Part 6: Work programme report
- Our work programme for 2003-04
- Core work of the Office
- Reports to Parliament and other constituencies
- Supplementary information
Our work programme for 2003-04
We identify our work programme for the coming year from our annual planning processes (particularly our Strategic Audit Planning). This is subject to consultation with Parliament.
Primarily, this relates to the performance audits and special studies we are proposing to complete, and the special areas of emphasis we will be requiring from our auditors in the annual audits. The planning looks at public sectorwide themes, and identifies sector-specific and entity-specific issues. It also outlines the areas where the Office makes broader contributions to the Public Sector and the accounting and auditing profession. In our Annual Plan 2004-05 we have extended this area to include our proposed Research and Development Plan and the actions we intend to take to bring effect to our Strategy.
Section 20 of the Public Audit Act 2001 requires the Auditor-General to report annually on the results of audits. We produce separate reports for this purpose. (Copies of our latest reports for Central Government and Local Government are available on our website www.oag.govt.nz.) These reports discuss in detail the key audit findings from our work on annual audits.
We do not intend to duplicate this reporting. However, to provide additional context in this Annual Report about the work of the Office, we present:
- a brief description of the core work of the Office and any major changes which have occurred in relation to the delivery of this work over the 2003-04 year;
- a summary of each of our reports on programmed performance audits and special studies issued in 2003-04; and
- supplementary information about the work the Office undertakes to maintain and enhance its professional practice.
Full information about our performance against our targets in the delivery of our work programme is provided in our Statement of Objectives and Service Performance contained within Part Seven: Financial Statements for 2003-04 (see pages 123-140).
Core work of the Office
The core work of the Office is focussed around three key areas (our “Output Classes”):
- reports and advice arising from the exercise of the function of legislative auditor;
- certification of authority to release funds from the Crown Bank Account; and
- provision of audit and assurance services.
Each of the activities that contribute to these output classes is defined in detail in our Annual Plan 2003-04 (see pages 69-83). They can be summarised into the following core assurance products and services:
- Annual audits
- Controller function
- Advice to Parliament
- Enquiries
- Advice and liaison
- Working with the profession
- Wider assurance work
- Performance audits, and
- International liaison and involvement.
Annual audits
The majority of our work and effort relates to the conduct of annual audits of the financial reports of public entities. We carried out 4070 audits during the 2003-04 year (for full details of our performance, see pages 134 and 137 of this Annual Report).
Major changes impacting on our delivery of annual audits
Audit resourcing model
The full implementation of our audit resourcing model – the process for appointing auditors to conduct annual audits – was the most significant change in our delivery of annual audits.
This has resulted in:
- a reallocation of some audits to alternative auditors;
- stability in Audit New Zealand’s portfolio, with a more predictable fee base; and
- stable and more sustainable portfolios for private sector firms with stronger sector specialisation and regional concentration.
Some audits of entities with a strong commercial focus will continue to be subject to the contestable audit appointments process, where the Auditor- General considers a tender process is appropriate to select an auditor to act on his behalf.
This year, ongoing audit contracts were negotiated for the audits of 250 entities in the context of the new auditor appointments policy. The Office of the Auditor-General was asked by 19 of those entities to provide additional comparative fee analysis to assist in resolving concerns about the audit fee proposed by the appointed auditor. In 18 cases, the matter was resolved between the auditor and the entity on the basis of that additional information. The Auditor-General exercised his direct statutory power to set the audit fee in the other case.
New entities added to our audit portfolio
The Public Audit Act 2001 resulted in a clearer definition of the Auditor- General’s mandate. The Auditor-General is now the auditor of every “public entity”, which also includes “controlled entities” under section 5(2) of the Act. We continued to examine and make determinations on the status of a number of entities over the 2003-04 year, and as a result an additional 56 entities were added to our audit portfolio in the 2003-04 year.
Long-Term Council Community Plans
The Local Government Act 2002 creates a new audit reporting responsibility for the Auditor-General on councils’ Long-Term Council Community Plans (LTCCPs), which comes into effect for LTCCPs adopted in 2006. This reporting responsibility applies to councils’ LTCCP statement of proposal and final LTCCP, as well as to any amendments that a council makes to its LTCCP.
The Auditor-General is required to report on:
- the extent to which the local authority has complied with the requirements of the Local Government Act in respect of the LTCCP;
- the quality of the information and assumptions underlying the forecast information provided in the LTCCP; and
- the extent to which the forecast information and performance measures provide an appropriate framework for the meaningful assessment of the actual levels of service provision (see sections 84(4) and 94(1) of the Local Government Act 2002).
We have commenced a project to manage our response to the LTCCP audit requirement, which involves putting in place the resources, standards and knowledge required to successfully and credibly audit LTCCPs from 2006 onwards. The project also has an objective to share, promote and communicate best practice in long-term planning through local government representative groups.
Five key work streams are being undertaken within the project:
- development of the methodology, audit procedures and guidance for auditors in conducting the audit;
- communication with the sector and key stakeholders;
- information to and Training of Audit Service Providers;
- impact analysis of the Office’s capability to undertake the work involved; and
- research and evaluation on the impact of the audit and the planning and reporting provisions of the Local Government Act.
During 2003-04, we focused on development of the methodology, audit procedures and guidance to support auditors in undertaking LTCCP audits. This included pilot work with three councils (Auckland City, Marlborough District and Central Otago District), through which we tested the approach we are developing.
Controller function
The Office acts as a monitor on behalf of Parliament to control the issue of funds from the Crown Bank Account. This includes monitoring departmental and Crown financial reporting systems to ensure that releases of funds are supported by Parliamentary appropriations and are for lawful purposes. A key part of this role is checking that warrants issued by the Governor-General for the release of funds, and daily amounts released to Departments to fund their activities, are supported by appropriations.
Major changes impacting on our delivery of the Controller function
There were no major changes to this area of work, although we note that the Public Finance (State Sector Management) Bill, if enacted, will change the way in which the Controller function is exercised.
Advice to Parliament
We report and provide advice to Parliamentarians – either in Select Committees, or as Ministers or individual MPs – on the results of audits and inquiries. Most of this work is done through financial reviews and Estimates examinations.
Major changes impacting on our delivery of advice to Parliament
There were no major changes to this area of work in 2003-04.
Enquiries
The Office responds to enquiries from taxpayers, ratepayers or individual MPs on matters that we think are appropriate to investigate. Between 150 and 300 enquiries are received every year. Of these, approximately 6-10 result in significant work. The Office also responds to approximately 80 enquiries in relation to the Local Authorities (Members’ Interests) Act 1968.
Major changes impacting on our delivery of enquiries
In our five-year Strategic Plan, we noted the increasing complexity and volume of enquiries over the last five years and the significant demands that this was placing on the Office. To date, we have dealt with this by re-prioritising other planned work in the areas of performance audits and research and development/product development. We believe that the Office is positioned well to undertake enquiry work – primarily because of our independence, and also because we have existing infrastructure and professional practices in relation to the gathering of evidence, accounting and auditing analysis, natural justice and reporting. However, we considered that we would be unable to sustain this work without it being appropriately resourced. We have now received additional funding from Parliament to expressly fund our work in this area.
Advice and liaison
Advice and liaison on matters of public sector finance, governance and accountability with central agencies, public entities and other sector groups is an integral part of the Office’s involvement and presence in the public sector.
Over the 2003-04 year, we have provided:
- input to the preparation of the Public Finance (State Sector Management) Bill, and advice to the Finance and Expenditure Committee;
- comment to the Cabinet Office on the draft Members of Parliament (Pecuniary Interests) Bill; and
- comments on a range of other draft legislation and policy proposals.
Major changes impacting on our delivery of advice and liaison
The workload in this area is growing, as a result of both the volume and complexity of proposals on which our views are sought. Select Committees are also keen to obtain our independent perspective on legislation in respect of public finance, governance and accountability and we are regularly invited to accept appointment as advisors to committees for this purpose.
Working with the profession
The Office plays an important role in representing public sector interests in working with the accounting and auditing profession, both in New Zealand and internationally. A number of our senior staff serve on committees, including the ICANZ Professional Practices Board and Financial Reporting Standards Board, and the National Asset Management Steering Committee.
Major changes impacting on our delivery of working with the profession
The decision that New Zealand will adopt International Financial Reporting Standards (IFRS) in the public sector by 2007 has significant implications for the Office. We have commenced a project to:
- Prepare the Office and our auditors to credibly audit public sector entities’ financial reports prepared under NZ IFRS; and
- Support “sector readiness”.
We have entered into a partnership with one of the major CA firms to help us achieve these project aims. This will enable the Office to draw on the expertise and resources of this firm, including their international experiences, to complement our public sector expertise.
Wider assurance work
Wider assurance work is the audit work undertaken by Audit New Zealand in response to particular needs of public entities (and accordingly is paid for by those entities). As an example of this type of work, Audit New Zealand is often asked to provide independent assurance over tender processes for large or sensitive projects in the public sector.
Major changes impacting on our delivery of wider assurance work
In 2002, the Auditor-General reviewed the consistency of this wider assurance work with his mandate under the Public Audit Act 2001. In his five-year Strategic Plan, the Auditor-General confirmed that this wider assurance work forms an important part of the overall level of assurance which he provides to the public sector. It is his intention to ensure that, over the 2004-05 year, this work is more strategically aligned through greater involvement in the Strategic Audit Planning process.
Performance audits/special studies
Performance audits and special studies are significant audits covering value-for-money or issues of effectiveness and efficiency. As such, they enable the Auditor-General to provide greater breadth and depth of assurance in the areas we have identified as key themes. Performance audits are resourceintensive, and often span more than one year. A brief summary of the performance audits/special studies we completed in 2003-04 is provided on pages 104-112.
Major changes impacting on our delivery of performance audits/special studies
In our five-year Strategic Plan, we observed that parliamentarians were asking us to do more performance audits in order to better address the key themes emerging from our Strategic Audit Planning process. We received additional funding to increase the number of performance audits we do annually – from 10 to 21 over the next two years. This will also enable us to build a more sustainable critical mass of professionals working in this area.
International liaison and involvement
The Office has had strong involvement with our international counterparts and various working groups that have been established. In particular, we make a significant contribution to the training and development of our South Pacific counterparts. We also make significant contributions to Asian countries, actively work together with our Australian counterparts at state and federal level, and are an active member of the INTOSAI working group on environmental auditing.
Over the 2003-04 year, we have:
- conducted a comprehensive peer review of the Indonesian Supreme Audit Institution – 3 senior audit staff carried out planning and initial fieldwork in April and completed their fieldwork and draft report in July;
- made an active contribution to the 17th UN/INTOSAI Symposium on the independence of Supreme Audit Institutions;
- begun preparations to host the Commonwealth Auditors-General Conference in January/February 2005;
- commenced a peer review of the Tonga Audit Office; and
- hosted a range of visitors from our international counterparts and other public sector bodies.
Major changes impacting on our delivery of international liaison and involvement
In our Strategic Plan we acknowledged both the value and cost of maintaining this international involvement and liaison. We intend to keep the level of our involvement at similar levels. However, we will target our efforts to ensure that we maximise the benefits to the work of the Office as a whole.
Reports to Parliament and other constituencies
Performance audits and special studies
Over the 2003-04 year, the Office tabled 10 performance audits and special studies (this met our planned target of 10). A brief summary of each performance audit/ special study is provided below. For fuller information, copies of each report are available from our website at www.oag.govt.nz.
| TITLE OF REPORT | INLAND REVENUE DEPARTMENT: PERFORMANCE OF TAXPAYER AUDIT |
|---|---|
| What it was about | The audit examined the taxpayer audit function of the Inland Revenue Department (IRD) in the context of the IRD’s Taxpayer Compliance Model. |
| What we found | We found that taxpayer audit was under-developed – much of what was needed for taxpayer audit to play its full part in the Taxpayer Compliance Model and to enable the IRD to meet its strategic direction was not in place. We also found that there was insufficient accountability for ensuring that good practices and new initiatives are taken up. |
| Key recommendations | IRD’s strategy for taxpayer audit needed to be further
developed; specifically:
• Implement case management techniques based on best practice • Strengthen capability including training of investigators, information availability and use, and knowledge management • Improve performance measurement (including impact measurement) and reporting of performance • Implement sound change management arrangements for overseeing changes based on good practice or new initiatives. |
| What happened as a result of our work | • IRD acknowledged the need for changes to be made in the
area of taxpayer audits. They had already progressed
many of these changes prior to our report being tabled.
• IRD now has an extensive process in place to fully implement all of our recommendations. Key to this is the establishment of a Business Initiative Governance Board to oversee changes to taxpayer audit and other new initiatives. The OAG is invited to observe at quarterly meetings. |
| TITLE OF REPORT | CO-ORDINATION AND COLLABORATION IN THE CRIMINAL JUSTICE SECTOR |
|---|---|
| What it was about | The audit examined the way in which the core agencies (which, at the time of our report, were the Ministry of Justice, the Police, the Department for Courts and the Department of Corrections) were working together to achieve the Government’s goals for the criminal justice sector. |
| What we found | We found that there were many examples of good practice across the core agencies, and a strong commitment to sharing information and collaboration. However, the core agencies had encountered difficulties in maintaining oversight of one complex project with sector-wide implications. |
| Key recommendations | Core agencies should:
• consider options for integrating their strategic planning processes; • consult on their draft policy work programmes; • promote active collaboration between research units; • consider the establishment of Māori advisory groups and develop an integrated sector strategy on outcomes for Māori; and • draw from the lessons on project oversight and risk management. The Ministry for Justice should be responsible for overseeing the status of information technology systems in the sector. |
| What happened as a result of our work | The Ministry of Justice has completed an analysis on our report and recommendations. Key actions have been developed in response. Not all recommendations were agreed to. |
| TITLE OF REPORT | MANAGING THREATS TO DOMESTIC SECURITY |
|---|---|
| What it was about | The audit set out to provide assurance to Parliament and the public that threats to the country’s domestic security were being adequately managed. |
| What we found | We found that New Zealand has taken, and is continuing to
take, steps to ensure that it is meeting current “international
best practice” in relation to domestic security.
We found however, that:
• there is no whole-of-government Domestic Security Strategy; • cross-agency information/intelligence is still in the early stages of development; • there is no current reporting on whole-of-government preparedness of domestic security arrangements (individual agencies do provide reports); and • traditional domestic security response elements are wellpracticed and planned in response aspects, but the requirements of the recovery phase have not received as much attention. |
| What happened as a result of our work | • The Foreign Affairs, Defence and Trade Committee
considered our report.
• The Department of the Prime Minister and Cabinet accepted the findings of our report and has undertaken to address them within 12 months. • Work is currently under way to address 5 of our findings, while the remaining 3 require further work. |
| TITLE OF REPORT | MINISTRY OF HEALTH: WHAT FURTHER PROGRESS HAS BEEN MADE TO IMPLEMENT THE RECOMMENDATIONS OF THE CERVICAL SCREENING INQUIRY? |
|---|---|
| What it was about | The audit examined what progress the Ministry of Health has made since the January 2003 independent review of the implementation of the Committee of Inquiry’s recommendations made in 2001. |
| What we found | This was our second report on progress in relation to the implementation of recommendations from the 2001 Committee of Inquiry. We found that 67% of the recommendations had been implemented or were likely to be implemented by June 2004. Of the other 33%, work had been planned on half, 2 of the recommendations will not be implemented, and decisions on implementation needed to be made on the remaining recommendations. |
| Key recommendations | We concluded that the most significant issues for the future
were:
• ensuring that the appropriate assurance processes are in place around the quality aspects of the Programme; and • ensuring the National Screening Unit is more open and collaborative with stakeholders and key positions are filled. We also recommended that the use of an independent expert to review progress be continued, and that the review be extended to include effectiveness. |
| What happened as a result of our work | • The Health Committee considered our report and noted
that it was timely.
• Draft legislation has incorporated the ongoing independent review of the Programme on a regular basis. |
| TITLE OF REPORT | SOCIAL SECURITY BENEFITS: ACCURACY OF BENEFIT ADMINISTRATION |
|---|---|
| What it was about | The audit sought to provide Parliament with assurance that the Ministry of Social Development has effective systems and methods for ensuring benefit accuracy, and that Parliament can place reliance on the performance data that the Ministry reports. |
| What we found | We were unable to form a clear view because of the limitations of the information currently collected by the Ministry. |
| Key recommendations | We identified a number of areas where information collected and published on benefit accuracy could be extended or improved. |
| What happened as a result of our work | • Parliament and the public (including beneficiaries) have
gained an insight into the information available on benefit
accuracy.
• The Social Services Committee considered our report and questioned Ministry staff about the various matters raised in it. • We intend to follow-up the Ministry’s response to the issues raised in our report. |
| TITLE OF REPORT | THE STATE SERVICES COMMISSION: CAPABILITY TO RECOGNISE AND ADDRESS ISSUES FOR MAORI |
|---|---|
| What it was about | The audit sought to assess the capability of the State Services Commission to recognise and address issues for Māori in the advice it provides to other departments and Ministers. |
| What we found | We found that the Commission has positioned itself well to work alongside departments to build a public service that produces more effective outcomes for Māori. The Commission has in place appropriate internal systems and processes to give effect to its role for Māori. In addition, it has aligned its Senior Leadership and Management Development Strategy well to the Government’s goals for Māori and the public service. We noted some areas where we felt the Commission could further enhance its capability. |
| Key recommendations | We recommended that the Commission should:
• complete its discussion to clarify its respective roles with Te Puni Kōkiri; • evaluate the impact of its strategy for effectiveness for Māori; and • take steps to provide more clarity, formality and certainty in its relationships with Chief Executives and their departments in relation to effectiveness for Māori. |
| What happened as a result of our work | The Māori Affairs Committee and the Government Administration Committee both considered our report, and encouraged us to undertake similar reviews of the capability of other organisations in the State sector. |
| TITLE OF REPORT | MAORI LAND ADMINISTRATION: CLIENT SERVICE PERFORMANCE OF THE MAORI LAND COURT UNIT AND THE MAORI TRUSTEE |
|---|---|
| What it was about | The audit sought to assess the effectiveness of the client service provided by the Māori Land Court and the Māori Trustee in assisting the administration and management of Māori Land by its owners. |
| What we found | We found that, overall, the Māori Land Court has provided a good level of service to its clients. Some areas for improvement existed. Likewise, we found that the Māori Trustee has provided his clients with a good level of service. Areas for improvement also existed. In addition, we noted that opportunities existed to increase the amount of interaction between the two agencies to ensure that clients receive a more seamless service. |
| Key recommendations | We recommended that the Māori Land Court should:
• improve its management and reporting of applications; • improve its training of case managers; and • standardise practices and processes between registries. We recommended that the Māori Trustee should: • establish more qualitative land management performance measures; • develop a set of criteria to determine which owners should receive written reports, and which reports should be delivered in a formal meeting; • develop a strategy for reducing the back-log in processing Court orders and correspondence; and • implement a time-recording system. |
| What happened as a result of our work | The report was not reviewed by a Select Committee. However, we have talked to both the Māori Land Court and the Māori Trustee about our recommendations, and they are both considering what actions to take. We will monitor the progress made against our recommendations. |
| TITLE OF REPORT | ACCIDENT COMPENSATION CORPORATION: CASE MANAGEMENT OF REHABILITATION AND COMPENSATION |
|---|---|
| What it was about | The audit sought to review the effectiveness and efficiency of the case management processes and procedures of the Accident Compensation Corporation (ACC). It considered ACC’s rehabilitation policy and practice, claims strengthening, and claims payment accuracy. |
| What we found | We found that ACC’s case management practices and policies were thorough and work well, and that ACC has a professional approach. However, we considered that there were areas where ACC can improve, particularly in the way it communicates with clients. Claimants also often perceive ACC’s service delivery as impersonal and inconsiderate. |
| Key recommendations | We recommended that:
• ACC should ensure that individual rehabilitation plans are tailored to a claimant’s rehabilitation needs; • ACC case managers should make sure that a claimant fully understands their rights and responsibilities before the claimant is asked to sign an Individual Rehabilitation Plan; and • ACC should report both short-term and long-term claimant satisfaction rates in a consistent manner. |
| What happened as a result of our work | • We were asked to present our report to the Ministers
Advisory Committee on ACC.
• ACC has also provided us with a formal response to our recommendations, and is looking to implement our recommendations. |
| TITLE OF REPORT | GOOD PRACTICE FOR MANAGING PUBLIC COMMUNICATIONS BY LOCAL AUTHORITIES |
|---|---|
| What it was about | The report updates our “best practice” guide for local authorities in respect of advertising and other communications. |
| Key recommendations | The report contains 13 principles which are intended to be used as a basis for local authorities to develop their communications policies, including policies on managing communications in the pre-election period. |
| What happened as a result of our work | The report has been widely accepted in the local government sector and has prompted a number of requests for guidance in the period leading up to the October 2004 triennial elections. |
| TITLE OF REPORT | LOCAL AUTHORITIES WORKING TOGETHER |
|---|---|
| What it was about | The audit sought to assess shared services arrangements against a set of high-level expectations with the objective of providing guidance to local government. |
| What we found | We found that:
• the opportunities for working together are many and varied; • a systematic approach will help local authorities avoid pursuing unproductive opportunities; and • support and leadership of councillors and chief executives helped give joint arrangements focus and direction. |
| Key recommendations | Because of the nature of the report, we made no
recommendations. However, the report identified a number
of key messages which were:
• When entering into a joint arrangement, local authorities should agree how they intend to work together. • Local authorities should determine the appropriate form and legal structure for the joint arrangement. • Local authorities should prepare a business case before committing resources to a joint arrangement. |
| What happened as a result of our work | We presented our report to the Local Government and Environment Committee. We are also seeking opportunities to discuss the report with local authorities. |
Unprogrammed inquiries
The Office reported on 6 unprogrammed inquiries during the 2003-04 year.
The most significant of these were:
- Inquiry into Expenses Incurred by Dr Ross Armstrong as Chairperson of Three Public Entities;
- Inquiry into Public Funding of Organisations Associated with Donna Awatere Huata MP; and
- Industry New Zealand – Business Growth Fund Grant to The Warehouse.
Supplementary information
Work that the Office undertakes to maintain and enhance professional practices includes:
- The Auditor-General’s Auditing Standards;
- training and support for our auditors;
- reviewing auditor performance; and
- implementing our allocation and tendering processes.
The Auditor-General’s Auditing Standards
The Auditor-General’s Auditing Standards establish the minimum standards to be applied to annual audits conducted on behalf of the Auditor-General. Under section 23 of the Public Audit Act 2001, the Auditor-General must publish the standards, by way of a report to the House of Representatives, and include in each Annual Report a description of any significant changes made to the standards during a financial year. The standards consist of the ethical and professional standards of the Institute of Chartered Accountants of New Zealand (ICANZ), supplemented by the Auditor-General’s Statements and (where an ICANZ standard does not exist) the Auditor-General’s Specific Standards. The standards are available on our website www.oag.govt.nz.
We enhanced two Auditor-General’s Statements during the 2003-04 year as follows:
- We wanted to clarify the way in which we report our opinion on an entity’s financial statements in the audit report. This resulted in a substantial revision of the presentation and format of audit reports – as contained in the revised Auditor-General’s Statement 702: The Audit Report on an Attest Audit.
- We updated Auditor-General’s Statement 202: The Terms of the Audit Engagement, by including a standard audit engagement letter to be used for all public entities. The revision means that the nature of the public sector audit, and the accompanying responsibilities of the auditor and entity management, is communicated consistently and comprehensively.
Training and support for our auditors
The Office maintains a Manual for Audit Service Providers, which provides:
- background information to assist auditors;
- The Auditor-General’s Auditing Standards; and
- annual audit plans (known as “audit briefs”) issued by the Auditor-General for all major sectors, together with sector information where appropriate.
The Manual also contains guidance for auditors in the form of statements of general policy on, for example, matters that affect entities in more than one sector or are unique to the public sector.
We also provide technical accounting and auditing advice and support to our auditors. We conducted a number of seminars for auditors over the 2003-04 year on:
- schools audits (7 seminars);
- local government; and
- central government.
Reviewing auditor performance
We aim to review the performance of each of our Appointed Auditors once every 3 years. Follow-up reviews may be initiated if we identify a need for improvement.
In 2003-04, we carried out 45 reviews (equal to our target). Consistent with previous years, the work we reviewed was, with only a few exceptions, of good quality. For the exceptions, we took appropriate follow-up action.
Implementing our allocation and tendering processes
The introduction of the audit resourcing model has significantly changed the way in which auditors are selected to carry out annual audits. The majority of entities are now subject to “allocation” by the Auditor-General. However, the audits of some entities with a strong commercial focus may still be subject to a process of competitive tendering, where the Auditor-General considers it to be the most appropriate process to select an auditor to act on his behalf.
The management of the allocation process and the implementation of the tendering process are facilitated by the Director, Auditor Appointments at the OAG. The integrity of these processes are evaluated annually by an independent reviewer (see page 54).
The report of the independent reviewer for 2003-04 is reproduced on pages 116-117.
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