Health Alert: Detailed Guidance for the Dry-Run of External Assurance on the Quality Reports

Monitor has recently issued a detailed guidance for the Dry-Run of External Assurance on Quality Reports. The guidance sets out the requirements of Foundation Trusts and their Auditors, and gives details of the criteria that Monitor require Foundation Trusts to be judged against.

04/05/2010

Vincent Buscemi

Vincent Buscemi

Partner

Monitor has issued detailed guidance ("Guidance") to enable Foundation Trusts ("FTs") and their auditors (the "Auditor") to carry out a dry-run of the external assurance proposals on their 2009/10 quality reports ("Quality Reports").

The Guidance follows consultation on the external assurance proposals, and the results of the dry-run will be reviewed in the summer to inform the requirements for the 2010/11 quality reports.

Introduction

Under the Health Act 2009 (the "Act") and the National Health Service (Quality Accounts) Regulations 2010 (the "Regulations"), the directors of the FT (the "Directors") are required to prepare Quality Accounts for each financial year. FTs must submit their Quality Report to Monitor by 8 June 2010.

In addition, under the Annual Reporting Manual 2009/10, FTs are required to perform this dry-run of external assurance.

Requirements of FTs

1. Publish a Quality Report in the Statement of Internal Control in the 2009/10 published accounts. The Quality Report must include a brief description of the steps which have been put in place to assure the FT board (the "Board") that the Quality Report represents a balanced view and that there are appropriate controls in place to ensure the accuracy of data. 

This refers to the integrated governance arrangements that the FT has put in place, looking at a "top-down" and a "bottom-up" review of the following areas indicated by Monitor:

1.1 Governance and leadership;

1.2 Policies;

1.3 Systems and Processes;

1.4 People and skills;

1.5 Data use and reporting.

In addition, the Statement of Internal Control will need to include a description of the process that has been applied in maintaining and reviewing the effectiveness of the internal governance arrangements. This should include comments on any weaknesses or gaps identified, and the actions and timescales that the Board will undertake to address these.

(Annex A of the Guidance contains more detail on the wording for the Statement of Internal Control);

2. Provide a signed proforma Statement of Directors' Responsibilities in respect of the Quality Report to their Auditor.

Under the Act and Regulations, Directors are personally responsible and liable for ensuring and declaring that the Quality Report is balanced, reliable and accurate; that there are proper internal controls over the collection and reporting of measures of performance included in it and that the data underpinning the Quality Report is robust, reliable and conforms to data quality standards.

Only if the FT has carried out its internal assurance framework robustly, and reviewed the effectiveness of its procedures comprehensively, will the Directors be able to sign the proforma that to the best of their knowledge and belief they have complied with the requirements of the Quality Report.

N.B. FTs do not need to publish this statement in their Quality Report for 2009/10;

(Annex A of the Guidance contains a proforma Statement of Directors' Responsibilities)

3. Provide their Auditors with a Board paper summarising the arrangements in place to prepare and publish the Quality Report against Monitor's Evidence (these criteria are set out in Annex B of the Guidance);

FTs are expected to include the paper which the Board considered to allow the Chief Executive to sign the statement that the Quality Report is accurate

4. Submit a copy of their Auditor's report on their dry-run to the FT's board of governors (the "Board of Governors").

Requirements of Auditors

1. Review and report on the arrangements that the Board has put in place to prepare and publish the Quality Report against Monitor's published set of criteria;

1.1 This review will focus on the systems' ability to secure data quality of the information included;

1.2 The basis of the Auditor's report will come from discussions and interviews with the FT, reviews of the FT's data quality policies, document reviews (e.g. Board and FT committee papers), internal reviews and national and local data (e.g. Care Quality Commission reviews).

2. Undertake sample tests of the systems put in place to meet three mandated performance indicators;

2.1 For acute FTs the mandated performance indicators are:

2.1.1 MRSA;

2.1.2 Maximum waiting times of 62 days from urgent GP referral to first treatment for all cancers;

2.1.3 18 weeks data;

Please click here to read the national definitions of these indicators.

 2.2 For mental health FTs:

2.2.1 100% enhanced Care Programme Approach patients receiving follow-up within 7 days of discharge from hospital;

2.2.2 Minimising delayed transfers of care;

2.2.3 Admissions to in-patient services had access to crisis resolution home treatment teams.

Please click here to read the national definitions of these indicators.

2.3 Auditors will be checking the systems for generating the underlying data and information for these performance indicators for accuracy, validity, reliability, timeliness, relevance and completeness;

3. Provide a report to the Board summarising their findings and setting out their recommendations for improvements;

3.1 It is expected that the report will be presented to the FT's Audit Committee; then

3.2 A copy of this private report must be provided to Monitor by 30 July 2010 at the latest;

3.3 Finally, the report must be shared with the Board of Governors.

In 2010/11 the Auditors will be required to publish a reasonable assurance opinion in respect of requirement 1 above, a limited assurance opinion in respect of requirement 2 and an audit opinion in respect of requirement 3.

What does the Guidance mean for FTs?

FTs must review the systems they have put in place to produce the Quality Report to ensure that they meet Monitor's criteria. In addition, FTs must review the processes and procedures in place in relation to the three mandated performance indicators relevant to them.

FTs must consider the Guidance and liaise with their Auditor to agree timescales for:

1. The papers the FT must provide the Auditor;

2. The interaction and activity required for the Auditor to undertake the reviews and sample testing;

3. The publishing of the Auditor's report.

Click here to view the Guidance through Monitor's website.

 

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