Submission on the Review of Tomorrow’s Schools
Introduction
Tomorrow’s Schools devolved the governance of schools to Boards of Trustees (Boards) which are individual Crown Entities. The Ministry of Education (the Ministry) provides schools with the buildings they occupy and pays all school teachers through a central payroll system, but the Boards are responsible for the governance and operation of their schools. In order to provide an effective education and ensure each student achieves to their best, a school has to be managed well. This includes all areas under the control of the Board; curriculum, staffing, health and safety, finance and some aspects of property.
The Auditor-General is the auditor of all state schools, including state-integrated schools. Schools are responsible for spending about $7 billion of public money each year. It is important that this is spent in an appropriate and prudent manner. Our audits focus on the school’s financial statements, and the results of our audits and other work we carry out in the school sector gives us a unique view across the sector.
In this submission we explain the work of the Office of the Auditor-General, the accountability of schools, and why this is important. We also set out some of the observations from our work, both our annual audits and other recent reports.
Background
The Office of the Auditor-General
Our work
The Public Audit Act 2001 governs the work of the Auditor-General. We carry out annual audits as required by legislation, and may carry out performance audits and inquiries into a public entity’s use of resources. Our work gives assurance to Parliament, public entities, and members of the public, that the annual reports of public entities fairly reflect the results of their activities, and are consistent with laws and regulations relating to financial reporting. We may also consider whether public entities are carrying out their activities effectively and efficiently, and are spending public funds appropriately.
Why is accountability important
Principles that are important to public sector accountability are; transparency, fairness, integrity, and trust.
Through their annual reports public entities are accountable to Parliament and the public for their performance and their use of public resources. In this context, we consider that transparency is crucial. Transparency is about a public entity's openness about its activities − the extent to which it provides information about what it is doing, where and how this takes place, and how it is performing.
Public reporting by public entities on their performance can influence the degree of trust in the delivery of public services and the public entities that deliver them. Parliamentary scrutiny of public entity performance is important because it helps to show whether public entities can account for what they have done and what they have achieved. It is also important that public entities engage with those that use their services and the wider New Zealand public.
The future of public accountability
Any changes to the Tomorrow’s Schools model will have implications for how schools remain accountable to their stakeholders. However, the need for good accountability will not change. While the focus of the review of Tomorrow’s Schools is to improve educational outcomes for all students, ensuring schools are governed well is an important part of this. When considering changes to the current model, in our view it is also important to consider how schools will remain accountable, both for educational achievement and other areas of responsibility.
How schools are accountable currently
Accountability framework for schools
All state schools (including state-integrated schools) are governed by a Board of Trustees (the Board). Each Board is an autonomous Crown Entity and must follow the provisions of the Education Act 1989 and those parts of the Crown Entities Act 2004 that are applicable. The Board has discretion about the school’s operations and how it will use school resources.
As public entities, schools must be accountable to Parliament and the public for the resources they are given. The Board should use those resources for educational purposes. Education affects the lives of many New Zealanders, so it is of interest to many different parties, including parents, whānau, local communities, and the wider public. Schools are subject to the oversight of both the Ministry of Education (the Ministry) and the Education Review Office (ERO).
School planning and reporting requirements
Every year a school must produce a Charter. The purpose of the Charter is to outline the areas the Board will focus on, both in the long-term and the coming year, incorporating the priorities identified by parents, whānau, and the community. The school then reports its progress against the aims and targets in its Charter to its community in its Analysis of Variance. The Board must send both of these documents to the Ministry by 1 March – the Charter for the coming year and the Analysis of Variance for the previous year.
The school must also prepare a 10 year property plan (10YPP) every five years which sets out its strategic intentions for property matters. This should be consistent with the strategic aims in its Charter. This 10YPP also includes an agreement with the Ministry about property projects for the next five years.
The school must prepare an Annual Report each year. A school’s Annual Report is required to include an:
- Analysis of Variance;
- financial statements;
- list of trustees;
- audit report; and
- Kiwisport statement.
Section 87 of the Education Act 1989 sets out what school financial statements should contain. It states that the financial statements must follow generally accepted accounting practice (GAAP). The External Reporting Board (XRB) has a mandate for determining GAAP, and that means the financial statements must follow the public sector accounting standards issued by the XRB.
The school must give its draft financial statements to the school’s auditors by 31 March after the school year end of 31 December, and send the audited financial statements to the Ministry by 31 May. Schools must now publish their Annual Report on the school’s website. This is a recent change to the Education Act 1989.
What does the Auditor-General audit?
Each year, the Auditor-General must audit all state schools and any entities controlled by a state school, or schools, which have an “audit requirement”. We do this by appointing auditors from local firms throughout New Zealand to audit each school on behalf of the Auditor-General. The total cost of school audits is about $12 million per year.
The Auditor-General only audits the financial statements of a school. We do not audit a school’s non-financial performance. The school publishes its Analysis of Variance as part of its Annual Report, which reports on how it has met the aims and targets in its Charter. While our auditor will read the Analysis of Variance to ensure it is not inconsistent with the audited financial statements, we do not audit it.
Our audit considers whether a Board has prepared and presented its financial statements in keeping with relevant accounting standards. We also consider certain aspects of laws and regulations that affect the financial statements, and matters of probity and financial prudence.
Once the audit is complete the Board will receive an audit report which sets out our opinion on the financial statements. This is a public document and must now be published on the school’swebsite with the school’s Annual Report. This recent change to the Education Act makes schools’ Annual Reports more accessible and increases transparency. In recent years we have published a summary of the results of the school audits on our website, which we intend to continue to do in the future.
The Board will also receive a management letter which sets out the detailed findings from our audit, including areas for improvement. During the audit our auditors will also provide informal advice and support to schools.
The Auditor-General also has an annual work programme of performance audits and other work. In July 2017 we published a report on how well the Ministry manages the school property portfolio. In this report we raised several recommendations for the Ministry, and we refer to some of our findings in this submission.
Observations from our work
In this section we set out some of the observations from our work, that we consider may be relevant to your review of Tomorrow’s Schools. It is important to note that, from our audits we do not find significant issues in most schools. However, where we do find that a school is not managing its finances effectively, it can result in the school getting into financial difficulty. Once a school is in financial difficulty, it may find it difficult to provide the necessary resources for an effective education.
Summary of results of the 2016 audits
For the year to 31 December 2016:
- Total public expenditure on schools was about $7.4 billion.1
- Schools collected about $540 million in locally raised funds, including about $130 million in donations.2
- Schools collected about $140 million from international students.3
- About 6% of schools have a working capital deficit, while 30% of schools have a working capital ratio (current assets/current liabilities) of 3 or greater.4
We report annually on the results of our school audits. Our most recent report, the Results of the 2016 school audits is available on our website. We issue a standard audit report on the financial statements for most schools. During 2017:
- We issued 26 modified opinions (16 for 2016 audits and 10 for prior year audits). For these schools we either couldn’t get enough evidence about an issue or we identified an error in the financial statements.
- We drew attention to matters of public interest in a further nine audit reports. These included conflicts of interest, spending on overseas trips, gifts and hospitality, and spending not clearly for school purposes.
- We identified 34 schools that were in serious financial difficulty (29 for 2016 audits and 5 for prior year audits).
- We identified 84 schools that had breached laws and regulations which impact on the school’s financial statements. These mostly related to breaches of borrowing limits, and unlawful loans or payments to staff.
In November 2017, 113 of the 2016 school audits were outstanding, about 5% of all schools, and 49 prior year audits were also outstanding. We have had a number of years of poor completion following the implementation of Novopay in 2012. Schools now need additional payroll information to complete their financial statements and because this information needs to be audited before it can be issued to schools, it is available later than in previous years. This has meant that auditors are receiving draft financial statements for audit later than usual, which puts pressure on auditors, financial service providers, and schools to complete the audits by the 31 May. We have also experienced delays and errors in the payroll information provided to schools by the Ministry in the past few years. If reporting is not timely, the information schools provide is less relevant, and proper accountability is more difficult to achieve.
We have seen some improvement in the current year. 86% of the 2017 school audits were completed by the statutory deadline of 31 May, which was a significant improvement on the prior year when only 81% of the 2016 audits were completed by the deadline. For the 2017 audits we worked closely with the Ministry and EY (the Ministry’s appointed auditor) to ensure that payroll reports were provided to schools earlier than in the past few years. We will be reporting on the results of the 2017 school audits later in the year.
School governance
School boards
A Board has responsibilities for curriculum, finance, health and safety and some responsibilities for property. Legislation sets out the make-up of the Board. It includes the school Principal, a staff representative and parent representatives. The boards of state-integrated schools can also have up to four Proprietor representatives.
As an autonomous Crown Entity the Board has discretion over how it runs the school and uses its resources. However, it must use its resources for educational purposes. A school board must have documented policies and procedures to support its general responsibilities to ensure:
- it performs effectively and efficiently;
- it follows laws, regulations, and contractual requirements;
- It minimises waste; and
- it conducts its business with probity - that is, the Board meets Parliament's and the public's expectations of appropriate standards of behaviour in the public sector.
We recognise that Board members want to do their best and have the children’s best interests at heart, but some may not have the necessary skills and capability to carry out their responsibilities effectively. In some areas, particularly rural areas (but not isolated to those areas), we have been told about schools that struggle to fill their boards.
When there is a lack of capability on a Board, the trustees often defer to the Principal who is a member of the Board. However, this may mean the Board is not properly carrying out its oversight role of management (as the Principal is responsible for the day to day running of the school). There may be a risk of inappropriate behaviour and spending, if the Board does not question the Principal’s decisions, or check their spending effectively.
Our school property report identified a heavy reliance on external property specialists.5 This can also be the case for school finances, with many schools employing external Financial Service Providers to do their finances. While we would expect a Board to use a specialist if its members lacked the necessary skills, there is a risk if a Board delegates its responsibilities without appropriate oversight of those specialists. The Board has the ultimate responsibility for property and financial matters and should not be fully delegating its responsibilities to an external party. While the Ministry have a panel of approved property planners, our school auditors find that the quality of Financial Service Providers can vary.
As Boards have three year terms, parent representatives on boards may focus mainly on the time that their child attends the school. There is a challenge in ensuring that boards plan for the long term.
The role of Principal
While the Principal is a member of the board, the Principal is also responsible for the day-to-day running of the school. The board may delegate some of its responsibilities directly to the Principal. A Principal’s role is more than just about education, the Principal is the Chief Executive of a Crown Entity.
Our report on school property identified that there was a lack of training for Principals on property matters,6 and we have been told that this is the same for financial matters. Principals need the right tools to be able to carry out their responsibilities effectively. New Principals may struggle, because they may not have had the opportunity to gain experience in some of the non-teaching areas that they are now responsible for and get little formal training in those.
Ministry support of schools
The Ministry sees itself as the “steward” of the education sector. Stewardship is about; focusing on the long term health and performance of the education system, and providing support to enable the sector to raise achievement.7 The Ministry receives funding (through appropriations) to support schools. However, the Ministry’s performance measures do not report on how well it is doing this. Because each school is an autonomous Crown Entity, the Ministry’s view is that it cannot tell a school what to do. However, it does have a role in supporting and guiding schools.
The Ministry own the school buildings used by non-integrated state schools and has overall responsibility for their management. The Ministry also pays all teaching staff. However, the Ministry devolves certain responsibilities to Boards, which have a role in managing both the payroll and property needs of their school. Boards decide on staffing levels, employ staff, have responsibilities for keeping their school buildings in good repair, and manage some property projects.
Because of the devolved system, the Ministry needs to be able to effectively monitor whether schools are using the funding they provide appropriately. We found from our audit of school payroll and our report on school property that in some areas this was not the case. For example, the Ministry does not review whether a school uses its property maintenance funding to maintain the Ministry’s buildings.8 Our annual audit of school payroll also identified some areas where there is a lack of Ministry monitoring.
The Ministry has a number of options available to it, to provide a Board with support if they consider it is at risk of poor performance, including several statutory interventions. In our 2008 report on how well the Ministry monitors and supports Boards we found there was no clear process to follow for deciding what support was best.9 We also found that there was no guidance on how quickly a statutory intervention should be put in place and the timeframes could be lengthy. We have not done a formal follow up of our report so do not know if there has been an improvement in this area.
A finding of our review of school property in 2017 was that the Ministry has not used the interventions available to it to resolve property matters.10 We recommended that the Ministry establish interventions in schools that are not maintaining their property to the required standards.11 The recent update to the Education Act 1989 has given the Ministry more interventions that it can use at an earlier stage. These include; the requirement to provide information, a case conference, a specialist audit, and a performance notice. The Ministry have told us that these have not yet been widely used.
School finances
We raised a concern in our letter to the Secretary of Education on the results of the 2015 audits, about the Ministry’s capability and capacity to provide support to schools on financial matters. Since then the Ministry has increased its number of Financial Advisors that work within the Ministry’s regional offices from 4 to 7, with additional support centrally. The Ministry has also started taking a more proactive approach to helping schools to improve their finances. However, the number of Financial Advisors is still small, for more than 2,400 schools. While the Ministry provides a lot of guidance on its website, and has been updating this guidance recently, it is not always easy to find what you are looking for.
Property matters
Our school property report noted that there was a lack of clarity about the roles and responsibilities of Boards and the Ministry relating to property.12 We found from talking to schools that many did not feel well supported by the Ministry. Schools also told us that while the Ministry does have tools and guidance available these are not always easy to find or use.13
We recommended that the Ministry review its support of schools and recognise that one size does not fit all, and increase the capability and capacity of its school property advisors to improve frontline services to schools.14 This links to the different skills and abilities of school boards. We understand the Minister of Education has also asked for a review of school property.
Competition vs collaboration
We have seen that funding schools based on the size of the school roll can drive competitive behaviour. If schools are competing for students this can be a barrier to collaboration. An example of this is a school buying a bus and transporting pupils from surrounding areas at the expense of the school, to increase the school’s roll. In the past we have seen this lead to the school getting into financial difficulties because the school is funding the running costs of the bus out of its operational funding. We also have concerns about whether this is a suitable use of the funds provided to the school for educational purposes.
Pupils moving to a “popular” school can cause overcrowding in one school and surplus classrooms in another. We reported on the use of school classrooms in our school property report, as at 31 July 2016 there were 4,760 surplus classrooms and 460 deficit classrooms.15
The current Communities of Learning initiative has allowed schools to collaborate to reach an educational goal. However, schools could also consider sharing assets such as pools and gyms, administration staff and specialised teachers.
Better collaboration may also eventually result in better quality Boards. Some schools do have combined Boards and the recent update to the Education Act 1989 has made it easier for more than two Boards to combine. It would be important to preserve the input of parents from all schools, but a combined Board for several schools may be able to draw on greater skill sets and employ specialist advisors.
Fraud
There have been several high profile frauds in schools in the last few years, some of them for large amounts of money. We have no evidence of there being more fraud in schools than other sectors. However, in most small schools and even some larger schools, there is often a lack of proper controls over cash receipts and to a lesser extent payments. This is usually because there are few office staff to allow for proper segregation of duties, which is an important control against fraud.
In small schools it may not be possible to improve controls by introducing some segregation of duties, as it is not affordable or practical for these schools to employ more staff. In these cases oversight by the Board of both income and payments becomes more important. Unfortunately, these schools are often those that have struggled to get Board members with the necessary skills. This links back to the need for better training and support for boards.
Studies have found that in preventing fraud, the tone at the top is crucial. One of the best tools to prevent fraud is staff awareness. An awareness of fraud means staff will be more alert to fraud risks and will also know what to do if they suspect fraud. We collect information about frauds or suspected frauds from our auditors. This has told us that there are sometimes barriers to Board’s reporting fraud, or suspected fraud, to law enforcement. Often the amounts our auditors advise us of are small, and if the employee pays the money back the school will take no further action. Also, where amounts are small the Board may consider that the cost of an investigation would not be worthwhile. This may result in some fraudulent activity going un-detected.
Through our audits we have seen instances where a Board has dismissed an employee because of fraud or theft, but has not told the authorities. In many cases the employee has paid back the money taken. However, that employee has then moved on to another school, with the risk that they may repeat the wrongdoing.
State-integrated schools
The proprietor of a state-integrated school can appoint representatives to the Board, and because the proprietor maintains the special character of the school, there will always be a close relationship between the proprietor and Board. In most instances the relationship between Board and Proprietor is handled with proper regard to public accountability. However in some schools the relationship between the school and the proprietor is blurred. This can lead to risks of poor accountability, improper use of public money and conflicts of interest. The proprietor is a private entity and the board a public entity, responsible for spending public money.
We raised concerns in our 2011 Education Sector report, about the accountability arrangements for parent donations in integrated schools.16 It may be difficult for parents to satisfy themselves about the use to which their fees and donations have been put. A school needs to make clear to parents who it is raising funds for and what it intends to use those funds for. Any funds raised by the Board is public money and must be used appropriately. As part of our audit we consider whether all funds raised by the school are recognised in the correct financial statements. This can be difficult because a Proprietor is a private entity, and the Auditor-General is not its auditor.
Kura Kaupapa Māori (kura)
As with all state schools, many kura are managed well, but some are not. We reported on a special exercise that we carried out on kura in our 2011 Education Sector report. This identified that 20% of kura did not have financial policies and practices that reflect good practice.17 The Ministry told us that they would be providing more targeted guidance on financial matters to kura, but to date little has been done. Although we are aware of a project of tailored training and support for kura, that the Ministry have been piloting in Northland. Because we were waiting for the Ministry to publish its guidance we have not done a formal follow up of this exercise. However, we continue to raise concerns about the financial management and appropriateness of spending in some kura in our annual audits.18 As a result of this, we consider that on average kura represent higher audit risk than other state schools.
Eleven of the 73 kura have multiple audits in arrears. One kura has five years of audits in arrears. This means the kura have not sent their audited financial statements to the Ministry, resulting in a lack of accountability for those kura for the past few years. Our auditors are working with the kura to complete these audits, but the usefulness of information and impact of accountability lessens over time.
Small rural schools
Because of the geography of New Zealand there are many small rural schools, about a quarter of schools have fewer than 100 students. Just under 100 schools have 20 students or less. These schools have different issues to other schools.
All schools have fixed costs, their audit fee is an example of this. A small rural school will usually need less audit work than a large secondary school, but there are certain audit procedures that auditors need to do for all audits, irrespective of their size. Because school funding is based on the size of the school roll, a small school’s audit fee could be between 5-8% of its operational grant, but for a large secondary school it could be less than 0.5% of its operational grant. For these schools, even a small fall in roll can have serious consequences because the school still needs to cover its fixed costs. This can limit the school’s ability to spend funds on resources to benefit the students.
Small rural schools may find it difficult to recruit and keep staff. These schools are also often seen as a stepping stone for new Principals. However, a Principal of a small rural school, who is often a teaching principal, usually has more responsibilities than a Principal of a bigger school. This is because there is no one else to delegate some of those responsibilities to. Many of these new principals may also lack experience in some areas, such as finance, employment matters and property, and as noted before there is little formal training to help them.
One of the findings of our school property report was that current funding structures for property suit large modern schools better.19 This is because the funding provided to schools for upgrading their buildings and annual maintenance is determined by the number of students, the size of the school buildings, and land occupied by the school, rather than the nature and condition of the buildings. This puts an extra burden on the small rural school that may also struggle to get the necessary services because of a lack of suppliers in the area.
Reporting framework
Since the 2015 financial year, a new accounting framework developed by the External Reporting Board has been applicable to schools. This framework brought in a tiered structure which meant that entities would report differently based on size and whether they were for-profit, public sector or not-for profit entities, such as charities. This new framework has simplified financial reporting for smaller entities.
Since the 2015 financial year, the Ministry decided that all schools should report using a common format, its Kiwi Park model financial statements. This was to ensure consistency of school financial reporting. However, in doing this, the Ministry has elected that all schools must report at tier 2 in the new accounting framework, unless they are large and need to report at tier 1. This has meant that smaller schools cannot take advantage of simplified reporting. We estimate that there are about 1,200 schools that would be able to take advantage of this simplified reporting, because they meet the requirements of reporting in tier 3.
The accountability framework would need to reflect any change to governance structures that resulted from the review of the Tomorrow’s Schools model. There should be opportunities for making reporting more understandable, valued and more accessible. This could include reporting on educational outcomes, as well as financial performance. We are aware that the recent update to the Education Act 1989 will allow better planning and reporting for schools. This is an opportunity to ensure better consistency of reporting between schools.
We have done some research on the accountability frameworks of schools in other countries. Appendix 1 sets out examples of financial reporting and governance approaches in other countries.
Procurement
Schools purchase items every day, including entering into contracts for items such as IT equipment and painting of the school buildings. Our annual audits have raised concerns about whether schools are getting value for money from some contracts, such as some printer and IT leases.20 We have seen instances where principals have entered into significant contracts without the approval of the Board. We also see schools struggling with how to provide IT equipment for their students, because there is more demand for on-line learning.21
Schools working together to negotiate contracts would have better purchasing power. Boards without the necessary skills to fully understand the contracts that they are asked to sign would be able to leverage off Boards that had those skills. We were told that the Ministry carried out a pilot project on a maintenance contract for all the schools in one area.22 The feedback on the service and time saved by the schools was positive. However, there were costs implications of using such a service.
Another example of where some coordination could save time and money for schools is where Boards have a matter on which they need legal advice. Boards do have the benefit of being able to consult with the New Zealand School Trustees Association, but we often find that several schools are consulting on the same matter. If greater collaboration saves the Boards’ and Principals’ time as well as money, this gives them more resources and time to focus on the educational achievement of their students.
Appendix 1: Financial reporting and governance approaches in other countries
Country |
Statement Preparation |
Compliance with Accounting Standards |
Audited |
Governance |
|---|---|---|---|---|
| UK | Each school prepares a financial statement every year, which is submitted to Local authorities who then forward it to the State Secretary.23 Publicly available on a benchmarking website.24 |
In accordance with Consistent Financial Reporting (England) Regulations 2012 and Accounting Practices of the Local Authority.25 Not necessarily GAAP compliant. | Not required26 | Each school has a Governing Body which consists of several Governors who manage both the finances and activities of the school. In accordance with the School Governance Regulations 201227 |
| Canada – Toronto (Ontario) | Annual statements are prepared at a district level. | GAAP compliance by following Public Sector Accounting Board Recommendation.28 | Externally audited annually.29 | School governance is at a District level. District School Board has to report to the Ministry of education for the province (Ontario). The locally elected board has a role in both strategic and financial decision making.30 |
| Australia - Victoria | Each school prepares a financial statement every year as part of an annual report.31 | Australian Accounting Standards which is GAAP compliant. | Audited at least once every four years.32 | Each school has a School Council which is accountable to the Minister of Education. It seems that they have a role in strategic and financial decision making.33 |
1: New Zealand Schools: Ngā Kura o Aotearoa (2016), page 22.
2:New Zealand Schools: Ngā Kura o Aotearoa (2016), page 21.
3:New Zealand Schools: Ngā Kura o Aotearoa (2016), page 21.
4:New Zealand Schools: Ngā Kura o Aotearoa (2016), page 24.
5:Managing the School Property Portfolio, paragraph 5.25.
6:Managing the School Property Portfolio, paragraph 5.17.
7:Ministry of Education Four Year-Plan, 2016-2020, page 2.
8:Managing the School Property Portfolio, paragraph 4.49.
9:Ministry of Education: Monitoring and Supporting School Boards of Trustees, section 4.
10:Managing the School Property Portfolio, paragraph 4.56.
11:Managing the School Property Portfolio, recommendations 5.
12:Managing the School Property Portfolio, paragraph 5.6.
13:Managing the School Property Portfolio, paragraph 5.20.
14:Managing the School Property Portfolio, recommendations 6, 7 and 8.
15:Managing the School Property Portfolio, paragraph 4.38.
16:Education Sector: Results of the 2011 Audits, paragraph 5.44.
17:Education Sector: Results of the 2011 Audits, paragraph 5.53.
18:Results of the 2016 audits, paragraph 3.28.
19:Managing the School Property Portfolio, paragraph 4.44.
20:Results of the 2016 audits, paragraph 3.44.
21:Results of the 2016 audits, paragraph 3.47.
22:Managing the School Property Portfolio, paragraph 5.38.
23:https://www.gov.uk/guidance/consistent-financial-reporting-framework-cfr
24:https://schools-financial-benchmarking.service.gov.uk/
25:https://www.gov.uk/guidance/consistent-financial-reporting-framework-cfr
26:https://www.nationalcollege.org.uk/cm-mc-les-resource-financial-reporting.pdf page 1
28:http://www.edu.gov.on.ca/eng/general/elemsec/psab/reporting.html
29:http://www.tdsb.on.ca/About-Us/Business-Services/Budgets-and-Financial-Statements
31:http://www.education.vic.gov.au/Documents/school/principals/finance/FinanceManualSchool.pdf
32:www.dtf.vic.gov.au/financial-management-government/financial-reporting-policy