Part 2: The process for auditing Long-Term Council Community Plans
2.1 Preliminary planning and risk identification
- Introduction
- Our approach
- Results of the self-assessment reviews
- Consultation
- Key controls review
- Conclusions
Introduction
2.101
From 2006, the Auditor-General has a new statutory duty to issue an opinion on a
local authority’s draft and final Long-Term Council Community Plan (LTCCP) under
sections 84(4) and 94 of the Local Government Act 2002 (the 2002 Act). Councils
have been preparing and publishing long-term financial plans since 1996, but the
plans have not been required to be audited until this year.
2.102
Both the LTCCP and the requirement for it to be audited are unique to New
Zealand. While other local government jurisdictions involve auditors in
prospective information, the requirement for such an audit is a unique response
to the specific legislative arrangements for New Zealand local government in a
context of general empowerment.
2.103
In this article we set out our approach to the audit of LTCCPs and discuss the
potential implications of breaches in the statutory adoption process for the LTCCP.
2.104
The article discusses issues arising from our work to date in the preliminary
planning and risk identification stage of our audit approach. These issues have
been identified through the outcome of 2 pieces of work that we undertook as
preparation for the audit of LTCCPs. The first of these was a “self-assessment”
exercise that we asked local authorities to complete. We discuss the key results
from these self-assessments later in the article. Secondly, our auditors completed
a “key controls” review to analyse the controls that councils had in place around
the preparation of the LTCCP. The main findings of this work are also reported later
in the article.
Our approach
2.105
We recognise that the LTCCP is a plan, and that plans, by definition, are not
based on information that is certain. However, we also recognise that the LTCCP
needs to represent the best knowledge of the local authority of what is intended
and required for it to achieve its purpose as a basis for consultation, decision making,
and subsequent accountability. Our work therefore seeks to confirm that
prospective financial and other information are the best estimates of the local
authority and are reasonably based on the best knowledge of future events.
2.106
Our approach1 consists of 5 main stages, shown in Figure 2.1.
Figure 2.1
Five main stages of our LTCCP audit approach
2.107
We consider that councils’ planning systems are vital to the preparation of a
robust LTCCP. We hope that by focusing on systems, rather than only on specific
decisions or forecast amounts, good practice will be encouraged and that, over
time, this will give communities greater confidence in the robustness and quality
of the LTCCP.
2.108
The major focus in our work is on the statement of proposal (SOP) for the LTCCP,
as this is the main document for public consultation. The SOP is often referred
to in the sector as the “draft LTCCP”. Our interest in the final adopted LTCCP is
primarily to ensure that changes made through consultation and final decisions
have been appropriately reflected in the adopted LTCCP. We note that handling
such changes can be demanding, where significant changes are made in response
to public feedback or when other changes are made between publicly notifying
the SOP and adopting the final LTCCP. It has been important that councils and
auditors work closely together to carefully manage the timetable for auditing and
adopting their final LTCCP.
Potential implications of breaches in the LTCCP adoption process
2.109
Given the pressure the local government sector has been under to adopt audited
LTCCPs, we formed some preliminary views about the potential effect of breaches
in the statutory adoption process for the LTCCP. We specifically considered the
effects of a failure to include an audit report or to meet the statutory adoption
date of 30 June.
2.110
Our view is that it would be preferable to adopt a day or 2 late with an audit
opinion, than to adopt in time without an audit opinion, because:
- failing to include an audit report in the SOP or adopted LTCCP would be likely to be a significant failure that would prevent a council doing any of the things set out in paragraph 2.112, including setting rates; whereas
- failing to adopt the LTCCP by the statutory date could be considered to be more technical in nature, assuming that a council made no decisions of the nature set out in paragraph 2.112 and proceeded as quickly as reasonably practical to adopt the LTCCP.
2.111
In addition, the 2002 Act requires a council to have an LTCCP in place at all times,
and to adopt the LTCCP before 1 July of the first year in which it is to take effect. While the LTCCP is not a commitment or obligation to do any specific thing,
certain decisions can be taken only where they are provided for in the LTCCP.
2.112
These include:
- decisions covered by section 97 of the 2002 Act, which include decisions to significantly alter service levels; transfer ownership or control of a strategic asset; or construct, replace, or abandon a strategic asset;
- amendments to the financial policies set out in section 102 of the 2002 Act;
- decisions under section 141 of the 2002 Act relating to the sale or exchange of endowment land; and
- most significantly, the setting of rates, which under section 23 of the Local Government (Rating) Act 2002 must be set by a council in accordance with the relevant provisions of its LTCCP and the funding impact statement.
Effect of a qualified audit opinion
2.113
The 2002 Act does not address the question of the effect of a qualified opinion
on a draft or final LTCCP or on the consultation process for the SOP. In our view,
a qualified audit report on a draft or final LTCCP does not, in itself, invalidate the
LTCCP. While a qualified audit report on a final LTCCP is considered significant, it
does not affect a local authority’s ability to make decisions or set rates.
2.114
One of the purposes of the audit requirement is to contribute to the information
necessary for communities to assess the quality of the LTCCP, both at the draft
stage and after adoption. The audit report forms part of the LTCCP, and we would
expect readers to take account of the audit report when making submissions on
the plan. A local authority may face increased risk of challenge to its consultation
process on the SOP, to the rates set, or to the decisions made under the final LTCCP,
depending on the nature of the qualification.
2.115
The Auditor-General does not have the power to compel a local authority to
change its SOP, but a qualified opinion on a draft LTCCP may lead to changes and
improvements in the final LTCCP.
Results of the self-assessment reviews
2.116
We developed a methodology to meet our reporting responsibility under the 2002
Act. This involved looking internationally for audit techniques that would help
us to effectively address the principles provided to guide councils’ judgements
in key areas (such as decision-making and consultation) within the general
empowerment that the 2002 Act provides.
2.117
One of the elements of the methodology we developed is the “self-assessment”. While this is an experimental approach, we were aware that mayors and chief
executives in the United Kingdom had evaluated self-assessment as the most
useful tool used by the United Kingdom Audit Commission in undertaking
Comprehensive Performance Assessments of local authorities in a statutory
context similar to the 2002 Act. In deciding to use this approach, we consulted,
developed, and tested the assessment with sector representatives.
2.118
Our purpose for using this approach was to ensure that our audit work would be
based on an understanding of the processes that underlie councils’ preparation of
an LTCCP from a principle-based, governance perspective. This would enable us to:
- provide feedback for auditors, based on our understanding of “reasonableness” reflecting the diversity of councils;
- identify risks in the council’s development of its LTCCP that were relevant to our planning of audit work and that had the potential to affect the nature and content of our opinion and management report; and
- establish a base of knowledge and information to allow us to assist the sector in the future by developing information to support good practice.
2.119
A small group of advisers oversaw our review of councils’ self-assessments. These
advisers were suggested by Local Government New Zealand and the Society of
Local Government Managers because of their knowledge and understanding of
the 2002 Act and the operation of councils.
2.120
The review involved grouping councils according to their size and scale. These
groups had to be large enough to allow generalisation but small enough to be
meaningful. We used 6 variables – 3 that were related to external constraints
(population, rates to median income, and population to area) and 3 that were
related to internal constraints (full-time equivalent staff, debt to equity, and other
council income).
2.121
We grouped each data variable into 6 groups by looking at their spread. Councils
were sorted according to which group they most commonly fell into across all the
6 variables.
2.122
We then reviewed each council’s self-assessment, and focused on common
themes that emerged from the information. These themes were:
- Consultation – the range of mechanisms used to engage with a range of stakeholders, how the council’s approach to managing consultation is instilled in the organisation, how consultation feedback is captured, involvement of stakeholders at phases of decision-making, the effectiveness of consultation techniques, and methods for engaging with Māori.
- Outcomes – assessment and communication of current state of well-being and trends, engagement of groups and organisations capable of contributing to the achievement of outcomes and monitoring, engagement with the community (including representativeness and inclusivity), community prioritisation and confirmation of the outcomes, and development of monitoring intentions.
- Governance – involvement from councillors and staff, clarity of roles between participants in the process, and relationships and links between policies and maintenance of such relationships.
- Decision-making – general processes around the preparation and presentation of decision-making advice that showed consideration of the decision-making requirements of the 2002 Act, controls around information going to councillors and the community, whether or not inconsistent decisions can be identified, and council-based levels of service decisions on appropriate sector-developed good practice.
- Performance management systems – whether or not regular performance management information is used to guide council activities and decisions; whether or not there is a logical framework and relationship between community outcomes and service levels; whether or not other sources of information/initiatives are identified and used to manage performance (for example, customer complaints and any other monitoring of well-being).
2.123
We developed group descriptors to help our auditors in planning their audit work,
forming opinions, and exercising judgement about the reasonableness of councils’
approaches.2
2.124
While the discussion below sets out the main themes that we identified, each
council will have provided additional information to allow auditors to assess
whether issues have been correctly identified in each instance. The auditors also
assess the significance of the information for our audit work, recognising that
there may be further information or circumstances that should be taken into
account as auditors form their opinions and report to each council.
2.125
Below are the common issues that we identified.
Consultation
2.126
The consultation provisions are an area that has greater emphasis in the 2002
Act compared to the Local Government Act 1974 (the 1974 Act). The provisions
require judgement to be used, and rest on consultation practices and principles
that have been emerging both in New Zealand and internationally for some time. The 2002 Act therefore reflects the growing expectation of communities to have
reasonable opportunities to be heard.
Consultation infrastructure
2.127
In our view, councils generally take their consultation duties seriously and make
good endeavours to consult and to make their processes accessible. We were
concerned about the responses to basic procedural requirements in only a
handful of cases. These included providing responses to submitters about the
result of, and reasons for, decisions and whether the council had mechanisms
for consulting with Māori. Issues we noted tended to relate to improvements to
their existing processes that councils could consider. However, probably because councils are still becoming familiar with the 2002 Act’s emphasis on general
consultation obligations (rather than on statutory consultation procedures
for specific decisions), in almost 40% of the self-assessments it did not appear
that councils had set up the formal internal support to assist staff and elected
representatives to ensure that:
- consultation steps are observed, such as considering the significance of issues to decide if, and what type of, consultation may be necessary; and
- the relationship between proposed consultation and decision-making needs is clear.
Options provided in consultation
2.128
Councils need to carefully judge the extent of information about decision options
and their associated costs and benefits that they provide in public consultation
material.
2.129
Decision-making obligations require councils to seek to identify all reasonably
practicable options for achieving the objective of a decision. A consultation
principle in section 82(1)(a) of the 2002 Act requires councils to provide persons
who may be affected by, or interested in, a matter with relevant information in
a manner and format that is appropriate to the preferences and needs of those
persons.
2.130
We noted that about a third of councils did not seem to provide much information
about the options and the effects of those options in public consultation material. Where option information was provided, there was extensive information about
the preferred option and little or none about other options.
2.131
Councils have a leadership role, and it is appropriate for their views to be given
in public information. However, it is also important that a reasonable level of
coverage is provided so that communities can assess the relative merits of options
when providing feedback.
Making effective use of consultation
2.132
One area that we thought councils could consider further is the means by
which they evaluate the effectiveness of their consultation. Many councils have
expressed concerns both to us and to others about the compliance costs of
consultation and the potential for “consultation fatigue” by placing too great
a consultation burden on communities. We were therefore surprised that over
a quarter of councils did not appear to have taken active steps to assess the
effectiveness of their consultation work, in terms of whether the methods used
are accessible to the public or whether the community felt it was being consulted
on appropriate issues.
2.133
We think that councils are right to be concerned and check whether the
consultation exercises they undertake are necessary and are as easy as possible
for members of communities to participate in. We believe that councils could
therefore consider ensuring that they use the information they have already
obtained through previous consultation exercises more effectively. They could do
this by capturing and maintaining their consultation knowledge and using this to
build:
- their awareness of the nature and type of issues that communities wish to be consulted on and those they want their council to “get on with”; and
- their knowledge about the particular groups and individuals who might be interested in, or affected by, various types of decisions.
Outcomes
2.134
Councils were required to undertake a community outcomes process for the
first time in 2006. Many councils made extensive and innovative efforts to get
widespread and broadly representative community input. We raised questions
about the process for community input with fewer than 20% of councils. However,
other areas of developing the community outcomes are more challenging – particularly in the context of this first round of LTCCPs. In particular, there has
been a debate about what information communities may need to allow them to
give well-informed feedback about outcomes and priorities.
Providing contextual information for well-being in communities
2.135
Almost half of councils did not appear to have provided communities with
information about the social, economic, environmental, and cultural state of
their city, district, or region, often because they were concerned that to do so
could distort the feedback that communities may provide. In our view, the 2002
Act is clear that the purpose of the community outcomes process is to allow
communities opportunities to consider outcomes and priorities in the context of
well-being. We therefore think that objective information about current state and
trends would be helpful for people wishing to participate.
Liaison with other organisations and groups
2.136
We were also concerned that it was not clear in about a quarter of cases if aspects
of the requirements of section 91(3) of the 2002 Act, about engagement of other
organisations and groups capable of influencing the identification or promotion
of community outcomes, had been given effect. We recognise this is an area in
which practice is developing and strengthening.
Development of monitoring arrangements
2.137
We were surprised that over a third of councils had not completed their
community outcomes process at the time we reviewed their self-assessments (July and August 2005). If councils are to be able to consider how their services
can contribute to outcomes, outcome information needs to be in place before
the service levels and other underlying information are assessed. It was not clear
to us how this sequential development would have been able to occur for some
councils. This is likely to have put pressure on these councils, as they would have
had to consider a large range of information simultaneously much later in the
process of delivering their LTCCP.
2.138
Likewise, we were surprised that monitoring intentions for community outcomes
had not been developed in some cases. Section 92(1) of the 2002 Act sets out the
requirements for local authorities for the monitoring and reporting of progress
towards community outcomes, and section 92(2) sets out the obligation to seek
the agreement of other organisations to the monitoring and reporting procedures. Clause 1 of Schedule 10 states that the LTCCP must set out how a council will
monitor and report on community outcomes. In our view, the potential to develop
monitoring intentions at the outcome level should have assisted councils to create
a meaningful performance framework for their own service levels by giving a
logical flow for performance management and reporting.
Providing for community debate on priorities
2.139
We have noticed, as has the local government sector generally, that the
community outcomes for many cities, districts, and regions are often broadly
similar. However, it appeared from the self-assessments that up to 15% of
councils may not have undertaken steps within their outcomes process to allow
communities to debate priorities and options, as intended by section 91(2) of
the 2002 Act. It may be that using local information and processes that sharpen
community and stakeholder attention on current context and trends in setting
outcomes and priorities would encourage more local variation to emerge. However, we are also conscious that local variation is not of itself the goal of a
community outcomes process.
Our audit obligations in respect of community outcomes
2.140
The community outcomes process does not form part of the LTCCP, and is
therefore not directly covered by our audit opinion. Rather:
- the LTCCP is required to include information about the outcomes, the process by which they were developed, how they are to be monitored, and how the council’s activities will contribute to their achievement; and
- the outcomes are a part of the underlying information that a council is required to consider when building a long-term plan, and it is therefore important that the information is prepared in a manner that would allow a council to rely on it when preparing its LTCCP.
2.141
Our focus has therefore been on understanding the process used by each
council, and checking that the required statutory information is included in
LTCCPs. We observe that, while there were many stand-alone processes that
were well run by individual councils, processes that involved collaboration by
groups of neighbouring councils generally allowed both greater engagement
with community and other groups capable of influencing outcomes, and greater
sharing of the cost of the process. However, there is also a risk that regional
processes could overlook specific local concerns.
Governance
2.142
Preparing a long-term plan is a process in which underlying technical information
must be reconciled with a council’s existing policies and strategies and then
shaped by the emerging and changing preferences of communities. The elected
representatives who make the choices and trade-offs for the long-term direction
of a council are at the heart of this process. We therefore wanted to understand
the governance processes underlying the preparation of LTCCPs.
Involvement of elected members and staff
2.143
We noted widely divergent approaches in councils’ facilitation of community
outcomes and the councillors’ involvement. Such approaches are for each
council to determine. However, from our review of self-assessment responses,
we were concerned that there may not have been a high level of opportunity
for involvement by councillors in up to a third of cases. In our view, if elected
members have had a minimal role in developing the LTCCP (for instance, if their
opportunity for involvement occurs solely at the presentation of an SOP for
adoption), there are risks that the LTCCP will not be understood, owned, and
supported by its governing body.
2.144
Likewise, an LTCCP that is not based on the underlying information prepared and
managed by council staff, and that is not communicated to, or understood by,
those staff, is less likely to be seen as relevant, and is therefore less likely to be
implemented and maintained. We were not confident about the level of senior
managers’ communication about the council’s long-term planning to staff in just
fewer than 20% of instances.
Alignment and strategic flow
2.145
In working to determine the levels of service that a council both aims to achieve
over time and may be able to achieve at any point in time, a council draws
together information from:
- “top-down” sources – such as the results of the community outcomes process, statutory obligations, assumptions about the wider changes that are likely to affect the council, and a range of policies and plans that the council has chosen to adopt; and
- “bottom-up” sources – such as the condition and likely remaining lives of its assets, its current staff, and commitments such as financing arrangements.
2.146
A council therefore needs to plan its LTCCP so that each of these sources of
information is prepared, and to draw these together in a logical sequence. In
particular, we noted that although asset management plans including service
levels were in the process of being confirmed:
- newer parts of the 2002 Act, such as community outcomes or water and sanitary services assessments, were sometimes still being prepared; or
- council policies and plans had not been maintained nor had their continuing relevance been confirmed.
2.147
Conceivably, these extra steps could provide information or public feedback that it
would be useful to consider when confirming service levels.
Quality assurance processes
2.148
Ensuring that the document tells a coherent and consistent story, and contains all
its required contents, is one of the important final processes in preparing a plan
that integrates many sources and types of information. We asked councils to tell
us the quality assurance steps they were intending to take to ensure this, and we
had concerns about these in just over 20% of cases.
Decision-making
2.149
One of the areas that the 2002 Act has placed a greater emphasis on than the
1974 Act has been in setting out principles and council responsibilities with
respect to decision-making.
2.150
The adoption of an LTCCP is itself a decision. However, an LTCCP is also a synthesis
or integration of a series of underlying decisions made over time. The decisions
are reflected in the services a council provides and the assets and resources it
commands to deliver those services. We have therefore been concerned to both:
- ensure that the process of adoption meets each council’s responsibilities under the 2002 Act; and
- understand the internal systems by which a council ensures that it addresses its decision-making responsibilities (set out primarily in sections 76-81 of the 2002 Act) when it makes any specific decision.
Systems underlying decision-making
2.151
In circumstances where there are not adequate systems and resources in place to
ensure that decision-making responsibilities can be met, there is a risk that the
decision-making provisions of the 2002 Act (for example, about the significance
of an issue and the identification and analysis of options having regard to effects on well-being) have not been complied with. We raised questions with over half of
the councils about areas of their systems and processes for decision-making as a
result of our review of their self-assessments. We think this is likely to be because:
- The decision-making requirements generally require councils to identify and consider relevant matters when determining the procedures and factors they need to assess for each decision. Therefore, the decision-making provisions are essentially judgement-based, rather than setting out prescriptive requirements.
- The decision-making provisions are newer areas of local government legislation, and many councils are determining how best to address the intention of the requirements.
Inconsistent decisions
2.152
One area in which we noted concerns was that of section 80 of the 2002 Act–
80 Identification of inconsistent decisions—
(1) If a decision of a local authority is significantly inconsistent with, or is anticipated to have consequences that will be significantly inconsistent with, any policy adopted by the local authority or any plan required by this Act or any other enactment, the local authority must, when making the decision, clearly identify—
(a) the inconsistency; and
(b) the reasons for the inconsistency; and
(c) any intention of the local authority to amend the policy or plan to accommodate the decision.(2) Subsection (1) does not derogate from any other provision of this Act or of any other enactment.
2.153
The planning provisions set out a framework within which council decisionmaking
is to occur. The provisions emphasise integrated decision-making by
councils with opportunities for public participation.3Section 80 essentially says
that deviating from prior plans and policies in force is acceptable if a council
considers and understands the effects of the intended change and is open about
its reasons for doing so. A council therefore needs to be conscious of its existing
policies and plans for it to be able to identify deviations from them. The responses
to self-assessments suggested that nearly a third of councils do not have
arrangements that make policies and their implications easily known (primarily by
council staff) for the purpose of identifying inconsistent decisions.
Determining levels of service
2.154
The other area that we were interested in was the process councils used to
decide on levels of service to provide. Determining and understanding service
levels and their effects is important, as they provide the basis for planning asset
management intentions, as well as general operating needs. Service levels
can be influenced by various factors – for example, legislative requirements,
resident or customer needs, and preferences supported by underlying technical
specifications. Understanding and making choices about the level of service to
deliver is therefore a core decision-making function that in turn dictates the
expenditure and revenue needs of a council.
2.155
At the time of our self-assessment work, about 40% of councils told us their
service levels were still being developed. As part of reviewing asset management
plans, many were taking the opportunity to review service levels either generally
or in specific activity areas, or were reviewing community feedback already
received to identify areas that may need improvement. In this review, councils
were considering how best to address the community outcomes and well-being
context that the 2002 Act requires when making decisions about service levels.
Performance management systems
2.156
Many councils identified difficulties in this area. These can be summarised as:
- a lack of resources internally (particularly for smaller councils);
- a lack of information specific to their area (we understand that Statistics New Zealand and other central government agencies are working on this); and
- difficulty in developing performance measures that are both measurable and meaningful (a problem that is by no means unique to local government).
Determining performance frameworks
2.157
Most councils have been working on this area, and have continued to do so in
the time leading up to the adoption of the 2006-16 LTCCPs. However, in mid-
2005, over a third were yet to complete development work on a performance
framework for assessing service levels. Our analysis of responses suggested that
the frameworks used by almost a further third may not systematically collect
information that addresses intended achievements and key risks.
2.158
From the self-assessment information presented, there is a risk that performance
frameworks will not:
- provide a coherent and logical flow from well-being and community outcomes to performance measures and targets (see Figure 2.2); and
- specify relevant performance measures accompanied by “best estimate” performance targets.
Figure 2.2
Logical flow in the performance framework
2.159
We are conscious that performance measures and targets are one of the evolving
areas of the 2002 Act as councils work to link well-being and outcomes to the
rationale for activities and service levels, and to performance measures and
targets. We are also conscious that there are inherent difficulties in assessing
performance for some types of activities (such as emergency response services). We therefore asked our auditors to exercise careful judgement about the
materiality of weaknesses in councils’ performance frameworks. We also
maintained a national overview of our audit work to ensure that we formed
opinions consistently, while taking account of the relative size and scale of
councils.
2.160
This is an area that we acknowledge will see improvement over time. We aim to
support this work, and to date have shared with the sector the understanding
we have gained in thinking about, and assessing, the development of council
performance frameworks and systems.
Key controls review
2.161
Alongside the self-assessment work described in paragraphs 2.116-2.160,
our auditors also conducted a high-level review of the planning systems and
processes each council adopted to prepare its LTCCP. This “key controls” review
looked at:
- project management;
- asset management planning;
- establishment of levels of service;
- business plans and budgets;
- financial modelling; and
- performance monitoring and reporting.
2.162
The purpose of the “key controls” review was to analyse the controls that councils
used to assess their audit risks. Being able to rely on controls lessens the auditor’s
need to do detailed checking. Each council’s review was centrally analysed using
the same grouping and general process outlined for the self-assessment process. This enabled a consistent approach to be taken and ensured that each council was
assessed for audit risk relative to its size and scale of operation.
Key findings
2.163
We outline below the common concerns that arose from this work.
Project management
2.164
In general, project management and planning did not address the risk of tasks
or information being incomplete. The process tended to rely strongly on senior
management reviewing whether or not information was complete. This was
coupled with a general tendency to produce information “just in time”. The
risks of “just in time” planning became evident when the SOPs to adopt a draft
LTCCP were centrally reviewed. The time needed for audit clearance and multiple
plan iterations was often not built into the plan, and many councils had to
move meeting dates in order for the plan to be completed or amended and an
unqualified audit opinion issued.
Asset management planning and service level definition
2.165
Many councils appeared to be preparing this underlying base of information at a
late stage and were potentially not leaving enough time to prepare an integrated
plan. This meant that, in some instances, it was not clear how asset management
information informed capital expenditure projections and operational plans. In other instances, it appeared that asset management information was being
adjusted to fit within available funding without any apparent consideration of the
effect this may have on levels of service.
2.166
In a number of instances, the audit of the SOP to adopt the LTCCP involved
additional work because the information in the asset management plans was out
of date, unreliable, and, in some cases, non-existent. Some councils are still not
producing asset management plans that are reliable enough to inform strategic
planning.
2.167
We intend to report further on our observations of asset management in our
report to Parliament on the results of our LTCCP audit work.
Financial modelling
2.168
There was a lack of integrity checks and consistency flows within models – particularly when associated with spreadsheets. Some councils also intended
to use financial modelling systems rather than relying on spreadsheets, but at
the time of our field reviews (late 2005) these systems were yet to be written
or implemented. This meant that their suitability and effectiveness would be
confirmed only relatively late in the cycle for developing the LTCCP.
2.169
While a large number of councils used integrated financial modelling packages,
there were still many that relied on spreadsheet systems to produce the financial
information for the LTCCP. While a well-written spreadsheet is a powerful tool,
in too many cases they were not robust enough to allow adequate modelling
of options. They also did not have the checks and controls we would expect, to
ensure adequate flow through of assumptions and calculated values.
Conclusions
2.170
It is important that councils take the lessons and experiences of the 2006-16
LTCCP process and build on them for the 2009-19 LTCCP.
2.171
Self-assessments were provided to us in response to a request for information to
help us assess underlying processes associated with consultation, preparation
of community outcomes, governance, decision-making, and performance
management systems. Key controls were prepared by our auditors through high-level
reviews of council systems and discussions with council management.
2.172
The information has formed one of the inputs on which our auditors have
assessed risk for the purpose of planning substantive audit work. Therefore issues
identified through these processes have been considered and raised with each
council, as relevant, to determine if the risk has been correctly identified and, if
so, how it might be mitigated or addressed by the council, either for the 2006-16
LTCCP or in future planning processes.
2.173
We are grateful for the sector’s co-operation in providing this important
information.
2.174
While councils are completing LTCCPs – often with “work-arounds” to deal with
control issues – it is apparent that, for many, the nature of the process is a project
undertaken every 3 years. For the LTCCP process to deliver on the purposes
outlined in section 93(6) of the 2002 Act, councils will need to ensure that the
planning and management processes are ongoing.
2.175
To achieve this, councils should consider:
- continuing to develop processes to give effect to the principles of the 2002 Act;
- continuing to develop robust underlying information – for example, asset management plans, levels of service, and assumptions;
- implementing reliable modelling systems;
- developing adequate disclosures – for example, price changes;
- developing meaningful performance management frameworks – especially ones that document the rationale for the activity and the levels of service provided; and
- ensuring internal consistency and integrity.
Next steps by the Office of the Auditor-General
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We intend to review the process we undertook for the audit of the 2006-16 LTCCP
when our audit work is complete. We intend to provide information on this in
our next report to Parliament on local government in 2007, and expect that this
will cover issues such as lessons learned, the feedback from the sector, and our
progress towards the audit of the next LTCCP.
1: See Local Government: Results of the 2003-04 Audits, parliamentary paper B.29[05b], pages 63-76, for further comment on our audit approach.
2: The group descriptors and more detail about the process we used are on our website (www.oag.govt.nz).
3: See, for example, section 93(6) of the 2002 Act.
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