Skip to main content

Language: English / Gàidhlig

Loading…
Chamber and committees

Public Audit and Post-legislative Scrutiny Committee

Meeting date: Thursday, October 6, 2016


Contents


Section 22 Reports


“The 2014/15 audit of Edinburgh College”


“The 2014/15 audit of Glasgow Colleges’ Regional Board”

The Convener

Item 4 is two section 22 reports on Edinburgh College and the Glasgow Colleges Regional Board. The Auditor General is joined by Mark Roberts and Mark MacPherson, senior managers at Audit Scotland; Hugh Harvie, partner at KPMG; and Gary Devlin, partner at Scott-Moncrieff.

I invite the Auditor General to make her opening statement, which will cover both audits, before I open up to questions from members.

Caroline Gardner

Thank you, convener. I am briefing the committee on two reports that I have prepared under section 22 of the Public Finance and Accountability (Scotland) Act 2000. The first of those is a report on the 2014-15 audit of Edinburgh College.

Edinburgh College was formed in October 2012 by the merger of Jewel and Esk College, Telford College and Stevenson College. Although the auditor gave an unqualified opinion on Edinburgh College’s financial statements for 2014-15, his annual report highlighted that the college had experienced financial difficulties at the end of that financial year. That was the result of the college failing to meet its activity targets for 2014-15 and it led to the Scottish funding council seeking to recover £800,000 from the college in November 2015.

Following confirmation from the funding council that it was seeking to recover funds, the principal initiated a detailed review to understand better the reasons for the failure to meet the target. The review highlighted a number of underlying problems, including issues with student recruitment and retention. The findings led to the college negotiating a 6 per cent reduction in its 2015-16 activity target, with an associated reduction in funding. The college’s scope to reduce its fixed costs was limited and the funding reduction led to a funding gap of £2.5 million for that year. That placed the college in severe financial difficulty.

My report on Edinburgh College was laid in Parliament in March this year. Since then, the college has developed a transformation plan to address the issues that were identified in the principal’s review. The funding council has agreed to provide transitional funding support to help the college to implement the plan.

The plan envisages that the college will return to a surplus in 2018-19. I have asked the auditor to monitor developments and to report on progress as part of the annual audit and I will report again early in 2017.

Alongside me is Hugh Harvie from KPMG, who is the auditor for Edinburgh College, and Mark MacPherson, a senior manager with Audit Scotland. With your permission, convener, I will pause there and we will answer questions about that report and then I will introduce the Glasgow Colleges Regional Board report separately, as the two reports cover quite different issues.

Thank you.

Colin Beattie

The report that we have in front of us is fairly brief. I realise that it came from the audit of Edinburgh College rather than an Audit Scotland intervention as such, but I for one would have appreciated a bit more information about how the situation came about and a bit more on the timelines. Anecdotally, I am told that it happened under previous management. I cannot really tell from the report whether that is the case. Are there any plans to do a more detailed investigation?

Caroline Gardner

We can certainly provide you with more information in answer to your questions this morning and, as I said, I will report again on progress with this particular case. It is fair to say that the problems came to light quite late in the financial year under audit. That timeline has limited the extent to which it has been possible to report on the history of what has happened. Hugh Harvie might want to say something more about what has come to light about the problem since it was identified at the end of the 2014-15 financial year.

Hugh Harvie (KPMG)

The main issue that has arisen is the college’s ability to meet its liabilities as they fall due, to put it simply. The activity levels upon which the college is funded had fallen below those which were forecast and, as a result, the funding that it was able to claim from the Scottish funding council was reduced. The college still had a large cost base that supported a higher level of activity and, as a result of the reduced funding and having too high a cost base, there are issues in the look-forward period.

Colin Beattie

I recognise from the report that the problem is from the college failing to deliver the agreed activity. What are the reasons for that? What led up to that? How did it get into that state? Did it happen gradually or overnight? Did it go wrong in one particular year? There are a lot of questions.

Caroline Gardner

There are, and I recognise that the report is brief. That reflects the way in which the problem came to light, which was as a result of a grant claim from the funding council.

The core of the issue is a shift in the funding council’s funding priorities. In the past, colleges have been able to claim for activity almost regardless of which students the activity related to. There was a widespread practice called additionality, which meant that colleges could claim funding for a student who was meeting the full-time minimum requirements, but could also claim additional funding for delivering additional learning to that student. As part of the policy to ensure that the funding was achieving the best impact and equipping as many students as possible to move into employment, the funding council removed the ability to fund additionality. Instead, more students had to be recruited and retained to generate the same level of funding.

The newly formed Edinburgh College did not understand the extent to which it relied on funding through additionality to cover its cost base. As the merger worked through and the information came to light, it became clear that there was a problem of about £800,000 relating to grant funding for 2014-15, and further investigation showed that there would be a much bigger problem in the future, which the college and the funding council have tried to work together to resolve. It is an emerging picture for the college, the funding council and for us, which is why the report that was laid in March is quite high level. We have done work since then to explore the issue and I will report on it again early in 2017.

Given the nature of the problem, is it possible that other colleges might have the same difficulty and that that has not come to light yet?

Caroline Gardner

The same question occurred to us, as you would expect. I will ask Mark MacPherson to talk you through what we have done in that area.

Mark MacPherson

From discussions with the funding council, we are aware that Edinburgh College was not the only college that used additionality. The use of additionality has not been outlawed as such, but a limit has been placed on it to encourage colleges to focus on individual students and additional students, instead of additional activity. We do not have the data to hand to see how widespread the practice might be in other colleges, but we understand that Edinburgh College was an outlier regarding the amount of additionality that it was using to bolster its activity.

Did the SFC do any assessment of the risk involved with such a fundamental change to the way that business was being conducted, and the possible impact on colleges, including Edinburgh College?

Caroline Gardner

You would have to ask the SFC that question. We understand the policy basis for the shift, but the extent to which it carried out a full assessment of the risks associated with that shift is not something that we can answer to the committee’s satisfaction.

That was a decision by the SFC, not the Scottish Government—or did the decision come from the Scottish Government?

Caroline Gardner

I think that it was a decision made by the funding council in 2014 that relates to the Government’s policy priority of focusing funding to help as many students as possible to gain qualifications that will help them into employment. It links back to the increasing focus on full-time students, rather than part-time students, and on courses that lead to a qualification.

It was the SFC that interpreted it in that way and sought to implement policy by making that change.

Caroline Gardner

That is my understanding.

Liam Kerr

I want to be absolutely clear on that point, as Colin Beattie raised some valid concerns. There was a college in financial difficulty and there was a move to recover £800,000 due to additionality, which better prepares the students for the workplace.

You said in your answer to Colin Beattie that that policy shift happened because colleges are trying to recruit more students in order to get the funding. In other words, we are trying to put more students through the system rather than better prepare for the workplace the students that we have, which is why there is now a problem. Was that policy decision taken by the Scottish Government or the Scottish funding council? In any event, is recouping that £800,000 really what the SFC should be doing in the circumstances?

10:30  

Caroline Gardner

There are a lot of questions in there.

Forgive me.

Caroline Gardner

I will make a start, then ask Mark MacPherson to come in.

The starting point is what we discussed earlier in relation to my other report. In 2009, the Government asked the funding council to focus its funding on courses that were most likely to lead to employment, which led to less funding for courses that did not lead to a qualification and less funding for shorter courses. The policy was one of the drivers behind the increase in the number of full-time students and the reduction in the number of part-time students over that period.

In 2014, the Scottish funding council introduced new guidance to ensure that colleges place an emphasis on increasing the number of students that they recruit rather than on the amount of learning that the students that they have already recruited experience or benefit from. There was therefore a move away from the previous practice of recruiting students who met the minimum requirements for full-time study and providing those students with more learning and receiving more funding for it; instead, the focus was on recruiting more students who each met the full-time minimum threshold.

During the merger process, Edinburgh College did not fully understand the impact of that change on its funding model, but it became clear towards the end of the 2014-15 financial year that it was at risk of overclaiming funding from the funding council under the old model. When the college thought that through, it recognised the impact on its funding for future use, which gave it a much bigger funding gap that needed to be filled. The college has been working with the funding council to understand that and manage its financial implications. It is one of those misunderstood policy changes, but it has had a particular impact on Edinburgh College that cannot easily be undone in a single financial year. Do you want to add to that, Mark?

Mark MacPherson

Yes. I have a couple of points. I emphasise again that the additionality that we talk about is a legitimate activity and use of funding, and the funding council has not said that colleges should not do it. However, I think that the funding council wants to understand very clearly why colleges are doing it and whether it might be at the expense of giving other students an opportunity to participate in learning and gain a qualification.

Mr Kerr also asked about the £800,000. Hugh Harvie can correct me if I am wrong about this, but the current situation is that the funding council has not recovered the £800,000 and has decided to allow the college to retain it in order to implement parts of its transformation plan. It is very important to emphasise that the college still has a difficult period ahead of it and a lot of work to do, and the funding council and Audit Scotland will be keeping a close eye on that.

Liam Kerr

Are you able to tell us what learning is being captured out of the situation to ensure that it does not happen again? Clearly, it is not impossible that there will be similar institutional movements in the future. How do we ensure that what happened does not happen again? Who will take forward the learning from this situation?

Mark MacPherson

I do not think that we are entirely well-sighted, as the Auditor General mentioned, with regard to what consultation or engagement took place with the sector before the policy change was made. I am pretty sure that the funding council will have acknowledged that and that other colleges that in the past might have made use of, and relied on, additionality will be looking closely at their own circumstances to understand how that worked. I would see it as a role for the funding council and colleges to reflect on the learning from what happened with Edinburgh College.

Liam Kerr

Thank you for that, but I am referring to the learning from the situation in general, not just that from the additionality. What is being done to ensure that the general learning outcomes from the process of addressing the situation at Edinburgh will mean that it will not happen the next time that there is such a merger?

Caroline Gardner

In general terms, we have taken two points from it that we are trying to play through our reports on the college sector as a whole. The first is that reform programmes, particularly those involving mergers, are times of higher risk when things can go wrong, whether that is people misunderstanding their funding models or problems around voluntary severance and letting staff go with redundancy packages. We have seen problems in all those areas and we have reported previously that the funding council could have done more to help and support colleges through that process.

The second point relates specifically to the policy change in 2009. As I said earlier, we do not think that the funding council did enough work to understand fully the potential impact of changing policy—however appropriate and well-intentioned the change is—towards focusing on getting people into employment. At the same time, it is important to understand the impact on other people affected by the policy. The same is true here.

Both points underlie our recommendations to the Government, and particularly to the funding council, about reviewing the funding council’s role, what it is expected to do and how well it is equipped to carry out that role.

Alison Harris

If I have picked up your figures correctly, you have said that the college did not have money and that it would not meet its liabilities but that, by 2018-19, it will be in surplus. That is quite a quick turnaround in only two financial years.

Caroline Gardner

I will start off, and Hugh Harvie might want add to what I say. Our sense is that the college has responded to the problem quickly and thoroughly. As soon as the problem was identified, the principal, who is relatively new, initiated a wide-ranging review to understand what had happened and to make sure that the problem was fully understood. The college has engaged with the funding council to agree a short-term funding solution to get it through, and it has in place a transformation plan that it expects to return it to surplus by 2018-19. I, too, think that that is ambitious. I hope that the college can do it, but an awful lot is required to do it over that timescale.

Hugh Harvie, as the appointed auditor, will keep a close eye on progress, and I will report back to the committee at the end of each audit to bring the committee up to speed with how well the plan is going. I hope that will be to tell you that it is being successful but, equally, if there are problems, I will make sure that the committee is aware of them.

Hugh, do you want add anything?

Hugh Harvie

The costs are higher during the transformation plan, because the costs of voluntary severance are part of that plan. Indeed, those costs are inevitable when trying to reduce an organisation’s cost base. Once the additional costs are incurred, the savings identified should get the college back to surplus.

That is good. The college is on the case.

Hugh Harvie

Very much so.

Good. Thank you.

Alex Neil

I want to clarify a couple of matters. I take the point that the funding council had not consulted on the matter, but I presume that once it had taken the decision, it informed the colleges of the policy change. What was the time gap between the funding council informing the colleges of the policy change through guidance and the college realising that it was engaging in practice that was no longer acceptable?

Caroline Gardner

The time gap was relatively short. The new guidance was introduced in June 2014 and the problem arose towards the end of the 2014-15 financial year, as the college was finalising its funding claim to the funding council.

Mark MacPherson

That is right. I do not think that there was a particularly big time gap between the formal guidance being issued and the college embarking on its next academic year. What is a bit unclear is how much consultation and notification there was in advance of the formal change being introduced.

Alex Neil

I accept the point about consultation. Clearly, a lesson is that the SFC needs to consult before it makes a decision on such matters. You are saying that, once it made its decision, it was a short time between the SFC’s new guidance coming out and the college realising that it had to change its practice. If the timeframe was so short, why is so much money involved?

Caroline Gardner

Edinburgh College is a big college—it is one of the largest in Scotland. For the initial year, the amount was £800,000. That sum of money is significant but not huge. It is when you roll up that to a full academic year and look ahead that you get to the £2.5 million gap, which is what we have here.

I presume that the college stopped the practice more or less whenever it realised its mistake, did it not?

Caroline Gardner

I am sorry, but I missed the beginning of that question, Mr Neil.

When the college realised its mistake, did it not very quickly stop the practice of additionality?

Caroline Gardner

It is quite difficult to stop an activity in the middle of a financial year, when students had been recruited to courses in a particular way.

Alex Neil

I think that Mark MacPherson said that the issue was discovered near the end of the financial year. I want to be clear on what you are saying, because something does not quite add up in my mind. I think that you said that the colleges were notified of the SFC decision in June.

Caroline Gardner

Yes.

I presume that the college financial year is from April to the end of March.

Mark MacPherson

It goes to the end of July.

So the college was notified in June—

Mark MacPherson

That was for the subsequent year.

That was before the start of the new financial year.

Mark MacPherson

Yes.

But the issue was not picked up until near the end of the financial year.

Mark MacPherson

Discussions were going on between the college and the SFC at various points, as they normally do between individual colleges and the SFC, to monitor performance and progress towards meeting the activity targets that had been agreed. At various times of the year, the college operated in the belief that all the activity that it was going to deliver would be eligible for funding from the SFC. Only when the final checks were conducted towards the end of the year did it become apparent that a proportion of the activity that the college expected to claim for and had delivered would not be eligible for SFC funding. That then triggered the SFC’s—

There were prior checks during the financial year but nobody picked up the discrepancy.

Mark MacPherson

At that stage, the checks are based on activity at a particular point in time, but activity runs throughout the financial year.

But they are still checks.

Mark MacPherson

I do not know the level of detail of the checks at that point. They are subject to—

Who does the checks—the college or the auditor?

Mark MacPherson

It is usually the internal auditor.

Hugh Harvie

It is the college’s internal auditor. The college has internal monitoring systems and the internal auditor carries out a check on the claim at the end of the financial year.

Is one of the lessons to be learned that, in the future, the internal auditor should be much more thorough and actually check that the college is following the guidance that is issued by the SFC?

Hugh Harvie

That would require the internal auditor to carry out its work throughout the year, but I understand that it is engaged at the end of the year, as the claims are submitted.

Alex Neil

Is there not a lesson to be learned about internal management of the audit function? I presume that, had a more robust internal audit function been operating, the chances are that the issue would have been picked up at a much earlier stage.

Caroline Gardner

I think that there is a lesson about the college’s overall system for making sure that it manages its finances properly. You are absolutely right that the college needs to have a system of ensuring that the assumptions that it has made about the funding that it will receive from the funding council and other sources are rolling up during the year as expected and that the funding is being properly claimed. Edinburgh College chooses to have its internal audit do that check at the year end, and there is a strong argument that colleges that have such complex sets of income streams should have audit systems that are robust enough to pick up problems during the year as they arise.

The problems surely would have been picked up much earlier in any robust audit system.

Caroline Gardner

It depends on what the internal auditors are asked to do. I expect that, in this case, the internal auditor is a firm that is appointed by the college to do a specific task, with the college remaining responsible for the quality of its internal controls and system of assurance. It sounds as though that system may need to be reviewed to ensure that it is fit for purpose.

The external auditor that the college employed would surely have checked the guidance from the SFC as part of its work.

Caroline Gardner

Hugh Harvie made a point about the timing of that check. If the auditor is asked to do a final check before submission, it may pick up problems too late for any adjustment to be made to the college’s income and expenditure projections.

But is it not a basic rule to check that the income that is expected fits in with the guidance that is provided by the substantially main funder?

Caroline Gardner

It is, absolutely. I agree with you.

I think that the auditor has something to answer for as well, does it not?

Caroline Gardner

I do not know the detail of how Edinburgh College organises its internal audit, but in any organisation the internal audit is there to support the management and the board by providing assurance about the governance systems that they have in place. In this case, it sounds as though the governance system, of which the internal audit is a part, did not operate as well as it needed to.

So the lesson is to improve the internal audit.

Caroline Gardner

Yes. It is to improve the internal audit as part of the system of internal controls and assurance, I think.

Because it failed.

Caroline Gardner

Yes. I think that the system of internal controls and assurance failed.

I do not think that we can blame it all on the funding council.

Are there any further questions on the Edinburgh College report?

Colin Beattie

Most businesses of any size do not have a snapshot audit at the end of the year; they have an on-going audit through the year, which makes the year-end audit a great deal easier and quicker. Typically, the auditors provide an update every quarter or so. Is that not common in the public sector?

Caroline Gardner

Absolutely. It is common among the auditors that I appoint. The work will normally take place in at least two chunks. Some work will be done during the financial year, which looks at the systems for controlling expenditure and risk and the process of financial management, and a shorter financial statements audit will be done after the year-end, which produces the audit opinion that I use when I report to the committee when that is needed.

However, that is not necessarily the case for internal audit. Normally, an internal audit plan is approved by the audit committee at the beginning of the financial year, which will contain six, seven or eight internal audits that are phased throughout the year and that report back as they are completed.

There is an important difference between internal audit and external audit, which I tried to explain earlier. Internal audit is responsible to those who are charged with governance—management and the board—and provides assurance internally about controls, whereas external audit is responsible for providing assurance to me as the Auditor General and to the committee about the financial statements and the wider governance. Internal audit and external audit have different roles. In this case, it might be that internal audit has failed, but I do not think that we can draw that conclusion from the work that we have done so far.

It is clear to me that the system by which the college understood its likely income and expenditure did not pick up the change early enough, which led to a funding gap at the end of the year.

10:45  

You say that, when you appoint auditors, you have them carry out an on-going audit process. Is it common among the colleges for just a snapshot to be taken at the end of the year?

Caroline Gardner

No. Hugh Harvie can tell you how he goes about the audit of Edinburgh College. I appoint him as the external auditor and he takes the approach that I described. Hugh, do you want to provide a bit more detail on that?

Hugh Harvie

We have communication and interaction with the college throughout the year on a quarterly basis. In general, the process involves us looking at the internal management accounts that are prepared and preparing questions to ask management, but it would take us a week or two to get into the level of detail that would allow us to answer the question about the funding issues, and we do not have that much time during the year to do that. That is what we do in our role as external auditors.

To expand on what the Auditor General said, the internal auditors will do what they are directed to do by those who are charged with governance. Should management decide that they want to take a closer look at the level of funding throughout the year, they will direct the internal auditors to do that. It is not within the internal auditors’ remit to always look at those areas. In effect, they will do as they are asked.

So you do a quarterly update with Edinburgh College and you ask questions about any issues that might arise. You do that according to a fixed programme.

Hugh Harvie

Yes.

Would you not ask about any changes that would impact on the college’s funding?

Hugh Harvie

We would ask about how funding was going during the year and whether there were any issues with student recruitment that were driving the underlying numbers, but we would not necessarily get into that level of detail.

Would you expect Edinburgh College’s internal auditors to supply you with information?

Hugh Harvie

If they were directed in that way, we would look to them and work with them so that we could leverage the work that they had done.

However, the issue arose in the context of the work that we carry out following the year end. As the Auditor General has pointed out, my role is to report on the robustness of the information that supports the numbers in the year-end accounts. We became aware of the issue, so our role was to ensure that it was appropriately reflected in the accounts.

So internal audit did not pick it up; you, as the external auditor, picked it up at the year end.

Hugh Harvie

No. We were told of it when we were carrying out our work at the year end. Our role was to ensure that the information that we were told was appropriately reflected in the accounts, which it was.

Was that the first indication that you had of the fact that there was an issue?

Hugh Harvie

Yes.

Who told you about the issue?

Hugh Harvie

We were told about it by the director of finance.

Not by internal audit?

Hugh Harvie

No.

Whose responsibility was it to follow the SFC’s guidance in the first place? Was it the director of finance’s?

Hugh Harvie

Yes, it was the responsibility of the director of finance and the management team in the organisation.

The director of finance should have read the guidance and followed it.

Hugh Harvie

The director of finance would be responsible for understanding the guidance. Those who record the students in the curriculum and the activity against them provide the information that allows the claim to be pulled together.

Alex Neil

I understand that, but there is guidance. To paraphrase, the SFC issued an instruction that additionality could not be applied from then on. I take it that you are saying that the financial controller or director of finance in the college was responsible for ensuring that, from that day forward, no assumption was made about getting additionality income in and that the SFC was not invoiced for additionality, as it was no longer claimable. Is that right?

Hugh Harvie

Yes, that is my view.

So has the director of finance been disciplined?

Hugh Harvie

No.

Some £800,000 of public money has gone down the Swanee and nobody has been disciplined. Why has nobody been disciplined?

Caroline Gardner

I think that that is a question for the college rather than for us.

Should you as the Auditor General not comment on that?

Caroline Gardner

As I said in my report, the principal has carried out a wide-ranging review to look at what happened and the impact on the college’s financial position in future, and to put in place a transformation plan for the college. I cannot comment on the individual responsibilities for that. My responsibility is to highlight to the committee the impact of the failure that took place in this case and the wider lessons that might come from it.

Alex Neil

There is a pattern. We discussed a similar issue last week. Large amounts of public money are being wasted as a result of incompetence, but nobody seems to take responsibility and nobody gets disciplined. If £800,000 was lost in the private sector, the person would be sacked if that was his or her responsibility. Some £800,000 of public money has gone down the Swanee because somebody did not do their job properly. That is not good enough.

Hugh Harvie

As Mark MacPherson mentioned, the investigation is still on-going. It is unfair to point the finger at the director of finance, because nobody knows who was to blame, if there was one person to blame.

Alex Neil

It is about responsibility. You are the auditor, I asked you a question, and I am taking this from you. You said that he was responsible. He has to implement the policy. As we would expect in any corporate body, the finance director has to implement new guidance on what is and is not claimable. Maybe somebody whom he employed was supposed to check those things. Obviously, the college is big, and he cannot individually check everything. However, yet again a lot of public money has gone down the Swanee, and it appears that nobody has taken responsibility for that.

There are a finance director, a finance department, internal auditors and external auditors. The issue was not picked up among you until the tail end of the financial year and, as a result, £800,000 was lost.

Caroline Gardner

I am not here to apologise for the college or the funding council, but the case is a bit different from others that I have reported on to the committee in the past in which, for example, voluntary severance resulted in payments to individuals that were higher than was justified, and money was lost to the public purse. In this case, funding has not been claimed from the funding council. It was not available from the funding council for learning activity that had been delivered. Therefore, the money was not lost to the public purse; rather, there is a funding gap for Edinburgh College.

I recognise that that is a fine distinction, but it is important to be clear about that for the record.

Fair enough, but it is clear that £800,000 is not an insignificant amount of money.

Caroline Gardner

I would not disagree with you at all.

Alex Neil

If we look at the total fees for the internal auditor, the external auditor and the finance department, we would, I presume, expect there to have been a fairly substantial amount of money between them to have got the matter sorted.

Caroline Gardner

External audit has done its job in this case. The management of the college—those charged with its governance—are responsible for having systems in place that prevent such things from happening. It is clear that those systems failed in this instance.

Absolutely.

Caroline Gardner

That is why I have reported to the committee.

The Convener

We can maybe take that up with those people.

Auditor General, are you satisfied with the Scottish funding council’s response and Edinburgh College’s response to the Edinburgh College report?

Caroline Gardner

It is early to say that. We have said that the college has a transformation plan in place. There is a funding plan in place to cover the college’s funding gap through to 2018-19. In a sense, the proof of the pudding will be in the eating and the progress that is made with the transformation plan. I will be in a better position to comment at the end of the 2015-16 audit, when I will report to the committee on the position.

Okay. Are there any questions on the report on Glasgow Colleges Regional Board?

Colin Beattie

The report is in some ways historical, but I would like reassurance that all the issues that came out in it have been fully dealt with and that Audit Scotland is satisfied that the Glasgow colleges are where they should be.

Caroline Gardner

I ask Gary Devlin to pick that up.

Gary Devlin (Scott-Moncrieff)

The issues have not all been fully dealt with, but the majority of them have been. For example, all the measures mentioned in paragraph 8 of the section 22 report—for instance, risk management frameworks, an internal audit function, key committees operating effectively and an approved scheme of financial delegation—are in place, but the draft financial memorandum between Glasgow Colleges Regional Board and the assigned colleges has yet to be finalised. Also, the Scottish funding council—probably reasonably—wants to observe how GCRB and the assigned colleges work together over a reasonable time to determine how the relationship is developing before it releases funds.

Most of the building blocks that we asked for in the section 22 report are now in place or just about to be finalised. We are at the final stages of the process.

Would it be correct to say that the governance, internal audit and process are sufficient to assure us that no public funds are at risk at this point?

Gary Devlin

In the main, yes, although the final judgment of that rests largely with the Scottish funding council and concerns the point at which it is assured that it can grant operational fundable body status to GCRB. Great progress has been made over the past 12 months on putting those building blocks in place and the measures are now working. Some of them have been put in place more recently than others, so a bit of time is needed to ensure that those processes operate effectively.

Is it because there are still some concerns that the date of 1 August 2016 for granting operational fundable body status, which is given in paragraph 22 of the report, has been pushed back into January?

Gary Devlin

It is for the funding council to explain how it arrived at that position. GCRB, which is the body for which I am the external auditor, has been working hard in partnership with the funding council and those relationships are much improved. They have worked together on the programme to ensure that the building blocks of governance are fully in place. As I said, they are largely in place now.

Colin Beattie

A date was given in the report. I would be interested to know why it was not adhered to and what caused the slippage. The report was done in March and, in that time, August was the date at which the status was to be granted.

Caroline Gardner

Our understanding as of today—it is only our understanding—is that, as Gary Devlin said, the funding council would like to see how the relationships between the regional body and the three colleges play out in practice, given the history, and that it expects the status to be in place by January.

Okay. Thank you.

The Convener

There are no further questions. If the Auditor General does not want to make any other remarks, I thank her and her officials for their evidence.

10:58 Meeting continued in private until 11:30.