Part 4: Payments for Additional Remuneration to School Principals

Central government: results of the 2002-03 audits.

Introduction

4.1
During our audit of the 2001 annual financial reports of school Boards of Trustees, we became aware of certain transactions in a particular school that were a cause for concern. Our concerns were heightened when we were told that these transactions were “customary” among schools.

4.2
The transactions included:

  • payments out of Board funds for the cost of items of clothing and personal grooming services incurred by the principal; and
  • lump-sum payments to the principal to meet school-related expenditure for which no supporting documentation had been retained.

4.3
We carried out a special audit of the transactions at the school, which we completed in November 2002. We concluded that, although the Board had approved the transactions in good faith, the transactions were in the nature of remuneration that:

  • required the prior concurrence of the Secretary for Education; and
  • incurred a taxation liability on the part of the Board that it had not recorded.

4.4
We also found some instances of expenses incurred by the principal and paid for by the Board that, in our view, did not represent an appropriate use of Board funds.

4.5
We discussed the matter with the Ministry of Education (the Ministry), which shared our concerns, and decided to look at the extent of the practices we had observed and the degree of compliance with the applicable legal and other requirements. If the result was to find that the practices were widespread, we would work with the Ministry and other interest groups to establish what would be best practice for the payment of additional remuneration to principals.

The Basis for Determining Principals’ Remuneration

4.6
The terms and conditions of employment for all school principals are set down in either:

  • one of two collective agreements, as negotiated between the Ministry and the primary or secondary teachers’ unions1; or
  • for principals who do not belong to the relevant union, an Individual Employment Agreement, approved by the Ministry.

4.7
A principal is responsible for the overall management and professional leadership of the school. The management role covers such responsibilities as:

  • the educational success of the school;
  • the professional performance and development of its staff;
  • the administration of daily school life; and
  • maintaining effective communication between all members of the school’s community.

4.8
Those responsibilities are classed as “normal duties”, the rate of salary for which is determined mostly by reference to the ‘U-grade’ of the school2, the number of teachers supervised, and whether the decile rating of the school is from 1 to 4.

4.9
Depending on the circumstances of the school, the principal might also have other responsibilities – such as supervising a boarding hostel or managing an international student programme3. These responsibilities are classed as “additional duties”, for which extra remuneration can be paid.

4.10
A school Board of Trustees is a Crown entity in its own right and, as such, has legal obligations.

How is Principals’ Remuneration Paid?

4.11
The Ministry requires all remuneration to be paid through its central system. This means that additional remuneration requires the Ministry’s consent.

4.12
The Ministry refers to the consent as “concurrence”, but for convenience we refer to it here as “Ministry approval”.

Salary Paid Fortnightly

4.13
The remuneration for normal duties is paid in the form of salary on a fortnightly basis.

4.14
Schools receive an annual entitlement of Government funding that is dedicated to paying staff salaries. This entitlement is centrally resourced and is administered through the Ministry’s central payroll system. It is separate from the operational funding that the Government provides quarterly to schools to pay for day-to-day activities.

4.15
A private service provider administers the Ministry’s central payroll system. It is the biggest payroll in the country, paying 2700 principals and almost 80,000 teachers and support staff every fortnight. The service provider staff are based at four regional payroll service centres. They process salary payments, respond to payroll-related enquiries, and provide personnel clerical services.

Payment for Additional Duties

4.16
Payments for additional duties must also be made through the Ministry’s central payroll system. But, because the purpose and amount of the payments are dependent on the circumstances of the school, they are not directly provided for in the collective agreements.

4.17
Unlike the salary for normal duties, the cost of this additional remuneration has to be met out of a Board’s operational funding.

Reimbursement for Job-related Expenses

4.18
The collective agreements stipulate that reimbursement should be made for actual and reasonable out-of-pocket expenses incurred in the proper performance of the principal’s duties. Payments for expenses are made by a Board out of its operational funding and are subject to the internal policies of the school.

4.19
Reimbursing payments do not require the approval of the Ministry and can be paid directly to the principal without being processed through the Ministry’s central payroll system.

4.20
Nevertheless, the Ministry has set out its expectations for the reimbursement of expenses in its Financial Information for Schools Handbook. The key expectation is that schools will have formal policies in place for the authorisation and payment of expenses – including that:

  • the Board or the Chairperson should authorise the expenditure; and
  • reimbursing payments should be supported by suppliers’ invoices that show full details of the expenditure.

4.21
Reimbursing payments for expenses that cannot be clearly identified as work-related (i.e. through documentary evidence) could be considered to be for personal expenses and, therefore, part of the recipient’s remuneration. If such a payment were made, it would have to go through the Ministry’s central payroll system, and would require the approval of the Secretary for Education.

4.22
In Figure 4.1 on the next page, we give examples of payments that do and do not constitute remuneration.

Figure 4.1
Examples of Remuneration

Transactions or Arrangements that Constitute Remuneration and Require Ministry Approval
Payments for additional responsibilities, bonuses, and incentive payments.
Personal expense payments – e.g. medical and other private insurance, telephone (where not used for school-related purposes), and general household expenses. This includes payments for clothing and personal grooming.
Payments intended to cover school-related expenses incurred personally by the principal, but where no supporting documentation has been provided of the actual expenditure incurred.
Allowances (other than payments or reimbursements of specific school-related expenses) – e.g. gym or club memberships where membership is not school-related.
Use of motor vehicles for private purposes, including all running costs.
Use of a school house at below market rental.
Contributions to superannuation funds, and any other retirement benefits.

Transactions or Arrangements that Do Not Constitute Remuneration or Require Ministry Approval
Reimbursement of expenses incurred in relation to professional development, including fees for attending conferences and seminars.
Reimbursement of travel expenses incurred on school-related matters such as meetings, visits to camps, interviews, class trips, and conferences.
Payments for professional publications, equipment, materials, entertainment, social expenses, gifts, meals, compassionate expenses, koha, etc. for school-related matters, for which supporting third-party documentation has been provided.
Subscriptions and membership fees to professional organisations relevant to school-related activities (this does not include fees for trade unions).

Obtaining Approval to Pay Additional Remuneration

4.23
The Secretary for Education has delegated the authority to grant Ministry approval for the payment of additional remuneration to the Ministry’s Industrial Relations Unit (IR Unit). The IR Unit is also responsible for negotiating and interpreting collective employment agreements, and dealing with related employment issues on behalf of the Ministry.

4.24
The IR Unit considers applications from Boards of Trustees that wish to pay additional remuneration against a policy framework that is set by the Minister of Education. The facts of each particular case are taken into account and a Board may be asked to provide more information about its application. The IR Unit has the discretion to approve or decline any application.

Specific Ministry Policies and Procedures

4.25
The Ministry first outlined the broad factors it considers when Boards apply for approval to pay additional remuneration in a December 2000 circular to Boards of Trustees.4 This information was reiterated to Boards with the settlement of the new collective agreements that took place in October 2002, and again in September 2003.

4.26
The key determinant that staff of the IR Unit look for when assessing an application is that a Board can show that the proposed enhancements to the principal’s remuneration compensate the principal for additional responsibilities – over and above those that normally form part of a principal’s job.

4.27
The Ministry’s guidance has stated that additional benefits such as cars, insurance, and “expense accounts” are unlikely to be approved. These were previously acceptable, if Boards could demonstrate affordability, but they have subsequently been excluded with the cessation of the bulk-funding regime in 2000.5

4.28
Payments recognising performance, recruitment and retention, or the decile level for the school are also unlikely to be approved. The Ministry considers that these aspects of performance are factored into the remuneration formula included in the two collective agreements.

4.29
Approvals are granted only for one school year at a time. If a Board wishes to continue providing additional remuneration, it has to reapply for approval annually.

4.30
According to the Ministry’s policies, all applications for approval must include:

  • detailed information and/or supporting documents from the Board that explain the principal’s additional responsibilities;
  • the specific amount of the additional payment the Board is seeking to make;
  • written acknowledgement that the Board accepts the liability for the payment and has the financial capacity to make the payment, without detriment to its other activities; and
  • where approval is sought for payments to principals employed on an Individual Employment Agreement (IEA) that provides for better terms and conditions than the collective agreements, a copy of the draft IEA with proposed amendments and/or additions.

4.31
The Ministry exercises discretion as to the value of additional remuneration that it will approve. It takes the principal’s normal duties salary (see paragraph 4.8 on page 48) into consideration when making this decision, and may decide to approve a smaller sum than that requested by the Board.

4.32
The Ministry logs in a register the applications received and the responses issued. When the Ministry has approved an application, a letter is sent to the Board of Trustees confirming the nature of the approval. The letter generally confirms the approved amount of the additional payment and the school year to which the approval applies.

4.33
As a control on the payment of additional remuneration, the Ministry requires Boards to provide a copy of the approval letter to their local payroll service centre before the payments are made.

4.34
The key steps in the approval process, as it is intended to operate, are illustrated in Figure 4.2 on the following page.

Figure 4.2
Key Steps in the Process for Approving Additional Remuneration Paid to a Principal

Figure 4.2.

The Scope of Our Examination

4.35
We sought to find out the extent and kind of payments principals were receiving for additional duties, and whether the payments were in accordance with the Education Act 1989 and any relevant Ministry requirements.

4.36
The basis of our examination was payments made to principals in the school financial year 1 January to 31 December 2002. We looked separately at payments through the Ministry’s central payroll system and payments directly by Boards of Trustees.

4.37 As a result of early indications that a number of payments had been made without the required Ministry approval, including some that were in breach of the Education Act, we also:

  • examined the Ministry’s written advice to Boards regarding the requirement for additional remuneration to be approved;
  • talked to the relevant Ministry staff to gain an overview of the approval process; and
  • compared the information we obtained on the policies and procedures for approval against our collected evidence.

Payments Through the Ministry’s Central Payroll System

4.38
We selected 70 payments for remuneration other than the regular fortnightly salary payments for normal duties that had been made through the central payroll system between 1 January and 31 December 2002.

4.39
We selected the 70 payments from among those that (either individually or as a type) involved significant amounts of money and where (based on the descriptive information available about each payment) it appeared that Ministry approval might be required. The 70 payments had a total value of $521,560 and were made to 54 principals.

4.40
We then examined the 70 payments and the systems and processes used to action them. The IR Unit and the Ministry’s Contracts and Resourcing Division6 assisted us by providing documentary evidence for each payment. The Ministry also provided us with further evidence from the files of the respective payroll service centres in relation to each of the payments.

4.41
Documents we sighted included:

  • payroll print-outs showing details of payments made;
  • applications from Boards and approval letters from the Ministry for the 2002 payments;
  • historical applications and approval letters where approval had been granted for payments in previous years; and
  • correspondence between schools and payroll service centres.

4.42
We examined the available documentation for each payment to establish whether the appropriate approval had been sought by the Board and granted by the Ministry.

Our Findings

4.43
Of the 54 principals, 45 had received payments with Ministry approval at a total value of $458,343. The remaining 9 principals had received additional remuneration to a total value of $63,217 without the required Ministry approval.

4.44
The payments to the 9 principals were:

  • a $10,600 rebate on the rental of the principal’s residence;
  • $10,500 for acting as a support officer for international fee paying students;
  • nearly $9,000 for acting as a Community Education Liaison Co-ordinator;
  • a “car reimbursement” of $1,000 a month paid for 10 months of each year;
  • a “travel allowance” of $282 a fortnight from January to September;
  • a “term allowance” of $2,000 for three terms;
  • an annual “extra pay” of nearly $6,000 approved by the Board;
  • $4,500 for involvement in a special literacy project; and
  • a lump-sum payment of $1,826 for health insurance costs.

4.45
Our findings highlighted three issues about additional payments through the central payroll system:

  • The Board had not sought Ministry approval. We did not seek to establish why approval had not been sought – which might have been through oversight or incorrectly assessing that approval was not required – but the failure was a clear breach by the Boards of a legal obligation.
  • The principal had authorised the payment (2 cases). As the principal’s employer, the Board must give its authority to any additional remuneration. The principal has no authority to act unilaterally.
  • Payroll service centres did not always sight approval letters. The Ministry has an internal control intended to prevent the payment of unapproved additional remuneration by requiring the Board to provide the payroll service centre with a copy of the approval letter from the IR Unit before the payment can be made. However, our review of documentation relating to the 70 payments showed that not all Boards had provided, and payroll service centres had not always insisted on receiving, evidence of Ministry approval before making the additional payment.

4.46
As a result of this last finding, the Ministry has reminded the payroll service centres of their obligation to sight approvals, and is considering new protocols with the private service provider. The Ministry told us that it intends to look at instituting new monitoring reports to check principals’ remuneration on a payday basis.

4.47
The Ministry is also to follow up these examples of unlawful expenditure and consider whether recovery of the payments would be possible or appropriate. In our view, the Ministry should also consider whether any other unlawful payments have been made centrally, which possibly should be subject to recovery action.

4.48
In September 2003, new collective agreements for primary, secondary, and area school principals were signed. The Ministry has informed us that all additional remuneration made through the central payroll system for each principal covered by the prior agreements7 has therefore ceased to be paid. The Ministry has informed all Boards that new approvals will need to be sought before any further additional remuneration payments can be initiated.

Payments Made Directly by Boards

4.49
Assessing the existence and extent of any additional remuneration paid directly by Boards to principals (i.e. not through the Ministry’s central payroll system) would have involved examining transactions at all 2582 schools.8 We decided to limit our examination to the 402 secondary schools.9

Our Findings

4.50
Our auditors identified 119 separate instances of possible additional remuneration to secondary school principals that had been made outside of the central payroll system and for which the Boards had not sought Ministry approval. The 119 instances involved payments to 72 of the 402 principals.

4.51
The values of the 119 payments ranged from under $500 to about $23,000. The list below sets out some of the types of payments made:

  • about $23,000 for time spent on implementing a video conferencing project for the school;
  • an expense allowance of $577 a fortnight;
  • a travel subsidy of $850 a month for 12 months;
  • a $10,000 performance bonus;
  • motor vehicle expenses (in one case the school leased a car for the principal who had free use of the vehicle at all times, at a cost of nearly $9,000 a year);
  • a $5,000 annual payment for duties relating to a school farm and hostel;
  • medical expenses and health insurance – which involved the reimbursement of $2,000 a year for health insurance.
  • a clothing allowance of $1,500 a year; and
  • payment of airline club membership fees.

4.52
We also became aware that principals of some integrated schools10 received remuneration from the school proprietors in addition to the normal duties salary payable in terms of the applicable employment agreement funded by the Ministry. Arrangements of this nature may be in breach of section 7(4) of the Private Schools Conditional Integration Act 1975. The Ministry is considering how to identify the extent of these payments and, if unlawful, how they may be stopped.

4.53
Some Boards of Trustees are paying additional remuneration other than through the Ministry’s central payroll system. Of the 119 payments identified, in our opinion 62 constituted additional remuneration requiring Ministry approval and, consequently, the 46 Boards that made the payments acted in breach of section 89 of the Education Act 1989. The total value of these payments was at least $210,000.

4.54
None of the 62 payments met the Ministry’s criteria and were unlikely to have been approved even if the Boards had sought approval. In that case, the payments should not have been made under any circumstances.

4.55
The status of a further 51 of the 119 payments needs further investigation before it can be determined whether or not they constitute additional remuneration and, if so, whether or not they might comply with the Ministry’s approval criteria. For 30 of the 51 payments that could be reimbursements for actual and reasonable business expenses11, the decision will be based on whether the Board and the principal can clearly show that to be the case.

4.56
Of the remaining 6 payments, the Ministry informed us that 3 did not require its approval12, and the other 3 had received retrospective approval since our examination began.

4.57
Both the Ministry and we are concerned about the extent to which unapproved additional remuneration has been paid outside of the central payroll system. We consider that there are no reasons that would excuse Boards for not complying with the legislative and other requirements. That 11% of secondary school Boards made these payments in 2002 is a significant finding, and we note that this figure could increase depending on further investigation of the 51 other payments.

4.58
Contracts between a Board and the principal that provide for additional remuneration could be illegal without Ministry approval. The Ministry told us that it plans to investigate the payments we have identified, and has indicated that it may consider legal avenues for recovery on the basis of further legal advice and on an analysis of the facts of each case, or group of cases.

4.59
We are concerned that the Ministry has taken a long time to initiate its investigation, given that we first raised the cases of additional remuneration with it in July 2003. This delay may make it harder to obtain full information on the payments and to pursue recovery where appropriate. Also, the length of time may encourage principals and Boards of Trustees to believe that such payments are proper.

4.60
However, we are pleased to note that some positive action is now being taken. The Ministry will be exploring ways to tighten its monitoring procedures over the payment of additional remuneration, and we consider that this, together with a requirement on Boards to disclose remuneration in their financial statements for the year ended 31 December 2004, will ensure that future monitoring is more robust.

4.61
The Education Review Office (ERO) is aware of our findings, and has told us that it will require the Board of each school being reviewed in 2004-05 to attest in its Board Assurance Statement that it complies with section 89 of the Education Act when providing additional remuneration to the principal.13 The ERO intends to audit this statement and will inform us of the results of this exercise in July 2005.

The Ministry’s Approval Process

4.62
As a result of finding instances of additional remuneration being paid without Ministry approval and outside of the central payroll system, we decided to examine the way in which the Ministry’s approval process operates. This involved looking at:

  • the guidance that the Ministry has issued to Boards; and,
  • what internal policies and procedures the Ministry had in place for the administration of its approval function.

4.63
Administering the statutory approval process is one of the roles of the IR Unit. According to the Ministry’s records, there have been 232 applications for approval since November 2000.

4.64
Advice provided by the Ministry to Boards of Trustees on the policies and procedures of the approval process is currently found in seven key documents. These documents do not deal solely with the requirement for approval, but with a number of other issues current at the time of publication. The documents are listed in Figure 4.3 below:

Figure 4.3
Key Documents for the Approval Process

Date Ministry Document
4 December 2000 Circular 2000/30 - Bargaining Issues: Settlement of Collective Agreements for Principals
31 August 2001 Circular 2001/17 - Collective Agreements for Primary Teachers and Principals, 2001-2003
6 September 2002 Circular 2002/20 - Collective Agreement Settlements and Variation: Principals and Teachers
4 October 2002 Letter to Boards of all State and State Integrated Schools - Implementation of Secondary School Principals' Collective Agreement, 2001-2003
3 October 2003 Circular 2003/16 - 2003 Annual Reporting Circular
3 October 2003 Circular 2003/17 - Primary and Secondary Principals' Collective Agreement Settlements
10 October 2003 Letter to Boards/Principals where the principals are not members of the relevant unions.

4.65
In our view, the guidance on the approval requirement could, on the whole, have been clearer. We have discussed our view with the Ministry, which has indicated to us that every effort will be made to ensure that the requirement for approval is clearly communicated to Boards in the future. Boards now receive advice on the requirement for approval through the Ministry’s Annual Reporting Circular, and the Ministry has said that it will include the requirement in a future update of the School Resourcing Handbook.

4.66
The Ministry has told us that all future guidance will be unequivocal about the prohibition on unapproved additional remuneration. We believe it would be useful for the critical points to be summarised in a single document prepared specifically for Boards of Trustees.

4.67
The Ministry has policies and processes in place to help ensure the smooth and efficient running of the approval function. However, these could be enhanced in some respects – in particular:

  • Although there are written guidelines for the IR Unit staff to follow when assessing applications for approvals, we were told that there are only informal quality assurance procedures in place. It is important that approvals are consistent and have a clear audit trail to support them. And, because the approval process has the element of discretion, it is also important that the IR Unit can show the basis on which that discretion is exercised, and that it is exercised consistently. The lack of formal procedures to review approvals, however, results in an increased risk of IR Unit staff assessing applications inconsistently.
  • The Ministry’s record of applications and responses was found to be incomplete and not wholly accurate. We viewed the Ministry’s entire record of applications and compared it to copies of letters sent by Boards to payroll service centres.14 Among the letters that the Ministry provided to us as supporting evidence for payments were 16 that did not have corresponding entries in the Ministry’s record of applications and responses. These letters were dated from March 2000 through to November 2003, and consisted of 14 granting approval and 2 requesting further information from the Board.
  • The Ministry had approved some applications despite the Board not meeting a specific approval criterion. Five approvals, dated from December 2001 through to March 2003, were granted even though the application did not comply with the requirement for Boards to confirm that the proposed payments were affordable and sustainable. In our view, this requirement is important as it shows an acceptance by the Board of its responsibility for the payments. The Ministry’s current practice of stating in approval letters “… that the financial liability for the payment rests with the Board” does not in our view achieve the same recognition of onus as a statement from the Board.

Potential Taxation Issues for Boards of Trustees

4.68
Boards of Trustees paying additional remuneration outside of the central payroll system without Ministry consent must nevertheless ensure that any relevant taxation issues are addressed.

4.69
To the extent that a Board of Trustees has provided a “fringe benefit” to a principal, it will be liable for fringe benefit tax on the amount concerned. Further, for cash amounts paid to principals, the Boards must generally deduct PAYE from the amount paid where the cash amount is “monetary remuneration” under the Income Tax Act 1994.

4.70
In relation to the 119 payments made outside of the central payroll system, in our view 97 of them potentially had tax implications, which not all of the Boards of Trustees appeared to have addressed. Failure to comply with the Education Act by ensuring that all additional payments are made through the central payroll system exposes Boards to potential tax liability issues that could prove costly.

Probity Issues Attaching to Additional Remuneration Payments

4.71
Consistent with the public accountability of Boards of Trustees as Crown Entities, the Ministry has published some guidance for Boards and school management on issues of probity. This guidance makes it clear that all funds received by the school, whether locally raised or from the public purse, must be spent in the best interests of students.15

4.72
We identified some payments that may not have conformed to the guidance. For example, we observed:

  • three instances where the principal was paid between $10,000 and $11,000 in performance bonuses; and
  • three instances where gifts to retiring principals had values of more than $10,000.

4.73
As noted in paragraph 4.28 on page 53, the Ministry considers that performance is factored into the remuneration formula in the collective employment agreements and that it is unlikely to approve the payment of bonuses. In addition, we believe that retirement gifts of the size noted above are excessive, and are out of step with wider community expectations for the responsible use of public funds.

Concluding Comments

4.74
Boards of Trustees must comply with the following obligations when providing additional remuneration to their principals:

  • Ministry of Education approval must be sought and obtained; and
  • all payments must be made through the Ministry’s central payroll system.

4.75
We are concerned that Boards of Trustees are not always complying with their legal obligations and that some principals have received additional remuneration without Ministry approval.

4.76
The Ministry’s approval function could be improved by:

  • ensuring that payroll service centres do not make payments for which there is no approval;
  • issuing clearer guidance to Boards of Trustees; and
  • strengthening various internal policies and procedures.

4.77
We are pleased that the Ministry has given us firm assurances that our concerns will be appropriately addressed.

4.78
Boards of Trustees have the primary responsibility for ensuring that principals are remunerated in accordance with the obligations noted above. We have discussed with the Ministry and the ERO strategies for following up unapproved additional remuneration, and intend to maintain a close watch on this issue through our annual audit of Boards’ financial reports.

1: The New Zealand Educational Institute and the Post Primary Teachers Association.

2: Every school is graded from “U1” to “U14” on the basis of roll size – U1 being a school with between 1 and 50 students, and U14 being a school with more than 2000 students.

3: International student programmes have been an area of particular growth. The number of foreign fee-paying students in New Zealand schools has increased from 7200 in 2000, to 15,000 in 2002. These programmes provide locally raised income that schools can use to supplement their operational funding, but they may also require additional management input from the principal.

4: From time to time, the Ministry issues ‘Circulars’ to all schools. These are intended to advise Boards and their staff of the Ministry’s current requirements on a range of issues, including industrial relations, resourcing, and finance (including annual reporting).

5: Bulk funding of teachers’ salaries was a funding option made available to Boards of Trustees under repealed provisions in the Education Act 1989. This option allowed Boards to self-manage their staff funding. After the 2000 Amendment Act, bulk funding was dropped as an option for Boards from January 2001. All Boards are now funded in the same way, with centralised resourcing for their teachers’ salaries.

6: The division of the Ministry with responsibility for overseeing the central payroll system.

7: Either as a member of the respective teacher’s union, or under an Individual Employment Agreement.

8: This number includes all State and State Integrated Schools, but excludes Private Schools.

9: The scope of this phase of the audit covered secondary schools (of which there are 316) and composite/area schools (of which there are 86). Composite/area schools combine primary, intermediate, and secondary schooling at one, predominantly rural, location. For ease of understanding we use “secondary schools” to describe this group of 402 schools.

10: Integrated schools provide education of a “special character” in line with a particular religious or philosophical belief. They receive an operational funding grant from the state education system under an integration agreement between the Minister of Education and the proprietors of the school.

11: For example, by providing evidence such as receipts and car log books.

12: These relate to provisions for special leave for the purpose of professional development as provided for in the Secondary School Principals’ Collective Agreement.

13: As part of the review process, the Education Review Office (ERO) asks the Board of Trustees of each school to complete a self-audit checklist and a Board Assurance Statement. The information in each of these documents assists the ERO in the scoping and planning of the review.

14: This record includes 232 applications dating back to November 2000.

15: Circular 2003/16 – Annual Reporting Circular, page 7.

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