4 OPERATIONAL
ASSURANCE UNIT
31. We consider it important for the strength
of the control environment that, in addition to the assurance
work of internal audit, internal checks are made as to whether
allowances justifiably claimed have in fact been used for proper
Parliamentary purposes, and have not "leaked" out into
non-Parliamentary use. Checks would in most cases be prompted
by a review of documentation supplied, evaluation of trends, or
examination of the use to which allowances had been put, for example
scrutiny of Members' websites. This might lead to a discussion
with the Member concerned. Such checks should increase the level
of assurance that can be provided to auditors and the Accounting
Officer about how management is ensuring proper use of public
funds, and how internal controls are operating. We consider that
the best way for such checks to be undertaken would be through
the establishment of an Operational Assurance Unit. The Unit's
role would be to give advice to Members and to ensure compliance
with rules and the maintenance of standards. It might also have
a key role on day-to-day decision making on complex or novel expenses
claims if the MEC decides to adopt a Green Book which is more
principles-oriented than rules-based. It should be stressed that
it would not be the role of this unit to tell Members how to do
their job or how to manage their offices.
32. The Operational Assurance Unit could either
form a part of the Department of Resources, or be located outside
the Department of Resources but within the House, or be an external
unit. The NAO would not normally undertake assurance work. We
consider it unlikely that another external unit would constitute
value for money in proportion to the risk. We conclude that a
unit within the House is the answer and we think it would be best
sited within the Department of Resources.
33. In creating the Operational Assurance Unit,
the Department of Resources would need to build on the experience
of the current Enquiry and Advice, and Quality and Assurance teams
within the Department, but the objectives of the new unit and
its approach should be developed afresh in the light of the new
regime's requirements. It is likely that there would be additional
costs involved for the Department of establishing such a unit
but we consider that the relatively modest costs involved would
be worthwhile given the increased level of assurance which could
be achieved.
34. The Leader's Paper stated:
In order to achieve the desired outcome, rigorous
enforcement of the rules is needed by the Department of Resources.
Robust management controls and process are one of the main requirements
for assurance. In order to carry out this role effectively, the
way in which the Department of Resources carries out its work
should be reviewed.[17]
We agree. However, in checking on MPs' allowances
the Operational Assurance Unit should act proportionately. For
example, we would not expect it normally to investigate a claim
to the extent of questioning the purpose of journeys made by a
Member with an Edinburgh constituency between Westminster and
Edinburgh. The principal reason for travel would be assumed, unless
otherwise shown, to be in connection with the Member's work as
such, even if there were other residual benefits.
35. WE RECOMMEND
THAT THE
DEPARTMENT OF
RESOURCES SHOULD
CONCENTRATE A
SMALL GROUP
OF MORE
SENIOR AND
EXPERIENCED STAFF
IN AN
OPERATIONAL ASSURANCE
UNIT, COMPOSED
AND MANAGED
SEPARATELY FROM
THE SECTION
ADMINISTERING PAYMENTS
THEMSELVES. THE
UNIT'S
ROLE WOULD
BE TO
GIVE ADVICE
TO MEMBERS
AND TO
ENSURE COMPLIANCE
WITH RULES
AND THE
MAINTENANCE OF
STANDARDS.
17 Office of the Leader of the House of Commons, Audit
and Assurance of MPs' Allowances, August 2008, Cm 7460, paragraph
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