Good Practice: Financial Audit and Corporate Governance Guidance
Resource Accounts - Preparing for Audit
November 1997
CONTENTS
Introduction
Part 1: Accounting Systems, the Boundary, Accounting Policies and Materiality
- Accounting systems
- Data extraction facilities
- Systems documentation
- Implementation testing
- Boundary Statement
- Accounting policies
- Materiality
- Materiality in the preparation of accounts
- Materiality as used by the auditors
Part 2: The Opening Balance Sheet
- General audit objectives
- Consolidating assets and liabilities
- Tangible Fixed Assets
- External identification and valuation of fixed assets
- Internal identification and valuation of fixed assets
- Determining the asset population and loading the fixed asset registers
- Validating fixed asset register data
- Intangible Fixed Assets
- Investments, shareholdings and public dividend capital
- Stock and work-in-progress
- Debtors and creditors
- Validation of creditors, debtors, accruals and prepayments: tests of plausibility and age analysis
- Cash
- Provision for liabilities and charges
- Contingencies and commitments
- Taxpayers' Equity
- Separate Trust Statements
- Submitting the Opening Balance Sheet for audit
Part 3: The Summary of Resource Outturn
Part 4: The Operating Cost Statement and Statement of Recognised Gains and Losses
- General audit objectives
- Accounting for income
- Accounting for expenditure
- Notes to the Operating Cost Statement
- Consolidation of income and expenditure
- Management representations
- Submitting the Statement for audit
- The Statement of Recognised Gains and Losses
Part 5: The Cashflow Statement
Part 6: The Statement of Resources by Departmental Aims and objectives
- Departmental aims and objectives
- Reporting performance by objectives
- Attributing costs to aims and objectives
Part 7: The Statement on Internal Controls
Part 8: The first full set of accounts for audit
- Audit planning
- The "Interim" audit
- Pre-audit informal review of accounts matters
- Management review of draft accounts
- The "Final" audit
- Submission of signed account and audit certification
- The NAO's management letter
Appendices
- Chronology
- Opening balance sheet: checklist of supporting papers
- Full set of accounts: checklist of supporting papers
- Proforma letter of management representations for resource accounts
- Select bibliography
Introduction
1 This guide is primarily addressed to departmental accountants responsible for introducing resource accounting. It gives general guidance on how departments should prepare for the external audit of their resource accounts. It is not intended to replace the detailed discussions between departments and their audit teams, but to provide a useful background to facilitate those discussions. It should be seen as complementary to the Resource Accounting Manual (RAM), a detailed knowledge of which is fundamental to the proper implementation of resource accounting. The references in this guide are to the version issued on 24 July 1997.
2 The guide is structured to reflect the Treasury's plans for departments to prepare "dry run" accounts, not intended for publication, for 1997-98 or 1998-99 prior to full audit and publication of accounts for all departments for 1999-00. Parts 1 to 7 address issues likely to arise in the dry run period leading up to the first full set of audited statements. Part 8 deals with the first, and subsequent, set of accounts prepared under a Treasury Accounts Direction. These require a formal audit opinion and will be laid before the House of Commons. For those departments which successfully "dry run" in 1997-98, the Treasury may issue a Direction for 1998-99. For the remainder the Treasury plan to issue Directions for 1999-00.
3 The main themes of this publication are:
- the audit of resource accounts will require different arrangements with departments from those they have become familiar with for the audit of Appropriation Accounts;
- consult the NAO as early as possible on unusual or difficult technical accounting issues, wherever possible providing the department's view;
- the selection of appropriate accounting policies, in accordance with the RAM, is an important early step and one on which the NAO need to be consulted;
- the Opening Balance Sheet is very important, and requires detailed external audit consideration; as such the department's decisions, calculations and validations must be recorded to allow the necessary audit coverage;
- keep the NAO fully informed of developments as they arise to avoid last minute "surprises" to either party during the "final" audit each year;
- ensure the accounts presented for audit have been subjected to documented rigorous validation checks and management review, and are accompanied by good quality working papers.
And although the NAO expect to be consulted and will be pleased to advise and recommend on any issues, management must accept that it is their responsibility to determine whether or not to implement the advice and recommendations.
4 Throughout this guide:
'Evidence' icons highlight those areas where audit evidence requirements are
stated;
'Consultation' icons mark those places where requirements to inform and
consult the NAO are stated;
Shaded boxes in the text contain general information and advice which draw upon the NAO's experience of auditing and advising various clients.
Responsibilities
5 Departments will be required by their Accounts Directions to prepare accounts which are "true and fair". Departmental Accounting Officers acknowledge their personal responsibility for the accounts in signing them; they also have extensive responsibilities for the propriety and regularity of their department's finances and for the keeping of proper records.
6 The Comptroller and Auditor General (C&AG) is the statutory external auditor of departmental resource accounts and is the head of the National Audit Office (NAO). He forms an independent opinion, based on his audit, on the accounts and on the regularity of the financial transactions included in them, and reports his opinion to the House of Commons.
7 The Accounting Officer and his finance team must therefore produce accounts for audit which they can demonstrate show a "true and fair" view of the department's operations and state of affairs at the balance sheet date, and that the expenditure and income have been applied to the purposes intended by Parliament. Accounting Officers and their finance teams therefore need their own assurances that department finances and financial systems are in good order, and should ensure that the accounts are supported and validated by comprehensive reviews before being presented for audit.
8 The NAO, on the other hand, has to perform sufficient additional work to form an independent opinion as to whether or not the C&AG should agree, and report to Parliament, that the accounts do indeed show a "true and fair" view.
9 In planning their approach to auditing a department's resource accounts, the NAO will initially be concerned to ensure that:
- as auditors, the NAO has sufficient knowledge of the business and operations of the department;
- the department's accountants understand their responsibilities and the relationship with the external auditor;
- the department's accountants are familiar with the "true and fair view" requirements of the RAM;
- the department has acceptable financial systems in place, along with arrangements to provide annual assurance on the reliability of such systems; and
- the department has arrangements in place to produce reliable accounts along with adequate supporting working papers to an acceptable timetable, and to ensure key staff are available at all stages of the audit until the accounts are laid.
10 Appendix 1 presents an outline of the chronology of events in the normal accounts/audit cycle, and relates to a department producing resource accounts for audit for the year 1998-99. Some of the events listed could in practice take place earlier than the dates shown. The timings should be taken as an indication of the latest feasible dates, rather than as ideal dates.
11 Audit teams will wish to make sure that departments understand the nature and extent of the evidence they and the NAO will need - in general, the more reliable the evidence provided by the department in support of the accounts, the easier the audit process will be for both the department and the NAO. Appendices 2 and 3 are checklists of the evidence to be included with the accounts provided for audit to the NAO. Audit teams will put the NAO's experience and expertise at the service of departments to provide information and advice.
12 The NAO will welcome feedback on the usefulness of this publication, addressed to audit teams; or to Martin Sinclair, Director, Room B352, National Audit Office, Buckingham Palace Road, London SW1W 9SP.
Part 1: Accounting Systems, the Boundary, Accounting Policies and Materiality
Accounting systems
1.1
The
NAO will wish to satisfy itself that each department implements sound and
auditable financial accounting systems which, together with work on the
opening balance sheet and other aspects of the accounts, will help them
produce accounts which attract an unqualified opinion. Prior to issuing an
Accounts Direction, the Treasury will look to the NAO to confirm the adequacy
of the department's accounting systems to support resource accounts. The NAO
will therefore look to be fully consulted when departments are introducing new
systems or modifying existing ones.
1.2 Departments should recognise that the accounting systems must, for the time being, support a variety of uses, such as:
- cash based Appropriation Accounts;
- Resource Accounts, including
- linkages between departments and agencies;
- the various output cost statements and analyses required by RAM; and
- resource-based Estimates;
- internal management reporting, including
- setting and monitoring resource budgets; and
- interim management accounts.
1.3 The type of system selected by departments will vary according to their accounting information needs. For the smallest departments a 'bolt on' to a cash accounting system may suffice. However, for most departments a fully fledged accruals-based system will be needed to cope properly with resource budgeting as well as resource accounting, enabling managers to track accruals based expenditure against budget.
1.4 Box 1 provides an indication of the main function requirements.
- General Ledger
- Fixed Asset Register
- Stock Ledger
- Purchase Order/ Accounts Payable
- Accounts Receivable
- Cash Management/Analysis
- BACS
- Activity Costing/Time Recording
- Budgeting
- Management Information
1.5 When specifying accounting software, departments should state routines for the production of financial statements as deliverables from the supplier. Box 2 provides the considerations for a proper Chart of Accounts.
The form of the financial statements and the detailed information required should be fully considered when specifying the underlying systems. The following are some of the requirements for resource accounts which should be considered:
Summary of Resource Outturn: to serve this statement and the associated Note "Analysis of Resource Outturn..." - income and expenditure must be analysed according to all elements in each 'request for resources'; income from the disposal of fixed assets appropriated in aid of fixed asset purchases must be separately identified; and amounts payable to the Consolidated Fund must be identified in cash and accrual terms, distinguishing between current and capital.
Operating Cost Statement: separate figures are required for income and expenditure by "Administration" and "Programme" activities.
The Cash Flow Statement: separate figures are needed for cash financing of operating expenditure; payments for fixed assets; receipts from the sale of fixed assets; cash financing must be separated from non-cash financing for reconciliation purposes; financing of expenditure must be separated from financing of capital transactions.
Aims and Objectives: departments must be able to identify the direct costs attributable to the defined aims and objectives as well as identifying the indirect costs which need to be apportioned to them.
Output and Performance Analysis Statement: the accounting records must be able to support the financial information in this statement.
Notes to the Accounts: some notes to the accounts need figures in greater detail to provide the analyses required; examples are:
- movements on fixed assets;
- the reconciliation of net operating cost to control total and net resource outturn;
- the analysis of net resource outturn and net operating cost by function;
- the analysis of net operating costs by spending body.
VAT: Expenditure must be reported inclusive of irrecoverable VAT in the Operating Cost Statement and its Notes; income must be recorded net of VAT; and expenditure capitalised must include irrecoverable VAT.
1.6 The NAO will also be concerned with the following areas:
- the audit trail : a clear and proper audit trail is essential for the accounts to be auditable - see Box 3;
- data selection, entry and extraction facilities;
- documentation; and
- controls and security : see Part 7.
'The ability to track from the financial statements back through the prime accounting records to the underlying transactions and events (and back again) so that management and the auditor may substantiate the individual account figures. This means both cash and accruals while cash-based Appropriation Accounts are still required.'
A proper audit trail:
- assures that all, and only, proper transactions and balances are included in the accounts;
- comprises a positive set of links for each transaction or balance from source to account, and back;
- must cope with bulk postings such as payroll eg through control totals;
- must deal with paperless transactions eg through retention of trail data within the system.
Data extraction facilities
1.7 It is important that the systems, including those outsourced, incorporate facilities to download or otherwise access prime accounting records which support the figures in the financial statements. The systems should therefore include "user-friendly" data extraction facilities which:
- allow users to produce reports without technical support;
- provide logic to support flexible record selection;
- support multiple sort keys;
- produce hierarchical levels of summarised data;<
- permit table look-up and expansion of codes to text;
- list reports to magnetic files and hard copy, as well as to the screen;
- provide output files in a form conforming with the input requirements of common PC spreadsheet, database management, word processing and graphics packages;
- save selection parameters in files for future use;
- list selection parameters as part of the printed report; and
- permit interrogations to be run interactively or in batch mode.
1.8 The circumstances of each department will require different audit approaches. However, the NAO's main data extraction requirements are likely to include the following:
- clear format and location of data;
- computer assisted audit techniques (CAATS);
- downloading or other access to global transaction data; and<
- use of the system's standard enquiry facilities.
- Audit teams will provide the exact details for each department.
Systems documentation
1.9 A good standard of technical documentation is necessary for proper internal control and to support data selection and extraction. System documentation should therefore include:
- an overview describing the purpose, operation and job scheduling of each of the functional modules (General Ledger, Accounts Payable, Fixed Assets etc) comprising the system;
- a high level graphical description of all processes in terms of their inputs and outputs, the programs which process them, and the databases/files/tables created/read/written;
- a list and description of all databases, files and libraries giving standard field names and formats (eg character, binary, packed decimal etc); and
- details of how to use the data extraction and retrieval facility, including worked examples at a level which enables staff with limited technical knowledge to create and run simple interrogation and downloading jobs.
Implementation testing
1.10 Each department must ensure that the new systems, or modifications to the existing ones, meet the specifications and its needs. As department's Internal Audit units are responsible for providing assurance to the Accounting Officers on systems of control, they will almost certainly wish to examine systems implementation issues. The NAO will review the extent to which management has tested the new systems and will look for evidence from the testing carried out that results matched the predictions. Departments should ensure that all aspects are tested, including, for example "close down" and, where appropriate, consolidation.
Boundary Statement
1.11 For many departments, particularly the more complex, it will be very useful to prepare a 'Boundary Statement' as an internal document. This would do two things:
- it would identify all the entities having links with the department (Ministerially, by statute, administratively etc) and articulate the decisions and rationale for including those entities which are to be consolidated; those entities to be recognised in the accounts in some other way such as partial consolidation or as investments; and those entities to be excluded, other than through the funding flows;
- it would identify the range of assets and liabilities the department will account for by reference, for example, to location or divisional responsibilities; it would identify those assets and liabilities where there is doubt as to which entity carries their main risks and rewards, and articulate the agreed decisions on these along with the reasons.
1.12 The Boundary Statement would thus serve as a useful stage in the development of accounting policies, dealt with later. It will also help inform the 'Basis of Consolidation' note in the accounts. Departmental staff will find Financial Reporting Standard 5 "Reporting the substance of transactions" of help in determining asset accounting policies as it provides guidance on the need to recognise "ownership" for accounting purposes instead of applying the strict legal definition. Some boundaries may be difficult to define, and Box 4 provides some guidance.
The Boundary Statement draws upon:
- the boundary definition in the Resource Accounting Manual;
- the department's Estimate and Ambit;
- other authoritative publications on the roles and outputs of the department such as the Government Expenditure Plans;
- detailed knowledge of staff of various specialisms throughout the
department; - discussions with related parts of the department (eg neighbours, customers, suppliers) and other departments.
The main topics to be covered are:
At the 'entity' level
Agencies:
All on-Vote agencies are to be included.
NDPBs:
Which are to be included and which excluded - it is important to have
a clear rationale and the decision may need to be separately determined for
each NDPB on the specific circumstances, based for example on whether it is
within the department's running cost controls.
NHS:
All NHS purchasers, excluding GP fundholders, are to be included.
Subsidiaries, associated undertakings and joint ventures:
Inclusion within the consolidation boundary will be determined by the degree
of "spending control" exercised by the department, and requires
reference to the Treasury. If not consolidated, appropriate treatment as an
investment will need to be considered.
Other elements
Below the 'entity' level the boundary statement may need to define those assets and liabilities the department is to acknowledge in its resource accounts, especially where there is doubt as to which department has the main benefit and responsibility. Assets to appear on departmental balance sheets will include loans from the National Loans Fund. Some further examples are set out below.
The statement may also usefully define the non-voted expenditure and income that is to be included, such as expenditure from Consolidated Fund standing services, and CFERs related to the recovery of costs or returns on investments. The intention is that, taken together departments will account for all material transactions, assets and liabilities under departmental stewardship in either their resource accounts, the "Trust Statements" appended to those accounts or the Pensions Statements. Collectively there should be no omissions.
Fixed assets:
Which land and buildings does the department own? Where a department is the
principal beneficial user of a site, it would normally assume ownership of
all the buildings on the site, and adopt a landlord relationship to other
departments which have the use of certain buildings. Conversely, where the
department is not the principal beneficial user of a site, it would not
normally be deemed the owner of buildings which it occupied, but would
rather be regarded as a 'tenant' of the main site user.
Overseas sites may need special consideration and the arrangement underpinning the basis of occupation will be relevant in determining ownership and whether the land and buildings are departmental assets. Other problem asset areas for the boundary are PFI projects, the Civil Estate, Heritage Assets, Infrastructure Assets and Intangible Assets.
Stocks and Work in Progress:
There may be some stocks held by third parties such as suppliers which
departments will be deemed to own as the main, or sole, beneficial user.
1.13 Having decided the entities to be consolidated, departments need to consider any problems which should be addressed at this stage, including:
- different accounting policies;
- non-coterminous year ends; and
- the need for audited financial statements from these entities to meet their consolidation timetable.
These issues are dealt with further at paragraphs 2.5 to 2.12 below.
1.14
The
NAO will welcome an early opportunity to comment on any proposed Boundary
Statement and the implications identified; or, in the absence of this, any
unusual aspects of a department's boundary, and the implications for the
Accounting Policies to be disclosed in the accounts.
Accounting Policies
1.15
It
is fundamental to the "true and fair" view that the accounting policies
underpinning the financial statements are appropriate to the specific
circumstances of each department and comply with the requirements of the RAM.
In the accounts, the Accounting Officer confirms that appropriate policies
have been selected and applied consistently. In his audit opinion the C&AG
includes a statement asserting that the accounting policies are appropriate to
the departments circumstances, consistently applied and adequately disclosed.
If this is not the case, the opinion might need to be qualified. The NAO will
therefore welcome early discussions on the accounting policies to be applied
and disclosed in the accounts. Such policies should be reviewed each year -
new policies may be required and may need to be disclosed, and some policies
may need to be revised. The NAO should be consulted on any such proposals.
1.16
The
NAO will expect to see accounting policies disclosed for all material groups
of assets, liabilities, income and expenditure. The usual policy areas
disclosed in accounts are shown at Box 5 depending on the circumstances of
each department. The NAO will therefore welcome discussions on accounting
policies proposed not addressed at Box 5, or where some of the items in Box 5
are considered inappropriate. Guidance on them is included in the RAM and the
underlying accounting standards.
- The Basis of Accounting
- The Accounting Convention
- Basis Of Consolidation
- Tangible Fixed Assets
- Intangible Fixed Assets
- Depreciation
- Stocks and Work-in-progress
- Research and Development
- Grants Receivable
- Operating Income
- Grants Payable
- Non-cash expenditure
- Foreign Exchange
- Pensions
- VAT
1.17 In order to ensure consistency across the department and from year to year, the NAO will also expect all the accounting policies, practices and treatments, including those for non-material areas, to be standardised and disseminated to all staff involved. This is usually done in the form of an Accounting Manual as required by paragraph 1.4.2 of the RAM.
1.18 Once acceptable accounting policies are in place, the NAO's audit will address whether or not they are being applied. Material failure in the application of an accounting policy is likely to result in a qualification of the accounts. Management should therefore ensure all accounting policies are being observed.
Materiality
1.19 Materiality is a concept which is central both to the preparation and audit of accounts. It provides a basis for determining how accurately transactions and balances need to be disclosed, and it underlies all professional standards on financial reporting. Materiality is defined as follows in the Accounting Standards Boards "Statement of Principles for Financial Reporting":
"Information is material if it could influence users' decisions taken on the basis of the financial statements. If that information is misstated or if certain information is omitted, the materiality of the misstatement or the omission depends on the size and nature of the item in question judged to the particular circumstances of the case."
1.20 A further definition is provided in Statement of Auditing Standard 220 "Materiality and Audit" issued by the Auditing Practices Board, as follows:
"An expression of the relative significance or importance of a particular matter in the context of the financial statements as a whole. A matter is material if its omission or misstatement would reasonably influence the decisions of an addressee of the auditors' report; likewise a misstatement is material if it would have a similar influence. Materiality is not capable of general mathematical definition as it has both qualitative and quantitative aspects."
1.21 It is important to recognise therefore, that materiality is a relative concept, and that it applies in the context of the way in which the user of the information might have acted differently had material error or omission not been present. Materiality may be considered to have three separate elements as follows:
- by value: in relation to a particular figure in the accounts, this element of materiality seeks to answer the question "By how much would this figure have to be inaccurate to distort the users overall view of the accounts?" Obviously, an error of a few thousand pounds might be material to a small account, whereas an error of the same absolute size might be immaterial to the view given by the accounts of, say the Ministry of Defence or the Department of Social Security;
- by nature: the question asked here is "Does the error affect a figure in the accounts which users expect to be stated with a high degree of accuracy or which is likely to be of great interest to them?" This recognises that in any set of accounts some s are more material than others; examples are - senior staff and board members' emoluments; the audit fee and the amount payable to the Consolidated Fund;
- by context: the question being addressed here is "Is the error material because of its implication for other aspects of the accounts?" In dealing with resource accounts the following errors, for example, even though they might be small in absolute terms would be likely to be material by context: errors in stated amounts which, if not adjusted, would
- trigger the payment, or non-payment, of bonuses to senior staff;
- result in the reported achievement of a key performance measure when it has not, or that it has been missed when it has, in fact, been achieved; and
- indicate that the department has net current assets when it has, in fact, net current liabilities.
Materiality in the preparation of accounts
1.22 Materiality is defined in terms of the accounts as a whole. However in arriving at this view, the preparers of accounts will have had to apply materiality considerations when deciding on the detailed accounting policies to be followed in compiling the accounts. Examples of such materiality decisions include those which set the capitalisation threshold, whether stock holdings are sufficiently small to allow items for consumption to be expensed on purchase rather than accounted for in detail as stock, and the degree of accuracy to which accruals and prepayments at the year-end need to be estimated.
1.23
Materiality also comes into play when management review the outcome of the
accounts preparation process. At that stage, management have to decide whether
errors which have come to light as a result of their review are sufficiently
material, individually and/or in aggregate, to merit amendments being made to
the accounts prior to them being submitted for audit. If management decide
against amending the accounts, the auditors expect this decision to be made
known to them together with a list of the unadjusted errors.
1.24 There is one area associated with accounts preparation where materiality considerations do not apply - this is in the area of reconciliations. The purpose of a reconciliation is to reconcile, and thus the failure to pursue differences on reconciliation on the grounds that they are small defeats the purpose of the exercise. As a minimum there would need to be a sustainable and acceptable explanation of any such differences.
Materiality as used by the auditors
1.25 Auditors use the concept of materiality both at the planning stage of the audit, when deciding what and how much work needs to be done, and in evaluating the results of the audit. These are sometimes known as "planning materiality" and "reporting materiality" respectively.
1.26 "Planning materiality" is primarily concerned with materiality by value. The auditor calculates the highest level of "tolerable error" for the estimated accounts as a whole, that is the highest amount which would not distort the overall view of the accounts given to the addressee of the audit report. Since auditors rarely examine all transactions or balances, allowance is made within this "tolerable error" leaving only a fraction for the incidence of errors identified during the audit. The auditor then assesses the risk of this level of error in the balances and transactions and focuses the audit work accordingly. This threshold, which is very dependent on the audit approach adopted and therefore rarely disclosed by the auditor, does mean however that figures which are "95 per cent right" or thereabouts will, almost invariably, not be good enough.
1.27 "Reporting materiality" applies at the end of the audit when all errors are evaluated and viewed in relation to the known outturn on the account. "Planning materiality" and "reporting materiality" only really differ where outturn is significantly different from that estimated. It is also at this stage that the auditors consider their findings "by nature" and "by context", and errors or omissions may be considered material which otherwise by value would not.
1.28 There are a number of issues considered by auditors when evaluating the audit findings:
- an error or omission found in one area such as stock may in itself not be material; but if errors have also been found in other areas such as debtors or fixed assets, then the total errors may exceed the materiality threshold. Because of this effect, all errors and omissions are recorded during the audit for consideration when the results across all areas of the account are assessed against the reporting materiality;
- unadjusted errors identified by the department need to be taken into consideration by the auditors when evaluating the audit findings against reporting materiality; departments should make this information available to the auditors; and
- audit work often involves the use of sampling techniques, ie a statistically representative number of transactions or balances are examined during the audit with the aim of drawing conclusions about the populations from which they were drawn. If errors are found in the sample, then sampling theory requires the effect to be extrapolated across the entire sampled population. As a result, an error which appears immaterial in isolation could actually represent a material error in relation to the total figure being audited.
1.29 Once all the errors and omissions found during the audit have been identified, the auditors schedule them into what is colloquially known as the "overs and unders schedule". This summarises all the unadjusted monetary errors and omissions and enables a view to be taken as to their net effect on the accounts. If the net effect is that the total error is less than the reporting materiality threshold, and there are no errors or omissions which are material by nature or context, then an unqualified audit opinion should result.
1.30 If, on the other hand, the net effect is greater than the reporting materiality threshold, the audit team will discuss with the department what adjustments can be made to bring the overall level of error down to an acceptable level. However not all errors are capable of being adjusted - for example those which stem from a failure of "regularity" can rarely be rectified. And those which are calculated from a statistical sample may require the department to carry out some extensive remedial work to remove the extrapolated effect of the sample. For whatever reason, where material unadjusted error remains in the accounts a qualified opinion will result. This will normally be accompanied by a report by the C & AG to Parliament explaining the background to the qualification.
1.31 Different materiality considerations apply to the audit work on opening balance sheets. In such cases auditors will normally set a much lower level of materiality to reflect the fact, amongst other things, that this is the first time that such balances will have been subject to audit and there is no accumulation of knowledge and experience on which to base the normal level of materiality. This also allows the auditor in future years to concentrate audit work on testing the movements on the balance sheet, in the safe knowledge that the opening balances were checked with great thoroughness. Departments should recognise as a result, that the auditors may require finer adjustments to the opening balances.
Part 2: The Opening Balance Sheet
2.1 The Balance Sheet (Schedule 3) is designed to provide a financial picture of the assets and liabilities of the department at a point in time. The form of the Balance Sheet used is similar to that required by the Companies Act. The only changes are in the terminology used to describe certain line items which has been revised to reflect the central government context of the information.
2.2
The
first balance sheet produced - called the Opening Balance Sheet - will need to
be prepared for the start of the dry run year; that is at 1 April 1997 for
those departments preparing dry-run accounts for 1997-98, and as at 1 April
1998 for those dry-running in 1998-99. This will be subject to rigorous audit
examination because future audits depend upon the accuracy of this position.
And Treasury will look to the NAO for assurance from their audit of this
opening position as part of the progress to an Accounts Direction. To ensure
that this audit work proceeds smoothly, it is vital that audit teams are
consulted by departments when they plan the preparation of their Opening
Balance Sheets. No formal opinion will be provided on this balance sheet, but
the results will be discussed with the department and adjustments may be
required. However, the final view on this balance sheet and any adjustments
made as a result of the audit will be taken on completion of the audit of that
year's closing position.
2.3 Box 6 provides the main audit requirements for newly created opening balances.
Opening Balances need to:
- be recognised and valued according to the chosen accounting policies;
- be accurately entered into the accounting system;
- be consistent with any figures brought forward from the cash-based accounts eg suspense accounts;
- have clearly identifiable, documented sources;
- have evidence of management review for ownership, accuracy and completeness;
- have evidence of physical verification, where appropriate.
General audit objectives
2.4 In examining whether the assets and liabilities as stated in the accounts meet the requirements of the audit opinion, the NAO will determine whether they comply with the general audit objectives outlined in Box 7. As part of this, they will consider whether the combination of systems, controls, validations and management reviews address these objectives.
- Completeness: there are no unrecorded assets, liabilities, events or other undisclosed items;
- Existence: an asset or liability exists at a given date;
- Rights and Obligations: an asset or liability properly pertains to the department at a given date;
- Valuation: an asset or liability is recorded at an appropriate carrying value;
- Presentation and Disclosure: an item is disclosed, classified and described in accordance with the RAM.
Consolidating assets and liabilities
2.5 The RAM requires departments to consolidate all the entities within the departmental boundary, applying FRS 2. Consolidation has been defined as:
"A method of accounting under which the information contained in the separate financial statements of the parent and its subsidiaries is presented as though for a single entity. After any consolidation adjustments for such matters as minority interests, intra group transactions and to obtain uniformity of accounting policies, the amounts for assets and liabilities, revenue and expenses in the individual statements are added together on a line by line basis to form the consolidated accounts."
2.6 The following are important considerations for departments when preparing consolidated accounts:
- that the financial statements of entities as used for consolidation purposes are suitable for inclusion in the department's resource account ie they must be signed and audited before being consolidated into the resource accounts;
- that any re-classification of income, expenditure, assets or liabilities of entities being consolidated as required to support resource account disclosures is feasible and auditable;
- that other information to support additional resource account disclosures from entities being consolidated is available and auditable;
- that agencies presently dry-running will be ready in time and can provide the information required for consolidation;
- that the accounting periods of all the entities are coterminous and they have uniform accounting policies - see below;
- the process of adjusting assets and liabilities - see below; and
- the process of adjusting revenue and expenses - see Part 4.
2.7
Since most public sector entities operate to an April to March accounting
year, the problem of different accounting periods is unlikely to be
significant. The Treasury have asked to be consulted on all cases where the
year-ends differ, and equally the NAO would wish to be involved. Concerns
about uniformity of accounting policies should also be minimised in that all
entities should be complying with RAM. This requirement should not be seen as
precluding some variation, for example in the choice of capitalisation
thresholds or depreciation rates. The NAO will look for evidence that
departments have carried out a review of the accounting policies of the
entities within their boundaries, and will welcome early discussion on any
policies deemed inconsistent.
2.8 The pre-consolidation adjustment of assets and liabilities needs to be carefully considered where, for example, fixed assets or stock are sold or transferred to entities within the boundary or there are amounts owing to and from the parties. The basis of pricing items for sale or transfer is crucial, and any profit element should be removed before consolidation. Thus the first part of the process will be to ensure such sales or transfers are identified, for example as a result of machinery of Government changes. The NAO will wish to see that reliable arrangements have been put in place, either manually or as part of the underlying systems, to capture this data. In most instances, however, any transfers of assets do not involve any element of profit and adjustments will not be necessary.
2.9 Where undertakings within the boundary owe amounts to each other, these amounts must be cancelled out before consolidation to avoid overstating assets and liabilities. Any provision by one party against such debts must also be removed before performing the consolidation.
2.10
Additional
problems may arise where "joint ventures" are involved, especially as this is
a term which can mean a number of different things. The treatment will depend
on spending control requirements and the Treasury require to be consulted on
all such cases, except where the entity is deemed an extension of the
department, in which case it will be fully consolidated. The NAO will also
wish to be consulted. If deemed to be within spending controls there are
several options:
- the joint venture is a subsidiary in which case the assets and liabilities should be consolidated in the normal way;
- the joint venture is an associate in which case the assets and liabilities should be consolidated on the equity basis defined in SSAP1 as amended;
- the joint venture is neither a subsidiary nor an associate - in which case it should be treated either as an investment or consolidated on a proportional basis where the department consolidates a share of the assets, liabilities, revenue and expenses in proportion to its share in the venture.
2.11
In examining the results of consolidation the NAO will wish to see that any
findings from the external auditor of the entity being consolidated,
especially those affecting the audit opinion on the entity, have been taken
into consideration.
2.12 Although FRS 2 considers the matter in terms of other entities producing financial statements, some larger departments may be involved in consolidating self accounting units which are themselves part of the department. The same considerations apply, but the NAO will need to discuss and agree with these Departments the stages of external audit involvement. Clearly there are risks in consolidating unaudited information, and the department and the NAO may wish to carry out some pre-consolidation audit. This has implications for the timetable, and has not been allowed for in Appendix 1.
Tangible Fixed Assets
2.13 A Tangible Fixed Asset is defined as "an asset held for use on a continuous basis in the departments activities; it has a physical identity and an expected economic life of more than one year." The normal categories of tangible fixed assets are:
- Land and Buildings;
- Plant and Machinery;
- Fixtures, fittings, tools and equipment; and
- Assets in course of construction.
2.14 Tangible Fixed Assets need to be:
- recorded in fixed asset registers (FARs) with an identifiable audit trail eg reference numbers and labels;
- reconciled to general ledger balances;
- subjected to annual management checks for existence/continuing use/remaining life/ obsolescence etc;
- revalued annually using appropriate indices and considered for any permanent diminution in value ("impairment");
- subject to proper purchasing procedures to ensure that all additions are identified and recorded; and
- subject to proper sales or write-off procedures to ensure all disposals are properly recorded.
In addition, land and buildings should be subject to professional external valuation at intervals of not more than five years.
External identification and valuation of fixed assets
2.15
The
requirements for the valuations of land and property are contained in the
Treasury publication 'Capital Charging for Property - Accounting Guidance'.
The NAO will wish to see any Statements of Requirement for external valuers.
2.16 The illustrative timings in Appendix 1 portray a scenario in which the valuer is chosen without competition. This is not a NAO recommendation, but a convenient simplification. Competition may mean that more time should be allowed in the period leading up to the issue of the Statement of Requirement. And there are timing issues associated with exploration of the availability of valuers, EU contract requirements, assembly of a suitable tender panel, &c, which are not represented in Appendix 1.
2.17 Box 8 presents some guidance on the tasking of professional valuers.
- The classes of asset to be valued should be defined
- The basis of valuation should conform with paragraphs 3.2.10 to 3.2.13 of RAM.
- The requirement should be to value all defined assets on (specified) site(s), NOT to value assets in a given list. A draft list may be provided, but it should be part of the requirement that the valuers establish that it is complete.
- The valuers should be required to provide, for each asset, both a value and an estimated useful life.
- Implementation of a capitalisation threshold implies that a proportion of the asset value will not be included in the Balance Sheet. Departments have to make a judgement about whether the proportion of assets excluded by application of the threshold is acceptable. For this judgement to be made a relatively low threshold must be used in the valuation. Subsequent analysis may reveal that a higher threshold is acceptable for compilation of the departments Fixed Asset Register.
- For the first valuation, it is important not to pre judge the threshold to be used for the fixed asset register and then value assets covered by that threshold. The threshold for inclusion in the valuation report should be applied to gross replacement cost (not net book value).
- Where there is a large population of small value assets (eg a network of computer terminals), there may be scope for treating a group of items as a single asset.
- Valuation reports should state explicitly whether valuations are inclusive of VAT. Non-recoverable VAT should be included in valuations arrived at on the basis of replacement cost, but not in (any) valuations arrived at on the basis of disposal (market) value.
- Estate valuers will follow RICS guidelines which generally require them to use net current replacement cost as the basis of valuation. This usually results in an Existing Use Value (a variant of open market value); and where not, Depreciated Replacement Cost. In some cases a modern equivalent asset valuation will be appropriate. The valuation report must state clearly which basis has been used for each property.
2.18
Obtaining a valuation report does not absolve management from its
responsibilities. The report should always be subject to review by management
for reasonableness, and, for second and subsequent valuations, for
consistency. The valuation report is an important source of audit evidence.
The NAO will wish to acquire a copy soon after the report has been delivered
to the department. Electronic copy on disk would be most welcome.
Internal identification and valuation of fixed assets
2.19
Many of the principles set out in Box 8 also apply when departments use their
own staff to identify and value assets. However, departmental staff should not
be used to value property. Other assets may be valued by reference to historic
cost, where sufficiently reliable evidence exists, updated by an appropriate
price index and depreciated according to the chosen accounting policy. For
further information see the Treasury publications 'Accounting for Capital
Assets - A Working Draft of Guidance' and the subsequent Supplement (currently
under review). Alternatively, other assets may be valued by reference to
appropriate catalogues giving current prices. Such catalogues will be
important audit evidence, and appropriate trails need to be provided to these
sources and any indexation adjustments.
Determining the asset population and loading the fixed asset registers
2.20
The
NAO will wish to be consulted on the departments choice of capitalisation
threshold; and on (any) plans to extrapolate valuation data to assets not
covered by valuers.
2.21
The reconciliation of initial Fixed Asset Register value totals to the
valuation reports is important audit evidence. The NAO will seek assurance
that such a reconciliation is being generated.
2.22 Care must be taken to establish the correct cut-off point for the reckoning of disposals, additions, and enhancements. All and only those transactions which took place after the valuation date should be reflected in the Fixed Asset Registers after the valuation data have been loaded.
Validating fixed asset register data
2.23 Departments should validate the Fixed Asset Register figures which underpin the Opening Balance Sheet. For land and buildings, evidence will be needed to show the source of information and procedures followed to establish the completeness of the records. For other fixed assets, validation may be achieved by circulating FARs to inventory holders, asking for confirmation of the accuracy and completeness of the records. Comments should also be sought on any circumstances bearing upon valuation, such as undue deterioration in physical condition, technical obsolescence, or other marked reduction in expected use of the asset as compared with the depreciation profile. Inventory holders should be required to respond with statements to the effect that, subject to stated amendments, they believe the FARs to be accurate.
2.24
The requests to inventory holders should remind them that physical existence
checks are to be conducted by staff independent of those responsible for
custody of the assets. Where asset populations are large, it may not be
feasible to conduct all verifications at the Balance Sheet date. A phased
programme of verification will normally generate sufficient audit evidence.
Departments should discuss their proposals with the NAO, who will be
particularly interested to study any proposed programme which does not provide
for 100% coverage each year.
2.25
The confirmations from inventory holders provide important audit evidence. The
NAO will seek assurance that they are being generated.
2.26 An audit trail must be retained of any FAR adjustments arising from circulation of FARs to inventory holders.
2.27
In most cases there will be some asset movements (additions, enhancements, and
disposals) between the original valuation and loading of FARs, and the Balance
Sheet date. Lists of additions, enhancements, and disposals should be
scrutinised within the finance function for conformity with expectation.
Commercial FAR software packages have facilities for producing such lists. For
other FARs it may be necessary to compile them manually. The lists might also
- perhaps only on an exception basis - be referred to inventory holders for
confirmation that they are correct and complete, and for advice on apparently
anomalous features. The NAO will require copies of the lists, together with
documentation of the validation procedures performed.
2.28
In most cases depreciation and revaluation (indexation) will be recorded
between the original valuation and the Balance Sheet date. Departments should
check these figures for reasonableness - some guidance is given in Box 9. The
documentation of this work provides audit evidence.
Depreciation and revaluation will usually be computed by the FAR software. Departments must understand how the software performs these calculations.
Broad tests of reasonableness for depreciation should be performed separately for each asset type. The initial test is to calculate the implied average asset life from the book aggregates for asset value and depreciation. These should be compared to expectation and in particular to the asset lives to be disclosed in the Accounts for each class of asset. Anomalous figures should be investigated.
Further confidence in the depreciation amounts can be established by comparing the results of the above test for various locations. Reasons for significant variances should be established and recorded. Anomalies should be investigated.
2.29 Departments have to determine an accounting policy for capital enhancements, that is an approach to deciding the extent to which outlays such as those on maintenance and repair of buildings, should be expensed (charged to the Operating Cost Statement) in year, or capitalised as asset enhancements.
2.30
Guidance on the capitalisation of enhancements is provided in Exposure Draft
51 ('Accounting for Fixed Assets and Revaluations'), the ASB discussion paper
'Measurement of Tangible Fixed Assets' and 'Accounting for Capital Assets: A
Working Draft of Guidance' (currently under review). There is much room for
judgement in interpreting the guidance to the circumstances of each
department. The NAO will welcome early consultation on the matter.
2.31
Care needs to be taken in capitalising other costs of acquisition such as the
cost of the staff involved. The NAO will welcome discussion on any proposals
in this area.
Intangible Fixed Assets
2.32 There are three basic categories of intangible fixed assets:
- development expenditure;
- goodwill; and
- concessions, patents, licences, trade marks and similar rights and assets.
2.33
Where appropriate, development expenditure may be deferred to future periods -
paragraphs 3.10.2 to 3.10.5 of RAM refer. The NAO will wish to see that the
criteria (listed in SSAP 13 and at 3.10.2 (b) of RAM) have been met and that
the period of amortisation is appropriate
2.34
Goodwill and other intangibles are to be accounted for in accordance with FRED
12, a summary of which is provided at paragraphs 3.10.10 to 3.10.15 of RAM.
The NAO will wish to be fully consulted on the recognition and accounting for
these assets.
Investments, shareholdings and public dividend capital
2.35 Fixed asset (ie longer term) investments, including shares in limited companies, should be reported at market value unless this is not available when historical cost should be used. The basis of market valuation needs to be provided by way of a note, and the source and calculation are important audit evidence. Movements in valuation, other than impairment, need to be recorded through the Revaluation Reserve. The NAO will wish to see that arrangements are in place to capture this information, and will expect share certificates to be available as audit evidence.
2.36
Short term investments, including the use of surplus funds, in marketable
securities should be recorded as current assets at market value. Movements are
included in the Operating Cost Statement. The calculation of market value is
important audit evidence.
2.37
Public Dividend Capital (PDC) and loans issued to public bodies not
consolidated in the resource accounts should be reported at historical cost.
Movements need to be recorded by way of a note, and the NAO will wish to see
that arrangements are in place to capture this information.
Stock and work-in-progress
2.38
The requirements for stock and work in progress holdings are provided at Box
10. 2.39 The NAO should be consulted on the determination of
the classes of item to be included on the balance sheet as stock, or where
stock is not deemed to be material to the balance sheet and is to be expensed.
Where Stock is material this will require:
- stores accounting procedures along with records of receipts and issues, and the opening and closing balances held including values;
- reconciliation to the general ledger balance;
- properly evidenced stocktakes periodically, and ideally at the year end;
- annual consideration of obsolescence/write-off;
- proper procedures to control receipts, issues and write-offs.
Where Work in Progress, limited to re-chargeable work, is material this will require:
- an auditable job costing system to track costs including
- records of labour input
- overhead absorption rates
- additional direct costs.
2.40
Requirements for stocktaking to provide sufficient evidence of the existence
and condition of stockholdings are generally more onerous than those designed
to meet S4 of the Exchequer and Audit Departments Act 1921 with which some
departments may be familiar. There is a presumption that the annual
stocktaking programme must cover the great majority (by value) of the stocks.
Ideally the stocktake should be at the year end; otherwise an annual rolling
programme may be sufficient but the NAO should be consulted. In assessing the
likely sufficiency of the audit evidence which will be available, the NAO will
review with the department any stocktaking programme, and the history and
treatment of discrepancies found. Agreement on the stocktaking strategy needs
to be reached before the Balance Sheet date: should NAO's subsequent audit
work reveal that there is insufficient evidence to support the account
balance, it may then be difficult or impossible to generate the evidence
required. Members of the audit team may wish to attend some stocktakes as
observers and will therefore need to be advised of the department's
stocktaking programme.
2.41
Unusual stock such as stockpile goods, military reserves, confiscated
property, foreclosed property and intervention stocks require careful
consideration. The NAO will welcome early discussions on these areas, along
with any other unusual aspects such as decisions on when stock is regarded as
issued or consumed.
2.42 A record should be kept of the reconciliation of the physical counts to the book records showing the treatment of all discrepancies identified. An audit trail should be retained of any write-offs and amendments to stock records.
2.43
Equally importantly, this audit trail will also need to demonstrate the value
attributed to the stock and be able to demonstrate that this meets the
requirement of being current replacement cost (where held for continuing use)
or the lower of cost or net realisable value as per RAM paragraphs 3.12.1 to
3.12.15.
2.44
Where Work in Progress on long term contracts (RAM paragraph 3.12.7) is
material, the proposed basis of valuation should be discussed with the NAO.
Debtors and creditors
2.45 Debtors are amounts receivable as at the Balance Sheet date no matter when they fall due for payment. They are normally sub-divided into Trade Debtors, Other Debtors, Prepayments/Accrued Income and Deposits and Advances. They should be stated at their net realisable value after allowance for bad and doubtful debts. Creditors, on the other hand, are amounts payable as at the Balance Sheet date. They are normally sub-divided into Trade Creditors, Other Creditors, Accruals and Deferred Income and Short Term Loans, Borrowing and Provisions. They should be stated at the full amounts due.
2.46 Box 11 provides the requirements for Trade Debtors and Creditors.
Box 11: Trade debtors and creditors - requirements
Trade Debtors, if significant, will require:
- a sales ledger system, diferentiating between "trade" and "other";
- the means of generating an aged analysis of debtors;
- procedures for review of, and policy for providing for, bad and doubtful debts;
- controls to ensure that debts cannot be written off without propoer authority;
- adequate separation of duties;
- ready audit access to system-held invoice information or hard copy; and
- ability to download listings.
Trade Creditors, if significant, will require:
- a purchases / purchase order ledger system;
- unique physical referencing between orders, goods received notes (GRNs) and invoices;
- ready physical access to documents;
- adequate separation of duties;
- access to listings of balances by supplier and by invoice;
- ability to age-list balances; and
- ability to download listings.
2.47 Where the department operates an accruals accounting system, debtors and creditors are generated directly from the books. If the accounting system is a cash accounting one, a special exercise is needed to identify those invoices received and issued before the year end for which the payment is made - or the receipt received - in the following financial year.
2.48
Identification of accruals and prepayments is a less mechanical process,
requiring detailed knowledge of the departments business. Box 12 provides some
guidance. It is important to remember that there should be no netting off of
related debtors and creditors; this practice (known as offset) is only
allowable in special circumstances. If in doubt, the NAO would be pleased to
advise. Remember also that debtors and creditors need to be split into amounts
receivable/payable within one year and after more than one year for the
related notes, and, where material, on the face of the account.
Box 12: Identifying accruals and prepayments
Focus effort on those areas where significant balances are likely to arise
Significant Accruals are likely to arise in the following areas of
Expenditure:
- industrial pay
- retentions on contracts
- Property Management
- any other large contracted-out functions
- utilities
Prepayments are usually much less significant than accruals. They can arise on:
- rents payable
- over-payments and pre-payments of grants
- some utilities (especially telephone charges)
- maintenance contracts, eg for computer equipment
- postal franking machines.
2.49
The NAO will welcome an early opportunity to review the departments initial
analysis of its expenditure and the resultant identification of debtors and
creditors; and to review the methodology for calculating major accruals and
prepayments. The NAO will need copies of documentation supporting the
calculation of major accruals and prepayments.
Validation of creditors, debtors, accruals and prepayments: tests of plausibility and age analysis
2.50 Plausibility checks of creditors, debtors etc. are a normal part of the validation procedures which are intrinsic to accounts production. Accountants responsible for initially producing the figures should apply plausibility tests and submit the results with the figures to supervising accountants for review. Reviewers must use their own experience and knowledge to test the plausibility of the figures, and to appraise the results of the plausibility tests which have been reported to them. Box 13 provides some guidance on plausibility checks.
Initial plausibility tests
Suppliers who are regularly paid monthly are likely to be creditors for
(about) a month's supply at the year-end;
For goods and services supplied continuously such as utilities or contracted-out services, there should normally be a creditor/ accrual item in the Balance Sheet;
Staff advances can be a significant debtor at the year end - there must be a process of validating the amounts outstanding as shown in the accounts;
The review of provisions should identify those which have become short term and moved into creditors.
Other sources of creditors can be in respect of pension costs, including early retirement commitments and any lump sums due.
There may not always be a debtor in respect of every source of income, but where there is no debtor for the larger income sources, it is worth confirming that this is correct and recording the explanation.
Departments may have spreadsheet analyses of creditors &c by expenditure ledgerhead. It can then be a straightforward matter to insert the corresponding expenditures for the previous period; and to compute eg creditor: expenditure ratios. Suspicious absences of creditors or accruals balances may be revealed, as may anomalous ratios.
Checks by reviewing accountants
Where there are two or more sub-accountants, comparison of their figures
should be considered. This can be useful in checking for completeness when,
for example, it is known that some sub-accountants are more experienced than
others. The reasons for major variances should be sought. Comparisons are
particularly useful if the ratios described above have been computed by each
sub-accountant.
2.51

The NAO will expect the results of plausibility checks to be made available to
them when the Opening Balance Sheet is presented for audit. Audit teams should
be consulted on methodology at an earlier stage.
2.52
Analysis of creditors and debtors by age is part of the departments validation
of Balance Sheet figures. Commercial accounts software will offer 'aged
creditors' and 'aged debtors' reports. Old balances should be investigated to
establish the substance of the liability or the recoverability of the debt.
Debts which are assessed as bad must be written off; and consideration given
to making a provision for doubtful debts. The basis of any provision,
including a "nil" provision, is important audit evidence; as are the 'aged'
reports, the record of consideration of them and the investigations made and
action taken. Where debtors include staff loans for example, departments
should confirm the amount outstanding with each member of staff at least once
a year (and preferably at the year-end).
2.53
For significant debtors, the NAO will need independent evidence of the
validity of the debt, and may therefore make direct contact with the debtor
(after consultation with the department). Where this is likely to be
significant, the NAO will need the schedules of debtors at a very early stage
(before the accounts are submitted for audit) so that this process can be
completed with the rest of the audit. Often the only significant debtor will
be HM Customs and Excise, i.e. recoverable VAT paid in January, February, and
March. Here the department should reconcile the debtor to the VAT recovery
received in May of the following financial year - this is important audit
evidence.
Cash
2.54 Cash consists of cash in hand, including material stocks of postal orders and stamps, and deposits with the Paymaster and other financial institutions which are repayable on demand. Balances not yet drawn down from the cash voted by Parliament are not included. Deposits, including those denominated in foreign currencies, are repayable on demand if they can be withdrawn at any time without notice and without penalty or if a maturity or period of notice of not more than 24 hours or one working day has been agreed. Deposits not meeting these requirements should be included in debtors or identified separately as short term investments.
2.55
The NAO will wish to see that proper arrangements are in place to ensure
reliable figures are provided for cash in hand at the year end. This will
normally entail evidenced cash counts and stocktakes of the other forms of
cash. The NAO will also wish to receive direct confirmation of year-end
balances from all commercial banks employed by the department and other bodies
within its boundary. This is normally done via requests to the banks from the
department, and audit teams will make the arrangements. Departments should
ensure they maintain complete and up-to-date lists of commercial bank accounts
in use during the year including those with nil balances and others closed
before the year end. Arrangements are in hand for the NAO to receive direct
from the Paymaster independent confirmation of departments' year-end balances.
The year end reconciliations of the bank and Paymaster balances to the figures
reported in the accounts are important audit evidence.
Provision for liabilities and charges
2.56
The rules on this are currently laid down in FRED 14, and the NAO will wish to
be consulted on the proposed recognition and valuation of any provisions. Some
typical examples are given in Box 14. In considering the need for provisions,
departments will have to look beyond their boundary to consider entities which
may be unable to meet all their liabilities and where the eventual charge will
fall on the department. The NAO will wish to see that such a review has been
fully carried out.
2.57
Very long-term liabilities such as nuclear decommissioning will need to be
discounted at the standard public sector rate. Where discounting is applied
the NAO will wish to see the discount calculation. Box 14
Some likely areas requiring provisions
Decommissioning costs where the department is obliged, legally or constructively, to bear the costs of remedying the environmental damage or contamination, or to perform restorative work; identified and calculated in line with paragraphs 4.4.2 to 4.4.9 of RAM.
Pensions and Superannuation only to the extent by which the Accruing Superannuation Liability Charge (ASLC) has not been completely discharged by payments of contributions.
Early Departure Costs only for the 20% departments are funding themselves; further guidance is available in paragraphs 4.6.4 to 4.6.9 of RAM.
Re-organisation costs where the department is demonstrably committed to the re-organisation, and the costs are not associated with ongoing or new activities.
Others: such as an onerous contract.
Contingencies and commitments
2.58
Departments will require a system to identify potential contingencies - both
contingent gains and contingent losses. On the basis of prudence, contingent
gains should not be recognised in the accounts. Contingent losses should be
recognised if there is sufficient evidence to indicate that the loss will
occur. But such contingent losses which are not recognised in the accounts
should be disclosed by way of a note unless the loss is regarded as remote.
Security reasons may preclude detailed disclosure in the notes, although the
amounts involved should be included in any aggregate totals provided. The NAO
will wish to be consulted about the extent of disclosure, and will seek
assurance that all contingencies have been provided for or disclosed in the
notes where appropriate.
2.59
Similarly, departments should have a system to identify obligations to make
future payments - usually on contracts for non-routine services or business
activities which are non-cancellable (or cancellable only at significant cost)
extending beyond the balance sheet date. Examples include major building works
and PFI contracts. These will need to be disclosed by way of notes to the
accounts, distinguishing between capital commitments and other. The NAO will
be pleased to discuss the need for, and the form of notation, for specific
instances; and will seek assurance that all appropriate commitments have been
disclosed.
Taxpayers Equity
2.60
For resource accounts, the capital and reserves section of the balance sheet
is termed the Taxpayers' Equity. The usual constituent parts of this section
are provided in Box 15. The NAO will wish to be consulted where any unusual
line items are to be introduced to this section.
The General Fund:
This represents the total assets less liabilities of the department to the
extent not covered by other reserves. RAM paragraphs 5.2.2 to 5.2.3 provide
details.
The Revaluation Reserve:
This represents the unrealised element of the cumulative balance of
both revaluation and indexation adjustments to assets other than donated
assets and those financed by Government grant. RAM paragraphs 5.3.2 to 5.3.5
provide details.
The Donated Assets Reserve:
This represents the net book value of assets donated to the department - see
RAM paragraphs 5.4.2 to 5.4.4.
The Government Grant Reserve:
This represents the proportion of the net book value of assets financed by
Government grants - see RAM paragraphs 5.5.2 to 5.5.4.
Separate Trust Statements
2.61
Departments receiving revenues or holding funds and investments for other than
departmental objectives are required to report them in separate Trust
Statements to be appended to the accounts. This will include, for example, tax
revenues and funds held on behalf of third parties, such as client funds held
by the Insolvency Service, assets seized by Customs and Excise, and client
funds held by the Lord Chancellors Department. Treasury have asked to be
notified of all cases. The Trust Statements will not be covered by the opinion
on the resource accounts, but it is the intention to provide a separate
opinion on such Statements, depending on their auditability. The NAO will wish
to be consulted on the form of such statements.
Submitting the Opening Balance Sheet for audit
2.62
The Opening Balance Sheet for audit should be supplied to the NAO together
with the supporting papers summarised in Appendix 2.
2.63 Adjustments necessary as a result of NAO's audit of the Opening Balance Sheet must be implemented well before the production of the first full set of accounts. The indicative timings shown in Appendix 1 are stated with this consideration in mind.
Part 3: The Summary of Resource Outturn
3.1 The Summary of Resource Outturn (Schedule 1) is designed to enable Parliament to compare the sums voted in Estimates with the resources and cash actually consumed. The Schedule is unique to resource accounting and has no equivalent under GAAP. It will play an important role in resource budgeting. The Schedule shows:
- a comparison of outturn against estimate in respect of voted resource expenditure and the related cash requirements;
- a reconciliation of total resource expenditure to the cash requirement for both outturn and estimate;
- an explanation of variances between estimate and outturn; and
- details of receipts payable to the Consolidated Fund.
3.2 No real problems are anticipated with this Statement; it is included here for completeness. However the NAO will wish to see that the required format has been fully complied with, and this should form part of managements review.
3.3 Since this statement is unique to resource accounts, and to help avoid problems in its preparation, the following is offered by way of explanation:
- columns 1 to 3 show outturn figures for Gross Expenditure, Appropriations in Aid and a Net Total;
- columns 4 to 6 show requests for resource figures for Gross Expenditure, Appropriations in Aid and a Net Total as per the Estimates;
- column 7 shows the difference between the outturn net total and the net request for resources - to show how the department performed in reality against its projections;
- column 8 shows the outturn for the prior year for comparative purposes;
- "Non Operating Cost Appropriations in Aid" and "Net Cash Requirements" are separate totals: examples of the first would be the sale of capital items or repayment of loans; the second represents the cash estimated and spent by the department to carry out its functions as controlled by normal Supply procedures;
- the following three totals are key figures to show how well the department
projected its expenditure and how successful it was in remaining within its
budget:
- Total Resources
- Non Operating Cost Appropriations in Aid
- Net Cash Requirement
- the next block of figures reconciles the Total Resource figures to the Net Cash Requirements by, for example, deducting non-cash items, movements in working capital, disposals of fixed assets and adding the decrease in liabilities and the purchase of fixed assets;
- Note that the figures for the purchase and sale of fixed assets are accruals-based amounts; any year-end creditors and debtors on these items will be included in movements in working capital;
- the next block is textual data providing explanations of the material differences between requests for resources and outturn, and providing information giving a clear picture for the reason; the reasons provided should be as informative as possible while remaining concise;
- the bottom block analyses the income that the department has received and, not being available to be appropriated in aid, has paid to the Consolidated Fund;
- the final note is included to provide a reference to other notes within the statements that will assist the understanding of the figures. 3.4 Working papers supporting the production of this statement, especially the calculations for the Reconciliation of Resources to Cash Requirements, are important audit evidence.
Part 4: The Operating Cost Statement and Statement of Recognised Gains and Losses
4.1
The Operating Cost Statement (Schedule 2) serves a similar purpose to a Profit
and Loss Account prepared under GAAP by the private sector, although the
prescribed format is different. It has been designed mainly to meet the needs
of Parliament and Treasurys budgetary control needs when resource accounts
replace Appropriation Accounts. The Statement shows resources consumed during
the year, and distinguishes between the department's own administration
expenditure and its programme expenditure, net of departmental income.
Administration costs, broadly equivalent to running costs under the existing
regime, reflect the costs of running the department as defined under the
Administration Cost Control Regime, together with associated income. Income is
analysed in the notes between that which, under the Regime, is allowed to be
offset against gross administrative costs in determining the outturn against
the Administration Cost Limit, and that operating income which is not.
Programme costs reflect non-administration costs, including payments of grants
and other disbursements by the department.
4.2 To present administration and programme items as net costs, the Statement discloses and offsets income against relevant expenditure, programme by programme. Accordingly, some of the disclosures which would otherwise be made on the face of the account under GAAP are instead made in the notes to the accounts. This is to enable the allocation of all forms of expenditure and income to be made across administration and relevant programmes and to avoid complexity in the Statement itself. It means that items such as interest payable and receivable, depreciation and losses and gains made on asset disposals are disclosed in the notes to the accounts.
4.3 The costs and income figures shown in the Statement are calculated using accruals accounting principles - income or expenditure is included at the point in time at which it is earned or incurred, rather than when moneys are received or paid. For instance, for a service item the income will be considered to have been earned when the service has been completed, and this may be before or after the point at which it is invoiced to the customer, or before or after the point at which the cash is received. The Statement will reflect the costs associated with the activities undertaken by the department over the period.
4.4
In
addition to the work on the Opening Balance Sheet, the NAO will carry out a
"dry run" audit of the related Operating Cost Statement. Thus for an Opening
Balance Sheet as at 1 April 1998, the appropriate Operating Cost Statement
will be that for 1997-98. This should be seen as an opportunity for the
department and the audit teams to ensure the exchange of information is
adequate, and that the timetable for producing the accounts for audit is
achievable. Appendix 1 sets out some indicative timings for addressing such
issues. These are a guide to the latest feasible dates for the work, if the
unpublished Operating Cost Statement is to be produced to the normal
timetable. If this Statement is not prepared, such work will fall to be
covered in the following year.
4.5 The NAO's audit work on this Operating Cost Statement (ie that for the period prior to the Opening Balance Sheet) will focus on such areas as:
- accounting systems
- accounting policies
- operation of key controls
- consolidations
- related party transactions
- exceptional items
4.6
Before this statement is provided for audit, the NAO will welcome
opportunities to comment upon:
- the proposed accounting polices and any variations to the standard Form of Account recommended in RAM;
- the Chart of Accounts and the accounts-production routines (whether manual or mechanical) for producing the accounts from the books of account;
- the programme of work to be carried out to provide management with assurance on the operation of accounting systems and internal controls eg by Internal Audit (see Part 7); and
- the programme of validation and quality assurance work which will be performed by departmental management on the accounts and supporting schedules prior to their presentation for audit.
General audit objectives
4.7 In examining whether the income and expenditure as stated in the accounts meet the requirements of the audit opinion, the NAO will determine whether they comply with the general audit objectives outlined in Box 16. As part of this, the audit team will consider whether the combination of systems, controls, validations and management reviews address these objectives.
Occurrence: a transaction or event took place which pertains to the department during the relevant period;
Measurement: a transaction or event is recorded at the proper amount and revenue or expense is allocated to the proper period;
Regularity: a transaction is in accordance with the legislation authorising it, regulations issued by a body with the power to do so under governing legislation, Parliamentary and Treasury authority;
Presentation and Disclosure: an item is disclosed, classified and described in accordance with the RAM.
Accounting for income
4.8 Income includes items such as fees and charges, rent, interest and EU funding whether treated as Appropriations in Aid or CFER. Importantly, it excludes Vote funding (dealt with through the General Fund), benefits from the National Insurance Fund and Consolidated Fund standing services. The figures must be included on an accruals basis (ie the amounts receivable), net of VAT and distinguished between "Administration" and "Programme" in line with related expenditure. Details are provided in paragraphs 6.1.1 to 6.6.1 of RAM.
4.9
The NAO will be concerned to see that departments have ensured:
- the completeness of income, including proper accruals where material for each item;
- that income, other than recoverable VAT, has not been offset against expenditure before being brought to the account;
- that income is properly credited to either "administration" or "programme";
- that income has been properly disclosed and presented in the accounts in accordance with RAM;
- where income is received from services to other public sector bodies and external customers, in order to disclose this by way of note in line with the Treasury's Fees and Charges Guide, the figures have been identified from the chart of accounts, or evidence on the derivation of the figures is available.
Accounting for expenditure
4.10 Expenditure consists of all voted expenditure including actual insurance premiums, plus Consolidated Fund standing services and National Insurance Fund benefits and non cash costs such as depreciation, the capital charge and foreign exchange gains and losses. Importantly it excludes notional insurance (except for the Intervention Board) although the effect of this may be shown in the "Fees and Charges" note for services to other public sector bodies or external customers. Expenditure must be stated on an accruals basis (ie amounts payable) and distinguished between "Administration" and "Programme" - guidance is provided at paragraphs 7.1.4 to 7.1.6 of RAM.
4.11
The NAO will be concerned to see that departments have ensured that:
- all expenditure for the year is properly accrued and brought to account inclusive of irrecoverable VAT;
- all novel and contentious expenditure has been considered for "regularity" and "propriety" purposes with the results available for management review and audit;
- expenditure is fully supported by appropriate evidence such as vouchers, and properly disclosed and presented in accordance with RAM;
- continuing and discontinuing activities have been properly identified in accordance with the principles in FRS 3;
- exceptional expenditure has been properly identified and presented in accordance with the principles in FRS 3;
- the capital charge has been correctly calculated, with proper tracking of the capital base to arrive at a reliable average cost ( see paragraph 7.4.5 of RAM); and
- all exchange gains and losses have been identified and properly calculated.
4.12 A significant element of most departments expenditure will be that on staff costs. In line with GAAP, these are defined as:
"The costs a department incurs in respect of the persons it employs under contracts of service."
In line with this definition departments should take care, for example, to exclude consultants' costs which are rarely contracts of service. These costs should be shown under other operating expenditure. Staff costs include the employer's contributions towards other pension costs, and the appropriate note in respect of the pension schemes in operation should be provided.
4.13 Departments should observe the recommended layout of the required note providing the breakdown of staff costs; and also ensure that all the salary disclosures have been made in the note to the accounts as required by paragraphs 8.5.1 to 8.5.4 of RAM; these disclosures should be supported by appropriate calculations and other evidence. The NAO will expect the department to carry out appropriate checks and validations to confirm the reliability of the payroll figures in the accounts, especially where this function is contracted out. Details are provided at Box 17. The results of this work should be retained as audit evidence.
The breakdown of staff
costs in the Note to the accounts, should be
provided under the following recommended headings:
- Salaries and Wages
- Social Security Costs
- Other Pension Costs
Other disclosures required are:
- Ministers' salaries
- analysis of the salaries of the Permanent Secretary and other members of the senior management board in the appropriate 5,000 bands, using actual salaries paid including any reserved rights to London Weighting and any other bonuses or allowances payable;
- average staff numbers employed during the year;
- pension scheme details in accordance with SSAP 24 - namely
- the nature of the scheme(s)
- the accounting policy
- the pension cost charge for the period which the department must discharge, as opposed to the Exchequer centrally;
- any outstanding or prepaid departmental contributions at the balance
sheet date.
Management should carry out sufficient checks on staff costs throughout the year and at the year end to ensure the figures provided in the accounts are reliable. Appropriate checks should include:
- headcounts from the payroll to personnel records;
- checks on leavers and starters to ensure changes are made at the right times and at the right rates of pay;
- analyses of pay movements from month to month and year to year, providing explanations for unexpected variances;
- analytical reviews of monthly/yearly payroll totals using, for example, average pay and numbers by grades - providing explanations for unexpected variances.
Notes to the Operating Cost Statement
4.14 The other notes required to support this Statement are listed at paragraph 12.1.22 of RAM; paragraphs 12.1.13 and 12.1.14 along with 12.1.23 and 12.1.24 are also relevant.
4.15 The three main notes, other than those providing breakdowns of the figures in the Operating Cost Statement, are:
- the Analysis of Net Resource Outurn and Net Operating Cost;
- the Reconciliation of Net Operating Cost to Control Total and Net Resource Outturn; and
- the Analysis of Capital Expenditure, Financial Investment and Associated Income.
4.16 For the first of these, the analysis is by voted components of Net Resource Outturn, with additional adjustments to add expenditure not funded by Supply and take account of income not recognised in Supply, to reach Net Operating Cost.
4.17 On the second, the reconciliation comprises adjustments to the Net Operating Cost to remove income and expenditures which are outside the Treasury Control Total to reach Resource Budget Outturn - a Treasury control figure; and further adjustments to the Resource Budget Outturn to remove expenditure not funded from Supply and add back Supply funded expenditure outside the Control Total. This results in the Net Resource Outturn, which represents net expenditure on the same basis as the Parliamentary Supply Grant.
4.18 The analysis of Capital Expenditure is required by "Request for resources".
4.19
The working papers supporting all notes are important audit evidence.
Consolidation of income and expenditure
4.20 The general requirements of consolidation are dealt with at paragraphs 2.5 to 2.12 above. In consolidating the entities within the boundary departments must also look to eliminate the effect of "intra group" transactions. These are likely to include items such as overheads re-allocated to other parts of the department and other shared costs. Departments also need to consider whether the presentation of income and expenditure in the accounts being consolidated is appropriate for the consolidated accounts. For example, expenditure treated as exceptional at the entity level may not be exceptional at the consolidated level. Notional insurance charges in agency accounts, where material, should be eliminated.
4.21
The NAO will wish to see that arrangements are in place to identify all "intra
group" transactions either manually or through the underlying systems. Where
dealt with manually, the working papers will be important audit evidence.
Management representations
4.22
In
the closing stages of each year's audit, the departmental Accounting Officer
is required to make formal representations to the C & AG on the content of the
departments accounts, and certain other matters. An example of such a letter
of representation is at Appendix 4. The letter includes the statement that:
"in all material respects the transactions reflected in the accounts were
regular and proper to the organisation". The audit team will wish to establish
the nature of the delegations, instructions, controls and procedures upon
which the Accounting Officer will rely when making these statements in future
years.
Submitting the Statement for audit
4.23
The Operating Cost Statement submitted with the Opening Balance Sheet for
audit should be supplied to the NAO with the supporting papers summarised at
Appendix 2.
The Statement of Recognised Gains and Losses
4.24 This will appear below the Operating Cost Statement and follows FRS 3, although the Net Operating Cost from the Operating Cost Statement (in lieu of the profit/loss in the business world) will not feature as this is financed either by the Vote or other source. Thus the word Total is excluded from the heading. The usual entries here will include the increase from the revaluation/indexation of tangible fixed assets, increases in market value of current asset investments and any unrealised currency translation differences on foreign investments. If the department has no such gains or losses in the period, a statement to this effect is required below the Operating Cost Statement.
Part 5: The Cashflow Statement
5.1
The RAM requires all departmental resource accounts to include a cashflow
statement. Subject to the provisions of RAM the exemptions in paragraph 5 of
FRS1 will not be available to entities within the departmental boundary,
unless specifically approved by Treasury. The Cashflow Statement (Schedule 4)
is designed to provide information on the way the department has absorbed, and
generated, cash (see paragraph 2.54) in the period. In effect this Statement
summarises the movements of cash during the year, and is prepared generally in
accordance with Financial Reporting Standard 1 (FRS 1). This requires analyses
of the net cashflow on both operating activities and capital expenditure, and
how this net cashflow has been financed. It is important that the format in
the RAM is followed, and the NAO will welcome discussions if departments
foresee any problems with this.
5.2
If the accounting system has been designed with the cashflow in mind (see Box
2 in Part 1) many of the figures in this Statement can be derived from this
and the other primary statements and supporting notes. However, as some of the
figures cannot be derived directly, a lot of care has to be taken in the
production of this Statement, and it should be subject to detailed management
review. The documentation must contain full audit trails to ensure the
Statement reconciles with the opening and closing primary statements including
all late adjustments.
5.3 The following should be noted:
- the flows must reflect all the entities within the departmental boundary;
- the Statement is concerned with external flows; internal flows should be eliminated on consolidation;
- the "financing" section will include the Vote drawn down from the Paymaster;
- interest receivable and payable are included in the Net Operating Costs and are not shown separately in the Operating Cost Statement; these items are therefore included in the Net Cash Outflow from Operating Activities rather than under the separate heading Returns on Investments and Servicing Of Finance required by FRS 1;
- three reconciliations are required either by way of Notes or in statements adjoining the cashflow statement:
- reconciliation of operating cost to operating cash flows;
- analysis of capital expenditure and financial investment; and
- analysis of financing.
Part 6: The Statement of Resources by Departmental Aims and Objectives
6.1 The purpose of the Resources by Departmental Aims Statement (Schedule 5) is to show an analysis of resources according to the departmental aims and objectives they are intended to serve. These aims and objectives will also be the basis for the annual Output and Performance Analysis report which departments are to produce as part of the resource accounting initiative but will publish separately from the accounts themselves. Schedule 5 is unique to resource accounting and has no equivalent under GAAP. It provides additional relevant information that is consistent with the other resource accounting statements.
6.2 There are four important aspects here:
- identifying the departmental aims and objectives;
- reporting performance against the Objectives;
- ensuring direct costs for each aim are properly identified; and
- agreeing the basis of allocation or apportionment for any indirect costs, or deciding to show unallocated costs separately.
Departmental aims and objectives
6.3 Aims and objectives are to be set by Ministers. The NAO
will welcome an early sight of these as they are agreed.
Reporting performance by objectives
6.4 As performance will be reported against Objectives, the
NAO will welcome early discussions on proposals before they are finalised.
There is important linkage between these Objectives and the Output and
Performance Analysis required by the Treasury. The Treasury are preparing a
manual for the Output and Performance Analysis which will set criteria for
performance measures.
Attributing costs to aims and objectives
6.5 Paragraphs 13.3.1 and 13.3.2 of RAM deal with this aspect. Ideally the direct costs of aims and objectives will be allocated to aims and objectives through the accounting system. For indirect costs which are to be apportioned across the aims and objectives, the NAO will need to:
- be satisfied that the bases of apportionment are appropriate to the circumstances; and
- see underlying reliable information supporting the actual allotment to the different aims and objectives.
6.6 There are numerous bases of apportionment. Some examples follow, but this list is not exhaustive:
- usage - eg on the same basis as expenditure by aims and objectives;
- in line with the management accounts;
- per capita - ie on the number of people employed on each aim or objective;
- on the basis of area occupied by the activities.
6.7 Where the basis chosen is other than in line with the
direct expenditure, the department will need to provide evidence to justify
the basis of allocation. Where, for example, the 'per capita' basis is chosen,
evidence of the number of people employed on each aim or objective reconciled
to the total staff employed will be necessary. Other bases may require more
sophisticated arrangements such as time recording systems. Early discussion
with the NAO on this is advisable.
Part 7: The Statement on Internal Financial Controls
7.1 The pro-forma suggested wording for the Statement on Internal Financial Controls will be circulated by Treasury. The Statement will not feature as part of the accounts covered by NAOs true and fair view certificate. Nevertheless it is Treasurys intention that these statements will be subject to NAO review, to allow the Comptroller and Auditor General to report that the information contained in the statement is not inconsistent with the information of which he is aware from his financial audit work on the departments Resource Accounts.
7.2 The Statement requires the department to specify, in broad terms, the framework of the system of internal financial controls maintained and operated by the department.
7.3 In addition, the Statement requires a note of the sources
of assurance or information that allow the Accounting Officer to form a view
as to the effectiveness of the system of internal financial controls. This
will come mainly from the results of work of the internal auditors and
executive managers within the department. For some departments this will
require a re-focusing of the work of Internal Audit to ensure that all
material financial systems are considered regularly, and that the appropriate
assurances can be provided. The results of Internal Audit work, their reports
and the assurances they provide are essential audit evidence.
The Internal Control Environment
7.4 Internal control is one aspect of corporate governance. Corporate governance is a system by which departments are directed and controlled. The Accounting Officers and Management Boards (if applicable) are responsible for the governance of their departments. Responsibilities include setting strategic aims, providing leadership to put them into effect, supervising the management of the business and reporting on their stewardship. Within that overall framework, the specifically financial aspects of corporate governance are the way in which the Accounting Officer (and Board) sets financial policy and oversees its implementation - including the use of financial controls and the process whereby the Accounting Officer reports on the activities and progress to Parliament.
7.5 Box 18 outlines key elements of a sound internal control environment. As with the wording of the internal financial control statement, some of these features such as the inclusion of independent board members will vary according to the nature of the central government body.
- A Management Board which meets regularly, retains full and effective control over the department and mon
