HIP IPS REPORT ON RECORD KEEPING REPORT PRODUCED FOR THE DEPARTMENT OF INDUSTRY AND SCIENCE The purpose of this report is to: 1. establish what is reasonable to request as supporting documentation in order to make an estimate of the adverse financial impact experienced by business entities as a result of the Home Insulation Program (HIP), and 2. recommend a methodology to apply when estimating the value of the adverse financial impact experienced by insulation installers. Note: Neither the Australian Accounting Framework, nor the Australian Accounting Standards provide specific guidance or a methodology to distinctly separate or rank the impact of influences or drivers on the profitability of a business entity. For this reason, the methodology suggested seeks to make a best estimate of a range of influences and their impact over time; and it cannot be taken to be solely reflect the impact of the HIP. BACKGROUND On 3 February 2009, the then Prime Minister, the Hon Kevin Rudd, announced the Nation Building and Jobs Plan, a $42 billion initiative of the Australian Government, released as part of its response to the Global Financial Crisis. A proportionately small part of the Nation Building and Jobs Plan was the Energy Efficient Homes Package (EEHP), which was initially allocated less than 10% of the total amount to be spent under the Plan. Part of the EEHP was a component concerned with ceiling insulation, then named the HIP, which ran for a little over 12 months.1 The Royal Commission, also identified that the decision to effectively terminate the HIP in mid February 2010, had a profound effect on businesses which manufactured insulation and which were engaged in the installation of it.2 TYPES OF BUSINESS STRUCTURES In Australia, there are four main structures that businesses operate under: Sole traders – business setup and controlled by the individual business owner. Partnerships – an association of people who carry on a business as partners and receive income jointly. Trusts – an obligation imposed on a person (trustee) to hold property and assets (such as business assets) for the benefit of others, and Companies – a distinct legal entity whose operations are controlled by its directors and which is owned by its shareholders. The businesses affected by the termination of the HIP could fit within any of the four business structures listed above. 1. 2. Attorney-General’s Department, August 2014 “Report into the Royal Commission into the Home Insulation Program”, p. 1 Attorney-General’s Department, August 2014 “Report into the Royal Commission into the Home Insulation Program”, p. 4 HIP IPS Report on Record Keeping: v3.0 10 February 2015 1 RECORD KEEPING AND REPORTING OBLIGATIONS In order to determine what information could be reasonable to request a business to provide as support for an application for adverse financial impact, a review of the main compliance record keeping and reporting requirements for each business type was undertaken. This review encompassed the requirements for: 1. The Australian Taxation Office (ATO), 2. The Australian Securities and Investments Commission (ASIC), and 3. The Australian Accounting Standards Board (AASB). Each of the compliance organisations listed above had a slightly different definition for business/ financial record keeping, but have the following common elements: 1. Records must correctly record and explain all transactions, 2. Records must be in writing (ASIC specifies these records must be in English), and 3. Financial records include documents such as invoices, receipts, cheques/cheque butts and working papers. Reporting obligations for each business type generally become more rigorous as the size of the business increases, with companies having the highest level of record keeping compliance obligations. Each business structure has different record keeping and financial reporting requirements in order to meet their compliance obligations. The following table summarises the record keeping and financial reporting requirements for each business structure under: 1. The Australian Taxation Office (ATO), 2. The Australian Securities and Investments Commission (ASIC), and 3. The Australian Accounting Standards. HIP IPS Report on Record Keeping: v3.0 10 February 2015 2 Business Structure ATO tax law compliance requirements ASIC Corporations Act compliance requirements Sole Traders Must keep business records which explain all transactions for five years. Nil – does not fall under Corporations Act. Partnerships Must keep business records which explain all transactions for five years. Nil – does not fall under Corporations Act. Trusts Must keep business records which explain all transactions for five years. Nil – does not fall under Corporations Act unless the trustee for the trust is a company. Companies Must keep business records which explain all transactions for five years. Identifies statement of financial position (Balance Sheet) and Detailed Operating Statement (Profit and Loss) as records that a company maintains. Financial records required to be kept for seven years. Financial records include financial statements (not required for small proprietary companies, but recommended.) HIP IPS Report on Record Keeping: v3.0 10 February 2015 Australian Accounting Standard requirements Not likely to fit within the scope of AASB101 as sole traders are unlikely to fit the definition of a reporting entity; and therefore Financial Statements would not be required to be prepared IAW AASB101. However, CPA Australia does recommend in their “Good practice guide for small business” the preparation of a Profit and Loss, Balance Sheet and Cash Flow Statement on a monthly or quarterly basis; as well as on an annual basis. Likely to fit within the definition of a reporting entity in which case Financial Statements are required to be prepared IAW AASB101. In addition, CPA Australia does recommend in their “Good practice guide for small business” the preparation of a Profit and Loss, Balance Sheet and Cash Flow Statement on a monthly or quarterly basis; as well as on an annual basis. Likely to fit within the definition of a reporting entity in which case Financial Statements are required to be prepared IAW AASB101. In addition, CPA Australia does recommend in their “Good practice guide for small business” the preparation of a Profit and Loss, Balance Sheet and Cash Flow Statement on a monthly or quarterly basis; as well as on an annual basis. Financial Statements are required to be prepared IAW AASB101 for entities required to prepare financial reports IAW Part 2M.3 of the Corporations Act. 3 REASONABLE FINANCIAL INFORMATION REQUEST As shown in the previous paragraphs, there is a difference between the compliance requirements for companies (excluding small proprietary companies) and the remaining business types, i.e. sole traders, partnerships and trusts. It is therefore reasonable to expect that companies (excluding small proprietary companies) will have different financial documentation/reports which could be reasonably requested to accompany an application for consideration of an adverse financial impact. It is therefore recommended the four business types be split into two groups in relation to the information which could be requested to be provided, i.e. 1) Group 1: Companies (excluding small proprietary companies*) and 2) Group 2: all other Businesses. *ASIC defines a proprietary company as small for a financial year if it satisfies at least two of the following paragraphs: the consolidated revenue for the financial year of the company and any entities it controls is less than $25 million the value of the consolidated gross assets at the end of the financial year of the company and any entities it controls is less than $12.5 million, and the company and any entities it controls have fewer than 50 employees at the end of the financial year. Some small proprietary companies may have to lodge financial reports with ASIC in certain circumstances. Refer to the list on pages 11-12, which shows which small proprietary companies are required to prepare financial reports under Section 292 of the Corporations Act 2001. The tables on the following two pages show the recommended information to be requested to accompany an application for consideration of an adverse financial impact. HIP IPS Report on Record Keeping: v3.0 10 February 2015 4 NOTE:- As the Australian taxation period for business returns runs from 1 July to 30 June, all financial reports requested will need to be provided for these same periods in order to allow reconciliation between the taxation returns and financial reports and a consistent assessment period for all applicants. Business Type Companies (excluding small proprietary companies) Although the ATO requirement for retention of records is only five years, the requirement for ASIC is seven years, therefore it is reasonable to expect that these companies will be able to provide the following information. Financial Information to be requested For Profit and Loss Information: Financial reports for the Financial Years 2007-08 and 2010-11 including Profit and Loss, Balance Sheet and Cash Flow Statement. Company tax returns and ATO assessment for the same periods. For Capital Investment Information: Depreciation schedules for Financial Years 200708, 2008-09, 2009-10 and 2010-11 used for Company tax returns. HIP IPS Report on Record Keeping: v3.0 10 February 2015 Notes regarding information to be provided The Profit and Loss reports must reconcile to the figures reported in the company tax returns and clearly show for each Financial Year the total Income and Expenses. In addition, it is required to show separately the Income and Expenses directly related to the installation of home insulation. The remainder of the Income and Expenses can be grouped together. Copies of Tax invoices and receipts will not be required to be submitted, but must be able to be produced upon request. Depreciation schedules should clearly show details of: 1) Investment in installation and/or installation related equipment, including purchase date(s) 2) Any change of the valuation of installation and/or installation equipment following the suspension of the HIP, and 3) Any disposal of installation and/or installation equipment following the suspension of the HIP, including details of any loss which may have resulted from such disposals. 5 Business Type Financial Information to be requested All other businesses For Profit and Loss Information: Financial reports for the Financial Years 2007-08, 2008-09, 2009-10 and 2010-11 including Profit and Loss, Balance Sheet and Cash Flow Statement. Notes regarding information to be provided It is recognised that for these businesses, records may not be able to be produced as the required ATO retention period is only five years. Therefore, information should be requested in the following order of preference, where it is outside the ATO retention period: 1. Business or individual tax returns and ATO Assessment for the same periods. Provision of the financial reports listed, along with a copy of the business or individual tax returns for the same periods, noting the Profit and Loss reports must reconcile to the figures reported in the company/trust/individual tax return. In addition, it is required to show separately the Income and Expenses directly related to the installation of home insulation. The remainder of the Income and Expenses can be grouped together. Copies of Tax invoices and receipts will not be required to be submitted, but must be able to be produced upon request. 2. For Capital Investment Information: Depreciation schedules for Financial Years 2007-08, 2008-09, 2009-10 and 2010-11 used for tax returns. HIP IPS Report on Record Keeping: v3.0 10 February 2015 If the business in not able to provide the information requested in dot point 1 above, they should provide a summary document showing their total income and expenses for each of the 2007-08, 2008-09, 2009-10 and 2010-11 Financial Years. In addition, they will be required to provide two transaction lists containing only those transactions relating to the installation of home insulation: 1) a listing of their invoices and 2) a listing of their receipts. Note: Copies of Tax invoices and receipts will not be required to be submitted, but must be able to be produced upon request. It is recognised that for these businesses, records may not be able to be produced as the required ATO retention period is only five years. Therefore, information should be requested in the following order of preference: 1. Provision of Depreciation schedules listed, which should clearly show details of: a. Investment in installation and/or installation related equipment, including purchase date(s) b. Any change of the valuation of installation and/or installation equipment following the suspension of the HIP, and c. Any disposal of installation and/or installation equipment following the suspension of the HIP, including details of any loss which may have resulted from such disposals. 2. If the business is not able to provide the information listed in dot point 1 above, they should provide a summary document for each Financial Year showing: a) a listing of all installation and/or installation related equipment capital purchases, b) a listing of the useful lives for all installation and/or installation related equipment, and c) a listing of all disposals of installation and/or installation related equipment. Note: Copies of receipts will not be required to be submitted, but must be able to be produced upon request. 6 Note- In addition to the financial information that will be requested, business entities will be requested to provide a copy of their ABN certificate which was in place as at February 2009 to add to the verification that they were operating as a home insulation installer at the time the HIP commenced. ADVERSE FINANCIAL IMPACT ON BUSINESSES Following the completion of the Royal Commission, the Government reviewed the report and determined the Government had a moral obligation to those businesses who had an adverse financial impact as a direct result of the HIP. For the purposes of this report, the adverse financial impact includes the impact on revenue and expenses directly related to the HIP and its suspension and capital investments in installation and/or installation related equipment. The HIP commenced in the 2008-09 Financial Year and was suspended in the 2009-10 Financial Year, approximately 12 months later. As a result of the HIP, some businesses had a spike in their revenue and Net Profits in these two Financial Years, which then dropped following the suspension of the HIP. In addition, some business invested in installation and/or installation related equipment which they undertook on the basis that the HIP would continue for some time. Following suspension of the HIP, the future economic benefit which could be obtained from these Assets was reduced, which had a negative impact on these businesses. DETERMINING ADVERSE FINANCIAL IMPACT ON PROFITS For the purposes of this estimation, the period 1 July 2007 to 30 June 2008 will be used as the baseline year, before the introduction of the HIP and the period 1 July 2010 to 30 June 2011 will be used as the comparison year, following the suspension of the HIP. In order to determine the extent of the impact and ensure a consistent and transparent approach, a table should be created to allow the rating/categorisation at set levels of the magnitude of the adverse financial impact. Levels of financial payment can then be allocated to the various ratings/categories in the table. As this assessment is only in relation to the adverse financial impact as a result of the HIP, comparisons should be done using the figures provided which only relate to income and expenses derived from the installation of home insulation. Using the financial information provided by applicants, a comparison should be made between the Net Profits (Revenue – Expenses) in the 2007-08, 2008-09, 2009-10 and the 2010-11 Financial Years. The comparison should be calculated to determine the dollar figure difference and the difference in percentage terms. If there was an increase in the Net Profits between the compared Financial Years, the applicant will have been determined to have not had an adverse financial impact. If there was a decrease in the Net Profits between the compared Financial Years, the applicant will be determined to have had an adverse financial impact and the dollar figure difference and percentage terms difference should be documented in order to be determine which rating/categorisation level the impact fits within. HIP IPS Report on Record Keeping: v3.0 10 February 2015 7 DETERMINING ADVERSE FINANCIAL IMPACT ON CAPITAL INVESTMENTS For the purposes of this estimation, the period 1 July 2007 to 30 June 2008 will be used as the baseline year before the introduction of the HIP and the 2008-09, 2009-10 and 2010-11 Financial Years will be examined to determine if there was an adverse financial impact on Capital investments as a result of the suspension of the HIP. In order to determine the extent of the impact and ensure a consistent and transparent approach, a table should be created to allow the rating/categorisation at set levels of the magnitude of the adverse financial impact. As there are two categories of possible adverse financial impact on Capital Investments, it is recommended to create one table for each possible Capital impact. Levels of financial payment can then be allocated to the various ratings/categories in both tables. As this assessment is only in relation to the adverse financial impact as a result of the HIP, an examination should be done using the figures provided which relate to Capital Purchases, Depreciation and Disposals in relation to installation and/or installation related equipment. Installation equipment and/or installation related equipment falls under the Accounting Standards definition of Property, Plant and Equipment (PP&E). Under Australian Accounting Standard AASB 116 “Property, Plant and Equipment”, after a business has initially recognised the value of their property, plant and equipment, they can choose to revalue it according to one of two models: 1. The Cost Model – which recognise the value of an item of PP&E at its cost less any accumulated depreciation and any accumulated impairment losses (Note: This value is known in accounting as “written-down value”), or 2. The Revaluation Model – which recognises the value of an item of PP&E at its fair value* at the date of revaluation less any subsequent accumulated depreciation and subsequent accumulated impairment losses. *Australian Accounting Standard AASB 13 defines fair value as “the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date.” The possible adverse financial impact on Capital Investments falls into two categories: 1. The loss incurred from the sale of equipment at less than its written-down value, and 2. The loss incurred from the reduction in the fair valuation of equipment as a result of the change in market conditions (as a result of the suspension of the HIP). 1. Loss from Sale of Equipment In order to assess the possible impact from the loss on sale of equipment, an examination of the information provided should be undertaken to identify any related purchases which were undertaken (including ordered but not delivered) during the period 3 February 2009 to 19 February 2010.3 If there was no Capital equipment purchased (including ordered but not delivered) during this period, the applicant will have been determined to have not had an adverse financial impact. If there was a purchase (or purchases made or orders placed) during the examined period, then a review of the information provided needs to be undertaken in order to determine if any of the equipment was 3. Auditor-General’s Department, October 2010 “Audit Report No. 12 2010-11 Performance Audit: Home Insulation Program”, p. 20 HIP IPS Report on Record Keeping: v3.0 10 February 2015 8 sold at a loss (i.e. at less than its written-down value) and if there was a loss, the dollar value of the loss needs to be documented in order to determine which rating/categorisation level the impact fits within. 2. Loss from Reduction in Fair Value In order to assess the possible impact from the reduction in the fair value of equipment, an examination of the information provided should be undertaken to identify any related purchases which were undertaken (or ordered, but not delivered) during the period 3 February 2009 to 19 February 2010.3 If there was no Capital equipment purchased (or ordered but not delivered) during this period, the applicant will determined to have not had an adverse financial impact. If there was a purchase (or purchases or orders placed) during the examined period, then a review of the information provided needs to be undertaken in order to determine if any of the equipment was revalued after 19 February 2010 but before 30 June 2011. The dollar value of the reduction in the fair value needs to be documented in order to determine which rating/categorisation level the impact fits within. TOTAL ADVERSE FINANCIAL IMPACT In order to determine the total adverse financial impact on a business, the evaluation of the impact upon Profits, Loss from the Sale of Equipment and Loss from a Reduction in Fair Value will need to be individually calculated and the output of each calculation applied to the relevant rating table. Each rating table will show the determined value of the adverse financial impact. The value for each of the three tables will then be combined in order to calculate the total adverse financial impact on a business. 3. Auditor-General’s Department, October 2010 “Audit Report No. 12 2010-11 Performance Audit: Home Insulation Program”, p. 20 HIP IPS Report on Record Keeping: v3.0 10 February 2015 9 RESEARCH DETAILS AND LINKS (Accessed between 3-10 February 2015) ATO – RECORD REQUIREMENTS Running a Small business https://www.ato.gov.au/Business/Starting-and-running-your-smallbusiness/Running-your-business/# The ATO advises in their business basics, that a business has ‘transactions where money flow into a business (receipts) and out of a business (payments). These transactions are supported by documents recording the details of the transaction such as tax invoices, wages records, cheque butts and credit card statements; and these documents contain the information a business needs to record. Management of invoices, payments and records https://www.ato.gov.au/Business/Manage-yourinvoices,-payments-and-records/ Under tax law, business records must: 1) 2) 3) 4) explain all transactions, be in writing, be in English, and be kept for five years (although some records such as capital gains transactions need to be kept longer). Period required for record keeping https://www.ato.gov.au/Business/Starting-and-running-yoursmall-business/In-detail/Review-of-your-assessment-and-record-keeping/ For small business entities – 5 years from when the business record is prepared or the transaction is completed, whichever occurs later. Financial Statements http://www.asic.gov.au/for-business/running-a-company/companyofficeholder-duties/what-books-and-records-should-my-company-keep/ The ATO does not require small businesses to submit financial statements, but it does recommend they prepare annually a summary of income and expenses in a Profit and Loss Statement. ATO record keeping and instruction guidelines (in their Company tax return instructions, 2014) states that the ‘records that a company maintains, includes a statement of financial position and detailed operating statement.’ https://www.ato.gov.au/uploadedFiles/Content/MEI/downloads/BUS40078_NAT0069_11_2014.pdf HIP IPS Report on Record Keeping: v3.0 10 February 2015 10 ASIC RECORD REQUIREMENTS ASIC is responsible for the regulation of companies, under the Corporations Act. Businesses which are not a company structure do not fall under the Corporations Act. What books and records should a company keep? http://www.asic.gov.au/for-business/running-acompany/company-officeholder-duties/what-books-and-records-should-my-company-keep/ The Corporations Act in s286(1) states that a company must keep written financial records that: 1) Correctly record and explain its transactions and financial position and performance, and 2) would enable true and fair financial statements to be prepared and audited. Financial records are defined in s9 of the Corporations Act as including: Invoices, receipts, orders for the payment of money, bills of exchange, cheques, promissory notes and vouchers, Documents of prime entry, and Working papers and other documents needed to explain: a. The methods by which financial statement are made up, and b. Adjustment to be made in preparing financial statements. Section 286(2) of the Corporations Act requires financial records to be kept for seven years. FINANCIAL STATEMENTS Certain companies must lodge financial reports with ASIC, including all large proprietary companies and small proprietary companies (if directed to do so). Generally, companies must lodge financial reports if: substantial sums of money are involved the general public has invested funds with the company, and the company exists for charitable purposes only and is not intended to make a profit. Financial reports are required even if the company has not made a profit or traded during the financial year. http://www.asic.gov.au/for-business/your-business/small-business/compliance-forsmall-business/small-business-companies-that-must-lodge-financial-reports-with-asic/ Section 292 of the Corporations Act 2001 (Corporations Act) requires the following entities to prepare financial reports: http://www.asic.gov.au/regulatory-resources/financial-reporting-andaudit/preparers-of-financial-reports/financial-reports/ all disclosing entities public companies companies limited by guarantee (except small companies limited by guarantee) all large proprietary companies** all registered schemes small proprietary companies that are foreign-controlled small proprietary companies or small companies limited by guarantee that we direct to prepare financial reports HIP IPS Report on Record Keeping: v3.0 10 February 2015 11 small proprietary companies subject to a shareholder direction under s293 of the Corporations Act small companies limited by guarantee subject to a shareholder direction under s294a of the Corporations Act ** A small proprietary company is defined by ASIC is it satisfies at least two of the following paragraphs: http://www.asic.gov.au/regulatory-resources/financial-reporting-and-audit/preparersof-financial-reports/are-you-a-large-or-small-proprietary-company/ the consolidated revenue for the financial year of the company and any entities it controls is less than $25 million the value of the consolidated gross assets at the end of the financial year of the company and any entities it controls is less than $12.5 million, and the company and any entities it controls have fewer than 50 employees at the end of the financial year. Some small proprietary companies may have to lodge financial reports in certain circumstances. Refer to the list on page 10, which outlines which small proprietary companies are required to prepare financial reports under Section 292 of the Corporations Act 2001. Under the Corporations Act, financial statements (for example Profit and Loss Accounts, Balance Sheets, Depreciation Schedules and Taxation Returns) are required to be prepared for companies, except small proprietary companies; for which this is not a requirements, but a recommendation (unless ASIC directs the small proprietary company to do so). HIP IPS Report on Record Keeping: v3.0 10 February 2015 12 AUSTRALIAN ACCOUNTING STANDARDS REQUIREMENTS AASB 101 “Presentation of Financial Statements”, prescribes the basis for presentation of general purpose financial statements. It sets out the overall requirements for the presentation of financial statements, guidelines for their structure and minimum requirements for their content. ‘The standard applies to: a) each entity that is required to prepare financial reports in accordance with Part 2M.3 of the Corporations Act, b) general purpose financial reports for each reporting entity, and c) financial statements that are, or are held out to be, general purpose financial statements.’ Entities required to prepare financial reports IAW the Corporations Act are companies, except small proprietary companies. A reporting entity is defined in the standard as “an entity in respect of which it is reasonable to expect the existence of users who rely on the entity’s general purpose financial report for information that will be useful to them for making and evaluating decisions about the allocation of resources.” General purpose financial statements are defined in the standard as “those intended to meet the needs of users who are not in a position to require an entity to prepare reports tailored to their particular information needs.” AASB116 “Property Plant and Equipment”. http://www.aasb.gov.au/admin/file/content105/c9/AASB116_07-04_COMPjun14_07-14.pdf Measurement after Recognition 29 An entity shall choose either the cost model in paragraph 30 or the revaluation model in paragraph 31 as its accounting policy and shall apply that policy to an entire class of property, plant and equipment. Cost Model 30 After recognition as an asset, an item of property, plant and equipment shall be carried at its cost less any accumulated depreciation and any accumulated impairment losses. Revaluation Model 31 After recognition as an asset, an item of property, plant and equipment whose fair value can be measured reliably shall be carried at a revalued amount, being its fair value at the date of the revaluation less any subsequent accumulated depreciation and subsequent accumulated impairment losses. Revaluations shall be made with sufficient regularity to ensure that the carrying amount does not differ materially from that which would be determined using fair value at the end of the reporting period. AASB 13 “Fair Value Measurement” http://www.aasb.gov.au/admin/file/content105/c9/AASB13_09-11_COMPjun14_07-14.pdf Measurement Definition of fair value 9 This Standard defines fair value as the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. HIP IPS Report on Record Keeping: v3.0 10 February 2015 13 The asset or liability 11 A fair value measurement is for a particular asset or liability. Therefore, when measuring fair value an entity shall take into account the characteristics of the asset or liability if market participants would take those characteristics into account when pricing the asset or liability at the measurement date. Such characteristics include, for example, the following: (a) the condition and location of the asset; and (b) restrictions, if any, on the sale or use of the asset. ADDITIONAL RESEARCH Good Practice Checklist for small business – CPA Australia (2012) www.cpaaustralia.com.au/~/media/corporate/allfiles/document/professionalresources/business/good-practice-checklist-small-business.pdf The good practice checklist provides a checklist to ensure businesses are implementing “good business practices”. It recommends businesses prepare a Profit and Loss Statement, Balance Sheet and Cash Flow Statement on a monthly or quarterly basis to show emerging problems in time for corrective actions. Report of the Royal Commission into the Home Insulation Program http://www.homeinsulationroyalcommission.gov.au/Documentation/Documents/ReportoftheRo yalCommissionintotheHomeInsulationProgram.pdf Audit Report No. 12 2010-11 Performance Audit: Home Insulation Program (October 2010) http://www.anao.gov.au/uploads/documents/2010-11_audit_report_no_12.pdf HIP IPS Report on Record Keeping: v3.0 10 February 2015 14 PURPOSE AND INTENDED USE OF THIS REPORT This report is provided to the Department of Industry and Science under the direction to provide consultancy services in the form of independent expert accounting advice to assist in the development of the Home Insulation Program (HIP) Industry Payment Scheme (IPS). The advice was provided by a consultant within CIT Solutions that displayed skills, knowledge, experience and qualifications acceptable to the Department upon signing the Order for Service. The result of this consultancy is documented as this report. This report is provided for the sole purpose of consolidating publicly available information as requested in the Order for Service. CIT Solutions bears no responsibility for the intended use and consequences of that use or relying upon the information provided. HIP IPS Report on Record Keeping: v3.0 10 February 2015 15