities on ad hoe basis Separate Strategic Plan committee can be formed for initiating the task. The representatives from Auditor General Office, Ministry of Finance, ICAN, Nepal Rastriya Bank, etcbe included in such Committee. The study report prepared by FCGO for reform in internal audit has suggested work plan for 6 years. However suggested activities can be carried out only by preparing Strategic Plan. The strategic plan could be basis for arranging internal and external financial resources to FCGO which need to be taken into consideration. In case of methods implementation of suggestions it may be effective to initiate dialogue with internal and external stakeholders for obtaining their consent. 7.2 Strengthening of Internal Audit Work – Plan Key Milestone 1. Leadership Activities Initiate to form a Steering Committee with specific TOR Output Steering Committee 2. Legal Arrangement Initiate to amend the Financial Procedure Act to extend the scope of work and provision of Independence • Initiate to amend civil service Act/Rules to create separate cadre for internal auditors FPA amended 3.Strategic Planning Form a task force to formulate strategic plan for three years by Covering all the above activities in detail. • Conduct organization and management survey in line with suggested In-house model • Initiate to formulate Public Sector Internal Auditing Standards in line with international best practices , code of ethics for Internal Auditors & Audit guide • Sign MOU with Institute of Chartered Accountants of Nepal to formulate Internal Audit Standards • Initiate dialogue with office of the Auditor General seeking cooperation in strengthen internal audit. • Develop strategy for capacity building / training for Internal Audit & training modules based on standards & Audit Guide deliver training modules. Conduct pilot internal audit packages covering the geographic spread at last in 10 places. Strategic Plan 1st Year O&M survey Report TBD by Steering Committee Starting from 1st year to 3rd year on ongoing basis Delay is decision making Lack of budget, administrative support and cooperation from related authorities Explore the avenues for application of CAAT in the entities maintaining Accounts in EDP environment by conducting a study. Study report on CAAT application 2nd year study 3rd year Application Use of EDP in Government Sector Trained manpower 4. Restructuring the organization and management 5. Capacity building Application of CAAT Internal Auditing Standards, Audit guide and code of ethics Time frame Within the month of 1st year 1st and 2nd year MOU signed with ICAN Risk factors Failure to form committee Procedural Delay or lack of support from MOF, MOGA, MOLJ , Parliament Administrativ e hassles Dialogue held and commitment from OAGN for cooperation Training strategy & training module All Internal auditors trained and Pilot audit conducted. ANNEXURE-1 Public Sector Internal Audit Standards UK Attribute Standards Purpose, Authority & Responsibility Independence and Objectivity Proficiency and Due Professional care Quality Assurance and Improvement Program Performance Standards Managing Internal Audit Activity Nature of work Engagement Planning Performing the Engagement Monitoring Progress Communicating Results Acceptance of Risk ANNEXURE-2 List of offices from which feedback were collected through Questioner. S.No. 1 Name of the Office Office Of The Auditor General District Kathmandu 2 Financial Comptroller General Office Kathmandu 3 Financial Comptroller General Office Bhaktapur 4 Financial Comptroller General Office Lalitpur 5 Financial Comptroller General Office Bara 6 Financial Comptroller General Office Parsa 7 Financial Comptroller General Office Kaski 8 District Education Office Kaski 9 Division Road Office Pokhara, Kaski 10 MalpotKaryalaya Parsa 11 Division Road Office Kathmandu 12 Directorate of Animal Health Kathmandu 13 Department of Agriculture Hariharbhawon, Lalitpur 14 Inland Revenue Office Pokhara, Kaski 15 District Animal Service Office Bhaktapur 16 District Animal Service Office Kathmandu 17 Forest Office Kaski 18 Forest Office Parsa 19 Forest Office Bara 20 Survey Office Parsa References • • • Financial Procedure Act,2055 Financial Procedure Rules, 2064 Internal Audit Directives,2068 • • INTOSAI, Lima Declaration Section 3 Internal Audit & External Audit, 1977. INTOSAI, Cooperative & Coordination between SAIs & Internal Auditors in Public sector INTOSAI Gov.9150 INTOSAI, guidance for good Governance, Internal Audit independence in the public sector INTOSAI Internal Audit Independence in the public sector INTOSAI Gov. 9140 INTOSAI, Using the work of Internal Auditor ISSAI 1610 Related Web site • • • •