“The 2013/14 audit of the Scottish Government Consolidated Accounts: Common Agricultural Policy Futures programme”
Agenda item 3 is oral evidence on the Auditor General for Scotland report, “The 2013/14 audit of the Scottish Government Consolidated Accounts: Common Agricultural Policy Futures programme”. The committee has received written submissions from the Scottish Government and the European Commission in connection with the report, and they are contained in the papers for the meeting.
I welcome our panel of witnesses from the Scottish Government. Graeme Dickson is director general for enterprise, environment and innovation, Jonathan Pryce is director for agriculture, food and rural communities, and David Barnes is the chief agricultural officer. I understand that Mr Dickson wants to make a short opening statement.
Thank you, convener. I will be brief.
I am grateful for the committee’s invitation to give evidence today. Because of the complexity of the CAP programme and the fact that it is moving very quickly, it is helpful to give you an oral update on progress rather than a written one. I am conscious of the fact that the committee’s membership is quite different from when we gave oral evidence last November. We will try to be concise but, because there is a lot of European jargon involved, it may take a bit of time to explain everything.
I remind the committee that the new common agricultural policy that we are implementing is radically different from the existing policy. The European Union promised to simplify the CAP, but this will be the most complex CAP ever. As well as introducing a new IT system, it will involve a new way of calculating subsidies, a range of new schemes, and complex new rules on greening. All those things are new to our farm businesses that are applying under the schemes and to all our staff who are implementing them, and we have had to make all those changes within a very tight and fixed timetable.
I heard the evidence that was given previously, and I assure you that our information systems investment board considered the programme at an early stage. It has been subject to gateway reviews and it has its own simple and, I believe, good governance structure now running it. Given its scale, it has also been fully within the sight of our ministerial team and senior management since its early stages.
Since we last gave evidence, we have made good progress. We have met our deadlines and, as I reported in June, we received almost 21,000 applications for the single payment on time. We have had excellent support from NFU Scotland and from our farmers and agents, who were patient despite the teething problems that we encountered in the application window. We have a clear plan in place for the remainder of the programme and it is being followed. We also have an excellent and highly experienced team in place, both in our IT side and in our business, which David Barnes runs, as well as a very good contractor with which we are working collaboratively.
The programme is an absolute priority for me, as the accountable officer, and it will remain so until it is completed.
Thank you. The committee members will now ask questions.
I take all your points about the complexity of the new programme, Mr Dickson, but will the futures programme deliver farm payments in the first two weeks of December, as we all hope?
As I mentioned, we have a detailed plan to start payments, as planned, from December. The schedule is very tight and depends on everything being delivered one thing after another. It should be borne in mind that we kept the application process open for a month longer and that this is the first time that we are doing it. We have a lot of complex business processes to complete in the coming three months. We have to calculate both the new payments and payments under the old system as it tapers out. However, we have a dedicated and highly motivated staff team who are doing their utmost to deliver the programme.
I was one of the people who were calling for the applications process to be extended by a month, on behalf of all the farmers I represent, so I totally take that point.
Can you tell us about the costs? The Auditor General reported to the committee that the original business case for the futures programme was £102.5 million but that the figure had increased to £178 million as of March 2015. The Auditor General’s figures will be based on the audit of your programme. What is the latest figure?
The latest figure that we are working to, for the business case, is £178 million. Echoing what was said in the previous evidence session, I point out that that contains an element of optimism bias—it is the outside of the envelope, and there is contingency or optimism built into the figure.
You expect that the system will be delivered within that budget of £178 million.
I very much hope so.
When is the closing date for that, as it were? When will it be judged that the system has been delivered? Will it be when all the automated bank payments have gone to the 22,000 farmers throughout Scotland? Or will it roll on from year to year, as the annual payments are made?
The business case is for a five-year period up to the end of March 2017. At the moment, we are focused on getting the farm payments out, starting in December, but more functionality will be required both in relation to some of the pillar 2 schemes and in relation to the livestock schemes that are required for this year.
We also have further mandatory requirements from Europe around the new land parcel information system, and the scheme accounting and customer account management system. There are also things to be done around business efficiency that we would hope to implement in the period up to March 2017. We will come to that once we have covered all the mandatory elements.
Thank you—it is helpful to understand the date. Included in the £178 million cost was the figure that Audit Scotland put on the IT delivery partner, which at March 2015 was £60.4 million, having gone up from £28.8 million. Who is the IT delivery partner and what has changed to increase the cost from £28.8 million to £60.4 million?
The principal IT delivery partner is CGI, which is the company that Dr Simpson referred to earlier—it has just won the contract for the City of Edinburgh Council and is also the Parliament’s IT supplier.
You were doing very well until you mentioned that.
If you can bear with me, I will take you back to the Auditor General’s original report. At the time that the initial business case was done, we did not know what we were going to deliver and were unable to scope it. As the Auditor General says, it is practically impossible in those circumstances to get a contract that has a fixed price at the outset—costs increase as the work develops and the scope becomes clearer.
As I said when I gave evidence last November, we got it wrong at the initial stage. We took advice from procurement and others who looked at similar systems, but at that point—a couple of years away from knowing what the new scheme would be—we radically underestimated what the IT would cost.
In our next business case, which we brought in last March, we had a clearer idea. Since then we have met a number of different cost pressures and additional elements that we need to build, such as the land parcel information system, which is an enormous database of 500,000 fields. That is what has taken the cost up to the current figure.
In your assessment of that IT delivery partner, would you say that it has not overloaded the costs and can satisfy you—and therefore the Public Audit Committee—that those costs are justifiable?
Yes. As I said, we are paying it on the basis of the work that it delivers. We agree work orders with the contractor, and we challenge anything about gold plating.
There have been a number of factors that have impacted on us. As I said, complexity was a major issue, and changed market conditions have also come into play. There are pay rates in the contract, and we are now paying a rate for developers that is about 32 per cent above the rate envisaged in the original contract. We have also put in a surge capacity at various points, first to meet the opening of the new portal in January and then to meet the opening of the payment window on 15 March—we had to pay a lot of overtime and bring in additional staff. We will do the same thing in the run-up to making payments.
That is fair. Jonathan Pryce mentioned 2017 as the period of the overall programme. Your letter to the committee of 22 June said that 35 per cent of submissions of the single application form to the Government were made on paper rather than online. I am not remotely surprised by that, and I am sure that you are not surprised either. Having seen this stuff, I know that the complexity is scary—although it is perhaps not the word that the NFUS would use to describe it.
Do you envisage, or does your business case envisage, a significant drop in the percentage of paper applications? If so, given that there is no broadband in many areas, such as mine, how do you expect crofters to apply online?
I will let Jonathan Pryce and David Barnes brief you on some of the arrangements that we have put in place for remote areas.
The approach that we took was to digital by encouraging people to apply online. It is a complex new form for anyone to fill in, but the online system has certain advantages for farmers and agents because what they see is now pre-populated and carries out checks as they go through. Therefore, by the time they come to submit the form, it will say that the application is compliant.
To have those checks, though, people need to have superfast broadband, because otherwise the system is so slow it grinds to a stop. That was the problem right at the outset. It is a chicken-and-egg situation.
The question is how to build in the incentives so that people apply online. Down south, they took a digital by default route. We did not do that.
Indeed, and we have seen the problems with that strategy.
We put measures in place to help farmers in remote areas. You want to hear from Jonathan Pryce and David Barnes about that.
I know about that. What I am really after is the future policy and whether it is reasonable to expect the number of online applications to rise compared with those on paper. I know that people can go into their local department office and so on, but that is not really the perfect scenario.
I can answer your question about the business case and what it assumes. The business case benefits are not dependent upon a significant increase in online applications—that is not a huge part of the financial elements of the programme.
We achieved almost exactly the same percentage of online applications this year as we did last year—there was a small increase. That was in the face of the teething issues that we had with the online system during the application window. We have some very detailed data. For example, agents normally—almost exclusively—apply using the online system, with very few paper applications. A significant chunk of agents used paper this year, but we are pretty confident that we will get them back to online application next year.
That does not answer your point about the availability of broadband. In general, the agents will make sure that they are covered.
My final question is on your thoughts on the paper that we got from the European Commission, which is, even by the standards of the European Commission, incomprehensible.
In the section titled “Financial sanctions”, which is obviously very important to you and to individual crofters and farmers, it says that
“additional complexity is added by Member States’ own supplementary rules and conditions which are added in order to tailor and target aid (notably in rural development programmes).”
I appreciate what it is trying to suggest there, but do you think that that is fair? Is it the case that the Scottish Government has added additional complexity, as the European Commission would appear to be suggesting, given that it wrote this letter to us as opposed to an audit committee in some other part of Europe?
The industry asked us for more complexity. It asked us to have three payment regions, so we pay a different fixed price per hectare in three different parts of the country, and three different livestock schemes, so we have a sheep scheme, a beef scheme and an island beef scheme. Those arrangements make it more difficult, but they are targeted toward helping Scottish farmers.
That is the difficult balance: we could have a one-size-fits-all policy, but what fits in France would not fit in Scotland.
So the Commission has a point.
We have tried to make things as simple as possible, but we are doing that within the constraints of trying to target best the £400 million or £500 million going to our farming communities.
Nigel Don has a brief supplementary.
It is absolutely on this point, and I hope that you are simply going to say “yes”. Once the scheme is set up, presumably the pre-population of the application form fields will come back next year. The scheme does not change so, unless a farmer makes a material change to their farm, they will not have to do anything other than press the return key next year. Is that essentially where we are going?
More or less.
I would hope so. It should be, provided that the European Commission does not change the rules.
We know from experience that there are some changes from the Commission every year. Commissioner Hogan’s focus is very much on simplification, which is intended to mean that we should not have significant changes. However, sometimes even simplification is a change, so we may see changes to make the system simpler.
There are some additional requirements for us. We have to make sure that we are clear that we will have a geospatial application in place for all farmers by 2018. Again, that is intended to make it as easy as possible for farmers rather than making it harder for them, but it certainly increases the complexity for us.
10:45
I am looking at paragraphs 14, 15 and 16 on page 7 of the Audit Scotland report. As far as I can see, a budget of £178 million will not deliver the whole project. Certain items have been taken out in order to enable the core—or most urgent—piece to be put in place. Is there a plan for the rest of the project to be implemented at some point? If so, can you give us a guesstimate of the cost?
Are you referring to the section 22 report from autumn 2014?
That is correct.
We essentially deferred some things rather than taking them out altogether. The specific elements that the report mentions include SMS text messages for alerting farmers to a change or to something that they might need to do.
The big thing to which the report refers is the mapping of registered land.
Sorry—do you mean the mechanism by which farmers are able to submit their own updates?
That is one of the main components.
The mechanism by which farmers can submit updates on their land online is in the scope of the current business case. It has not yet been delivered, but it will be part of the new land parcel information system.
Which of the items that were deferred are not covered by the £178 million?
We have ruled out more or less nothing from the scope. We have deferred certain things because we have been working hard to meet the statutory and regulatory deadlines to ensure that we get the main bulk of the payments out as early as we can. We have not ruled anything out as a result of changing the order in which we are bringing functionality in.
When you say that you have not ruled anything out, does that mean that it is all within the scope of the budget of £178 million?
The £178 million budget was drawn up to enable that kind of scope to be covered, but I cannot give you a guarantee today that the £178 million will pay for all that functionality. That is why we are saying that we know what we absolutely have to do, and that there are other things that will improve our business efficiency in terms of the operation of the paying agency and the agricultural staff. Whether we can get all that delivered within the £178 million budget is unclear at this point in time, because we are working to get the most important elements in. With regard to making further improvements, we will most likely have a future decision to take as to exactly what is most cost effective and what represents a good use of public money.
As I said, the business case runs to March 2017, but there will be continuing investment in the systems beyond that date, and some things may be deferred beyond the existing five-year programme.
The biggest part of it—the online mapping—is currently part of the procurement for a new land parcel information system. The other two elements, which came up in our previous committee evidence session, are SMS messaging, which would be nice to have, and the ability for our in-field inspectors to do livestock inspections on their laptops. We will look at the latter element to see whether the business benefits from it would meet the costs.
When will you know whether there is any additional cost to the programme? When do you anticipate having that information?
At present we are working to the £178 million business case, and we are not intending to exceed that amount. It may be that we choose not to deliver certain elements if they do not provide a sufficient individual cost benefit ratio.
But there is a possibility that a further business case will be brought forward to bring other elements into the programme, so the £178 million is not necessarily the end of the road.
We will take a cost benefit view of all the things that we intended to deliver within the £178 million if it turns out that £178 million will not be enough to do all that.
As I said, we have within the business case things that are not absolutely essential to meet the European regulatory requirements and our compliance duties. Those are things that we thought it would be good to have in order to improve our efficiency. We have been so focused on dealing with the regulatory requirements that we are not yet at the stage of doing a further analysis of whether, for example, we would want to spend an extra £3 million on a particular piece of business efficiency and what the cost benefit of that might be. We will come to that in time. I am pretty confident that we can do everything that we have to do within the current business case price.
You are talking about cost benefit. I am looking at the Audit Scotland report again. Paragraph 5 on page 4 states:
“The Scottish Government has estimated that it could incur costs of up to £50 million per year if the IT system failed to deliver”.
The cost is £178 million, which means that there is a three-and-a-half year payback period. To put it crudely, is that a good investment? I am not suggesting that we do not take the European money, but the cost seems disproportionate, does it not?
The fact of the matter is that we have no choice: we have to have a compliant system, even if we still suffer disallowance. Obviously we intend to ensure that we do not suffer disallowance.
It is refreshing when someone comes before the committee and says honestly—as I think the witnesses said about the initial stage of the programme—that they got it wrong. I thank you for that—it is unique to hear that rather than the jargonistic speeches that we often get.
My first question is a supplementary to the response that you gave Tavish Scott. You said that you will start the payments to farmers in December. I am concerned about the word “start”. Will all farmers be paid in December this year?
We have a pretty good record of getting payments out. Last year, we got just over 90 per cent of payments out in the first couple of days in December.
There are various complex rules. We cannot begin to pay farmers until inspections are through, so that the people who are not being paid do not know that they are to be inspected and therefore cannot do things to get out of the inspection. We are never in the position of getting 100 per cent of the payments out, but we endeavour to get out the payments to those who are inspected and all the other payments as soon as possible after that.
I am not a farmer like Tavish Scott, so I am not sure about the inspections. What percentage of farmers can look forward to receiving payments in December? If they do not receive payments in December, for whatever reason, what is the delay likely to be? Will it be one month, two months or three months?
Our plan is to get as many payments out as we can in December, and to deal with a high percentage of payments. The cabinet secretary has already announced that we are likely to split payments, as we have done in the first year of previous schemes. That is happening generally across Europe—
Do you mean that farmers will get their payments in instalments?
Yes. We will try to get the highest possible instalment to the highest number of people in December, and then get payments out as quickly as possible thereafter in the new year.
I am not familiar with rural issues. What would be the highest payment to the highest number? Given that we are the Public Audit Committee, can you give us an idea of that?
When I met Allan Bowie of NFU Scotland at the weekend, he said that farmers are worried. They are looking to the Parliament to find out when the payments on which they depend so much will come in. Can you be a bit more precise?
I am afraid that I cannot give you a precise figure today, because David Barnes and his team will be working through that as we get closer to December and as we know how many people’s forms we have processed and how many people we are safe to pay. To reclaim the money from Europe, we cannot just make payments; we have to do that in a way that complies with all the rules and ticks all the boxes.
I appreciate that. However, we represent constituents who are looking to us for certainty. Over the past year, they have faced a huge amount of risk and uncertainty. I am doing my best to elicit an assurance, but I do not think that I am getting it.
I appreciate that. I do not know whether David Barnes wishes to say more about when we will get there.
As Graeme Dickson said, we must abide by European rules to ensure that we do not risk overpaying people. We are not in a position to give numbers at this stage, because every farmer’s payment is different. When we get to the end of the present policy, after the transition period to 2019 that we will go through, all farmers will get the same amount of money per hectare, and the arithmetic will be relatively straightforward.
In 2015, however, every farmer will get a combination of some money on a flat-rate basis and quite a lot of money that is based on their individual track record. That means that, having processed X per cent of claims, we might not have a fixed amount of assurance about how we are running up against the budget, because each farmer’s payment is different. Having treated a claim from one 100-hectare farm does not give us the same amount of budget certainty for a claim from another 100-hectare farm, unfortunately.
Let me put it this way. Will all farmers get a payment in December, whether that is the first instalment or the full payment? Will all farmers get something?
As I said, we will try to get as much money to as many people as we can. The cabinet secretary and the Deputy First Minister are meeting us regularly to talk about progress. We want to have some certainty and to know what we can do with a reasonable amount of risk, and we are keeping the farming industry as up to date as we can on progress.
I have gone as far as I can with that.
I have an additional question. You spoke to Tavish Scott and to my colleague Colin Beattie about the complexity of the programme and the changes that have been made. I appreciate that you have three different schemes. In 29 countries in Europe and in the four countries in the United Kingdom, the complexity will be fairly similar.
Yes.
This is a question in two parts. Why were 50 changes made to the official guidance in Scotland between the opening and the closing of the application window? Did the other countries in the United Kingdom also have a 74 per cent increase in their budget? Yours is going from £102 million to £178 million. Did the other countries in the UK have the same number of changes and the same hike in the budget?
I will ask David Barnes to address the question about the changes in the scheme guidance. We do not have, and we have not seen, any official reporting of other schemes in the UK. It is in the public domain that the—
If there had been an increase of 74 per cent, we might have known about it.
As I said, when people started on this, nobody knew what they would be delivering. I think that the Rural Payments Agency has spent about £154 million on its IT system.
Is that in England?
That is in England.
So its figure is £154 million and yours is £178 million.
We believe that that amount is for that agency’s IT component alone. It took a completely different approach from the one that we took. The Welsh have adopted a more incremental approach across a number of years. I am not sure where the authorities in Northern Ireland have got to.
Jonathan Pryce meets representatives of the European paying agencies. Delivering something new and so complex has been a challenge in every EU member state.
Have all budgets gone up by an average of 74 per cent?
We do not have the figures from other countries and we do not know where they started. As I said, in our case, we were overoptimistic—
11:00
So the cost of the system in England, which has nearly 10 times Scotland’s population, is similar to the cost of the Scottish system. Is that correct?
England might have 10 times the population, but the system has to cover however many people apply for the scheme. England has four times the number of claimants that we do.
What about the 50 changes between the opening and the closing of the application window?
It is important to emphasise that that does not mean that the rules that farmers have to comply with were changed 50 times in flight, as it were. In January, we changed the way in which the guidance was presented to farmers—
But there were 50 changes.
There were a number of changes to clarify the position, in response to feedback from customers on the previous version of our guidance, which told us that the guidance was too disparate and that it was not helpful that guidance on different schemes was in different places and in different formats. From January this year, we put a lot of effort into ensuring that the guidance was in one place on the new portal and was available in a consistent format.
Of course, we got feedback all the time. A lot of it was positive, but we were told about spelling mistakes, about things that were not in the right place and about things that were expressed in a way that the writer thought was clear but which the audience felt needed clarifying. You should see the changes as part of a continuing process of improvement of the guidance.
Mr Dickson mentioned the complexity of the new scheme and said that, in terms of IT, there were—from memory—5,000 fields.
The figure was 500,000—half a million.
Okay. A few years ago, the Parliament passed the Land Registration etc (Scotland) Act 2012. With regard to the complexity of land registration and the system that we are working with, has that had an effect on what you are trying to implement?
No, I am afraid that there has to be a completely different system. For the European Commission, we have to maintain a record of every field and piece of land that our farmers and agents claim for or have responsibility for, and that might be different from the cadastral map that the Registers of Scotland holds, which shows the holdings of a farmer or a business. The legislation has not helped to simplify the process. There is a complication that arises from the fact that, as well as recording every field boundary down to a precise limit, we will be required—from 2018, I think—to bring in a number of layers on top of that to the show biological features that farmers will need to maintain. It is horrendously complex.
Will the roll-out of the new land registration process make things easier for you in future, bearing in mind that there might be amendments from the Commission on an annual basis?
The land registration is predominantly about title to the land, and the system that we hold is all about the features that are actually on the land—the eligibility of the area within that field and how much of it can be claimed against. If the land cannot be foraged by livestock, that cannot be claimed for. We have to do detailed mapping of individual features—sometimes down to individual trees, but certainly down to hedges, boundaries and relatively small water features, which will, under most circumstances, not be eligible. It is quite a different system from that which is used by Registers of Scotland.
I am interested in that particular area, as it is about land mapping and the precise use of the land and not just about saying that something is a field and is so big, what the trees and water features are and what wildlife protection is being put in place. It is all about outcomes and use, which is fascinating.
I am interested in the disallowance side and the inspections. Do you have the necessary system in place to do the inspections—the verification visits and checks—before the payments can be made? The timescale for that seems pretty tight.
The first set of inspections that we had to do was under the new greening requirement. Clearly, they had to be done while there was still evidence in the ground for inspectors to see. I think that David Barnes’s inspectors were out until 15 July. Members probably do not want to know the details of what they inspected, but that worked. The next set of inspections to do with the other parts of eligibility is coming up. The inspection software has now been deployed and is being used by the inspectors.
Colin Beattie asked about that earlier. That is in place. Can the inspectors go out with information on their laptop, personal computer, tablet or whatever and check it quite easily against what they see on the ground?
Yes. They have a downloadable system. They go out with a global positioning system kit. They download in the office the relevant set of data for the farm that they are inspecting and go out and do the work. They are not in real-time connection with the system—that may be a future thing—but they do an upload when they are back in the office. That system is in place and that is happening.
So that will not cause any delay in the payments in the interim. Will you be able to complete those?
We have a plan to ensure that the system does not cause any delay in payments. That plan includes going to a farm if necessary, doing the initial stages of the inspection, taking that to a certain point of completion and, if necessary, going away to do the same on other farms and coming back to finish the first inspection at a later date. It is clear that that is not the most efficient way to operate, and that is not our normal approach. If it is possible for us to avoid that inefficiency, we will do so, but if necessary we will do things in the first way in order to ensure that inspections are not an obstacle to payments being made.
So you are fairly confident that the Government will not be targeted for significant disallowance. The system is not perfect.
Disallowance covers many different things, of course. The specific disallowance that was linked to inspections relates to the greening inspections that Graeme Dickson mentioned. For example, there is a new greening rule that says that some farmers have to grow three different crops. If someone inspects too late, sees a ploughed field and cannot prove what crop was there, the European Commission would say that that inspection was inadequate and that there will be some disallowance. That is why it was important to get the greening inspections done by the July date.
As it happened, Europe said in a spirit of helpfulness quite late in the day that it would change the guidance on what evidence could be taken into account. Initially, we thought that our inspectors had to see a field of barley to be able to say that it was a field of barley, but the European Commission said late on that crop residue would suffice. It said that, if there was barley stubble and bits of odd barley ear that had dropped off the trailer around the field, that would suffice as evidence that the field was a barley field. That is an example of the moving goalposts that we have had to deal with all the way through.
I can see people having photographs with the day’s newspaper in them. I will not go on.
I want to ask a couple of questions, if I may. I want to go back to the basic idea of ICT systems. I think that you mentioned earlier wage elasticity of 32 per cent. Is that right? I have in front of me a note of rises in wages and costs of 32 per cent. Forgive me, perhaps you did not mention that: it may have been the previous panel. That shows what happens over a long meeting.
The question is relevant to you nonetheless. How on earth do you account for that kind of thing? When you are managing such programmes, is there any possibility of getting the numbers right? Are we asking you to do the impossible?
I will clarify what I said for Mr Don’s benefit. The example that we got from our principal contractor is that software developers are now commanding 32 per cent higher rates than we had envisaged in the contract. It is very difficult to allow for that in the management of a programme.
Skills have been an issue in the context of the rates that we are paying through our principal contract with CGI for its staff and the people that it takes on. As the previous evidence that we gave to the committee showed, it was challenging to take on the very senior people whom we need to lead the programme. It took us time more than money. It is a hot market and it is difficult to deal with that.
Okay. It is difficult.
May I return to the point about December payments? I still do not understand why it is not possible to make a payment to every farmer. Is there not some minimum defensible payment that could be made? Mr Pryce is shaking his head. I am not disputing it, but I would love to understand why it is the case that there is a farmer whose entitlement is so uncertain that it might be zero. That is the only circumstance under which you could not pay him.
The EC regulations are very clear about what we have to have done before we can make a payment to an individual farmer. For a payment to an individual farmer, we need to have completed all the application processing and all our administrative checks, as well as the on-the-spot field inspections. There is no relaxation to enable us to make a payment to any farmer who is going to get a field inspection. We cannot pay that farmer until all those inspections have been done and all the processes have been completed.
You are quite right that there is a number that we have to try to calculate once we have done all the inspections and before we know what the final payment to a farmer will be. We are looking at a two-part payment system, so that we can make a partial payment as early as we can.
Ultimately, we need to have completed all our administrative checks and all the inspections in order to be able to make a payment to each individual farmer.
Coming back to the point of disallowance, my worry is that, as Jonathan Pryce said, if we do not comply with the rules, we will get a blanket correction put on us.
At the end of the day everybody pays for that; we have to pay for it on a national basis.
Yes.
So it is not in our collective interest to fiddle the figures for any individual, however much we might like to.
We have a pretty good record. In the current programme, our disallowance has been about 1 per cent, which puts us in a good position in the league table in Europe and is about half of the rate for the rest of the UK.
As the accountable officer, I need to balance getting that number as low as possible with trying to get money out to people as quickly as possible. That is the judgment that we make with ministers when we have an idea of what the risk is.
Forgive me, I used the term “fiddle the figures” merely as a way of saying that we do not stick to the rules. It is jargon.
I thank the panel for their time.
I remind colleagues that we will discuss this evidence in private under agenda item 6.
I will allow a brief suspension to let the witnesses leave the table.
11:14 Meeting suspended.Previous
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