Annual Report of Findings 2022

07 February 2023

jerseyauditoffice.je  

R.22/2023

Contents

2022 Reports and Publications Issued 3 Tracking of C&AG Recommendations 7 Appendix One – Summary of Reports and Thinkpiece issued during 2022 12

2022 Reports and Publications Issued

1. I have issued ten reports, one Good Practice Guide and one Thinkpiece during 2022 as shown in Exhibit 1.

Exhibit 1: Reports, Good Practice Guide and Thinkpiece issued in 2022

Quarter Three

States Employment Board - Follow Up

Quarter One

Child and Long-Term Care  Adolescent Mental Fund Health Services

Quarter Two Quarter Four

Governance of the  Risk Management  -

States of Jersey  Follow Up Police - Follow Up

Annual Reporting

Cyber Security

Arrangements Annual Reporting Good Practice

Governance and  Guide Decision Making

during the COVID- Grants to Arts, 19 Pandemic Heritage and

Culture COVID-19 Test and  Organisations

Trace and

Vaccination  Thinkpiece on Programmes Governance and

Accountability of Independent

Bodies and Office Holders

2. Appendix One of this report contains a summary of each of the reports and the Thinkpiece I have issued during 2022.
3. In total, I have made 156 recommendations, noted 12 areas where I concluded that work planned by the States should be prioritised and identified 34 areas for consideration by the States. Exhibit 2 provides a summary.

Exhibit 2: Summary of recommendations, work planned that should be prioritised and areas for consideration

Long-Term Care Fund

Governance of the States of Jersey Police - Follow

Up

Cyber Security Arrangements

Governance and Decision Making during the

COVID-19 Pandemic

COVID-19 Test and Trace and Vaccination

Programmes

States Employment Board - Follow Up Child and Adolescent Mental Health Services

Risk Management - Follow Up Annual Reporting

Grants to Arts, Heritage and Culture Organisations

Governance and Accountability of Independent

Bodies and Office Holders Thinkpiece

0 5 10 15 20 25 30 35

Recommendations Work planned that should be prioritised Areas for consideration

4. At the time of writing this report, formal Executive Responses have been submitted to the Public Accounts Committee for the nine reports I issued before the end of November 2022, in accordance with the agreed protocol timescales. 147 of the 149 recommendations made in these reports were accepted or partially accepted for action. Exhibit 3 shows the allocation by Government of responsibilities for action in respect of these 147 recommendations across departments.

Exhibit 3: Allocation of implementation of 2022 accepted and partially accepted recommendations

40 35 30 25 20 15

10 5 0

CLS Police JHA HCS Non-Mins CYPES COO SPPP OCE T&E

Authority

Annual Reporting

Risk Management - Follow Up

Child and Adolescent Mental Health Services

States Employment Board - Follow Up

COVID-19 Test and Trace and Vaccination Programmes Governance and Decision Making during the COVID-19 Pandemic Cyber Security Arrangements

Governance of the States of Jersey Police - Follow Up

Long-Term Care Fund

5. I have analysed all of the 156 recommendations I have made in 2022 across the following four themes:

• governance and accountability

• value for money (economy, efficiency and effectiveness)

• financial management; and

• internal control.

6. As shown in Exhibit 4, most of the recommendations made in 2022 relate to opportunities to improve value for money.

Exhibit 4: Analysis of the themes of recommendation made in 2022

Governance and accountability Value for money Financial management Internal control

7. A breakdown of the themes of the recommendations in each report is shown in Exhibit 5.

Exhibit 5: Themes of recommendations in each report issued in 2022

Long-Term Care Fund Governance of States of Jersey Police - Follow Up

Cyber Security Arrangements

Governance and Decision Making during the

COVID-19 Pandemic

COVID-19 Test and Trace and Vaccination

Programmes

States Employment Board - Follow Up Child and Adolescent Mental Health Services Risk Management - Follow Up

Annual Reporting Grants to Arts, Heritage and Culture Organisations

0 5 10 15 20 25 30 35

Governance and accountability Value for money Financial management Internal control

Tracking of C&AG Recommendations

8. The nature of the actions required to implement accepted C&AG recommendations vary. In some instances implementation may require legislative change while in other instances implementation may require policy or process change. The length of time required to implement accepted recommendations may therefore vary dependent on the actions required.
9. The Government records open' C&AG recommendations (accepted recommendations that are in the process of being implemented) on a Tracker. At the beginning of 2022 the Tracker recorded that 225 C&AG accepted recommendations were in the process of being implemented. By the end of 2022, this had decreased to 199. The overall movement in the number of open' recommendations during 2022 included:

• 169 recommendations added the Tracker:

• 22 recommendations from reports I issued in 2021; and
• 147 recommendations from nine out of the ten reports I issued in 2022; and

• 195 recommendations removed from the Tracker as having been implemented or otherwise addressed. This is made up of:

• 122 recommendations that were recorded as open' at the beginning of the year; and
• 73 new and accepted recommendations that had been added from the first nine of my 2022 reports.

10. Exhibit 6 contains more details.

Exhibit 6: Movement in C&AG open' recommendations during 2022

Source: Jersey Audit Office analysis of Government of Jersey C&AG Recommendations Tracker data

11. The Government is currently compiling its responses to the Grants to Arts, Heritage and Culture Organisations Report and the Thinkpiece issued in December 2022. When these responses are issued further recommendations may be added to the Tracker alongside a number of areas of work planned that should be prioritised and areas for consideration.
12. At the beginning of 2022, Government departments had a target to implement 80% of Public Accounts Committee, Scrutiny and C&AG recommendations that were open at that time, by the end of 2022. For C&AG recommendations, 54% of recommendations open at the beginning of 2022 had been addressed by the end of 2022.
13. I have carried out an analysis of the open recommendations reported on the Government C&AG Recommendations Tracker at the end of 2022. Exhibit 7 shows an analysis of the age of the open recommendations and the reports that they relate to.

Exhibit 7: Analysis of open recommendations by age and report

Child and Adolescent Mental Health (2022) Risk management (2022)

Annual reporting (2022) States Employment Board (2022)

COVID Test and trace and vaccination (2022) COVID Governance and decision making (2022)

SOJ Police (2022) Long-Term Care Fund (2022)

Tracking C&AG Recommendations (2021) COVID Other schemes (2021)

COVID Co-Funded Payroll Scheme (2021) Health and Social Care (2021)

COVID Public Finances (2021) States Employment Board (2021)

COVID Procurement (2021) COVID Healthcare Response (2021) Anti-Corruption Arrangements (2021) Management Information in Education (2020) States of Jersey Development Company (2020)

Insurance (2020) Enforcement Powers (2020) Non-Ministerial Departments (2019) Remuneration of Board Members (2019)

Financial Management and Internal Control (2019)

States Employment Board (2019) Housing Repairs and Maintenance (2019) The States as Shareholder (2019) Operational Land and Buildings (2018) Grants and Subsidies (2017)

Arm's Length Organisations (2017) Private Patient Income (2017)

Use of Consultants (2016) eGovernment (2016)

Compromise Agreements (2016) Freedom of Information (2016) Community and Social Services (2015) Private Patient Income (2015)

Pension Schemes (2014) Procurement (2014)

0 5 10 15 20 25 Source: Jersey Audit Office analysis of Government of Jersey C&AG Recommendations Tracker

14. In summary, there remain some recommendations dating back as far as 2014 that have been accepted by the Government for action but have not yet been implemented. The Government has set revised targets for most of its open recommendations, including all those dating from 2018 and earlier. Based on

these revised dates, as at 1 January 2023, 44% of recommendations were overdue and a further 29% due within three months. Exhibit 8 contains more details.

Exhibit 8: Analysis of open recommendations by due date at 1 January 2023  

Not due within 12 months Due within 9 to 12 months

Due within 6 to 9 months Due within 3 to 6 months Due within 3 months

Fewer than 3 months overdue Between 3 and 6 months overdue Between 6 and 9 months overdue

Between 9 and 12 months overdue

More than 12 months overdue

0 10 20 30 40 50 60 70 Source: Government of Jersey analysis of C&AG Recommendations Tracker

15. I have analysed the themes associated with the recommendations that have not yet been implemented fully by Government. Exhibit 9 contains more details.

Exhibit 9: Analysis of the themes of open' recommendations

Internal control Value for money

Financial management Governance and accountability

Source: Jersey Audit Office analysis of Government of Jersey C&AG Recommendations Tracker data

16. In my Report Tracking Comptroller and Auditor General Recommendations (November 2021) I noted that there were 259 recommendations on the C&AG Recommendations Tracker at 27 October 2021 of which 74 were overdue for implementation, or very near to being overdue when compared to their latest revised target dates for implementation. While progress has been made in implementing recommendations during 2022, the number of recommendations overdue for implementation has risen to 87 at 1 January 2023.
17. C&AG recommendations are made to improve governance and accountability, value for money, financial management and internal control. Recommendations that remain open represent opportunities for improvement that are not being realised. It is therefore disappointing to see an increasing trend in recommendations that are overdue for action against the timescales for implementation set by Government.

Appendix One

Summary of Reports and Thinkpiece issued during 2022

Long-Term Care Fund 28 February 2022

R3  Ensure that the actuarial review based on 31 December 2021 data is

commissioned as soon as possible for reporting in 2022 and to inform the Government Plans from 2023.

R4 Review the LTCF investment strategy in light of experience since the last formal

actuarial review, to assess whether the current strategy is the most appropriate.

R5 Carry out detailed analysis of the LTCF contributions collected by Revenue

Jersey and use this to inform or validate future revenue forecasts for the Government Plan.

R6 Re-evaluate the basis for the grant contribution from the States to the LTCF.

R7 Carry out a full review of the management charge to the LTCF and ensure that

the charge is an accurate representation of the costs of managing the fund.

R8  Complete the proposed review of the asset disregard level included in the LTCS

during 2022, to  

• consider whether a revised level is more appropriate to meet the objectives of the scheme; and

• provide a basis for future reviews.

R9  Undertake a formal analysis of care costs to inform the 2022 review of the

following variables within the LTCS:

• standard care cost at each level

• standard co-payment

• standard personal allowance; and

• standard care cost cap – single and couple.

R10  Review and update the LTCS guidance following feedback from the community

as part of the planned engagement initiatives.

R11  Complete the planned systems updates to provide a direct data link for the

LTCS between HCS and CLS systems.

R12  Update the standard hourly rate figures for domiciliary care in the Resource

Allocation System and ensure that these are reviewed and revised annually.

R13  Publish the re-determination and appeals process for both care needs and

financial assessments on the website and in future guidance.

R14  Undertake a review of all performance measures for the LTCS to:

Long-Term Care Fund 28 February 2022

• establish a more comprehensive suite of performance measures to reflect the customer journey, including metrics to monitor the balance between residential and domiciliary care provision

• ensure data and other information for all performance measures are reported and monitored on a regular basis; and

• ensure underlying reasons for performance variances are investigated and improvement plans are agreed to address risks and issues arising.

R15  Review and update existing framework agreements with all care providers.

Ensure that the update includes a clear articulation of the data and quality standards required from care providers.

R16  Prepare a detailed plan to implement a range of initiatives to reduce demand on

the LTCF in future This plan could form part of the Jersey Care Model implementation and should include shifting the emphasis of care provision to prevention and domiciliary care.

R17  Review the potential to streamline the claims process, for example, through:

• providing an online self-assessment tool

• providing a standard template for claimants to notify a change of circumstances; and

• simplifying the property loan process and guidance.

R18  Introduce a performance measure to monitor the timeliness of annual reviews of

individual claims.

R19  Resolve the issues in the interface between the CRM system and NESSIE as soon

as possible to avoid requirement for duplicate data entry. In doing so, review the allocations of payments to LTC Benefit and LTC Support in both systems to eliminate adjusting entries.

R20  Review the potential to move to a single, consistent approach to making

payments due from the LTCS.

Summary of Government Response

Government accepted 19 of the 20 recommendations (R20 was not accepted). Actions were allocated across departments as follows:

Customer and Local Services (CLS) – 10 Treasury and Exchequer (T&E) – 3

Governance of the States of Jersey Police – Follow Up 27 April 2022

Background and Scope

In 2018 the C&AG undertook a review of the effectiveness of the design and operation of the governance arrangements for the States of Jersey Police. This report followed up the implementation of the 2018 C&AG recommendations.

Key Findings

• The amended Law was adopted in May 2021 and has put in place a number of revisions designed to secure changes in the roles and responsibilities of all parties involved in the governance of the States of Jersey Police.

• Whilst the amended Law has given the enabling powers, some requirements are yet to be implemented and significant change in some roles is still required.

• Ten of the 14 recommendations made in the 2018 C&AG report have been fully or partially implemented. Further work is required to implement the eight recommendations that are either not yet implemented or are only partially implemented.

• The enhanced role of the Police Authority, to monitor and oversee the States of Jersey Police and to promote and support continuous improvement, is in its early stages. A business case to request resources for the enhanced role of the Police Authority has recently been agreed in part, with some additional capacity for staff and training and funding for an inspection.

• Whilst the Police Authority is working well with the States of Jersey Police, the capacity and expertise to develop plans, set targets, analyse budgets and hold the States of Jersey Police to account have not been available. The Police Authority has been heavily reliant on one person to undertake all the administrative and business functions required by the recommendations and the legislation, which is not a sustainable option going forward. Further thought needs to be given to what arrangements are necessary to ensure the Police Authority has the appropriate expertise to enable it to fulfil its role more effectively.

• Operational control of the States of Jersey Police has been re-defined to be further removed from Government control and decision making. Article 7 of the amended Law changed Ministerial powers and requires the Minister for Home Affairs to consult with others in determining ranks of the Force and the appointment of the Deputy Chief Police Officer. A Tripartite Protocol has been developed by the Chief Police Officer which further clarifies the position.

• The Police Terms and Conditions of service have not been reviewed since the 2018 C&AG report, but this work is planned for 2022.

• The amended Law requires the Minister for Home Affairs to set policies in relation to the key aims and objectives of the States of Jersey Police. The amended Law also requires the Police Authority to prepare both an Annual Policing Plan and a Four -

Governance of the States of Jersey Police – Follow Up 27 April 2022

Year Policing Plan which considers the key aims and objectives set by the Minister, the efficiency and effectiveness of the States of Jersey Police and the resources available to the States of Jersey Police. The Police Authority does not currently set out performance objectives for the States of Jersey Police. Neither is there any evidence of high-level targets set by the Minister for Home Affairs for the States of Jersey Police. Whilst a Four-Year Policing Plan was developed for 2020-23, it has not been updated on a rolling basis and is now out of date. Further work is also required to develop a more detailed Annual Policing Plan. Annual Policing Plans have not been developed in detail since the 2020-23 Four-Year Policing Plan and have not been laid before the States Assembly as required by the Law.

• At the time of my review an Annual Report on the States of Jersey Police had not been produced since 2018 despite there being a statutory requirement for one to be produced within three months of the end of each financial year. An Annual Report covering two years (2019 and 2020) was published on 28 March 2022, significantly after the statutory deadline. An Annual Report for 2021 has not yet been published.

• Improvements have been made in the visibility of police budgets and monitoring of expenditure by Treasury and Exchequer both in the Government Plans and in reports for the States of Jersey Police.  However, further work needs to be undertaken to provide support to the Police Authority so that it can discharge its functions more effectively in respect of police budgets and expenditure.

• The States of Jersey Police has a well developed framework for performance monitoring and has recently given permission for Police Authority officers to access all the data. However, there is currently no clarity on Ministerial objectives and no clear line of sight to objectives and subsequent performance. While the States of Jersey Police is monitoring performance, the Police Authority has yet to develop targets and performance measures for oversight and to enable it to perform the role of promoting and supporting continuous improvement in a meaningful way.

• The Police Authority is responsible for arranging an independent inspection of the States of Jersey Police at least once every four years. Budget for an inspection has been approved for 2023 but it is not clear when this will be planned, who will undertake it and how any inspection regime is decided.

• Meetings take place regularly between the States of Jersey Police, the Police Authority and the Justice and Home Affairs Department (JHA). The Police Authority also meets quarterly. However, the agendas and papers are quite informal for these meetings and minutes, decisions and action logs are not consistently documented. As a consequence, it is difficult to assess whether these meetings are effective in delivering the objectives expected. Data security and business continuity arrangements are yet to be established. This leaves the Police Authority open to a significant degree of risk.

Governance of the States of Jersey Police – Follow Up 27 April 2022

Conclusions

Overall, progress has been made in addressing many of the recommendations set out in the C&AG report of 2018. The legislative changes in the States of Jersey Police Force (Amendment No. 3) Law 2021 have strengthened the independent operation of the States of Jersey Police from the Government.

At this stage however, the Police Authority has not had sufficient resources to undertake the role envisaged in the recommendations of the C&AG report of 2018. The Police Authority is not yet adequately resourced and supported in a way that enables it to undertake its functions. There should be a further assessment in due course as to whether the planned additional resources will enable the Police Authority to undertake all its functions effectively.

Summary of Recommendations

Government of Jersey

R1  Notify the Police Authority formally of its budget for 2022 and beyond.

R2  Review the level of Finance, HR and ICT support provided to the Police Authority

so that the Police Authority can function efficiently and effectively.

R3  Ensure the approved Annual Policing Plan is submitted to the States Assembly

as required by the Law.

R4  Undertake a formal review to evaluate whether the role of the Police Authority

could be extended to cover other services where operational independence is important.

R15  Ensure that internal operating procedures clearly document the respective roles

of different parties for police human resources issues.

R16  Ensure that the planned review of the Police Terms and Conditions of Service is

undertaken in 2022.

R17  Ensure that reports accompanying all Ministerial Decisions include details of the

advantages and disadvantages of different options considered in making the decision.

R18  Introduce mechanisms for a stronger dialogue between Treasury and

Exchequer, JHA and the Jersey Police Authority about resourcing requirements for the States of Jersey Police.

Police Authority

R5  Undertake a full assessment of training requirements and develop and

implement an appropriate training plan.

Governance of the States of Jersey Police – Follow Up 27 April 2022

R6  Undertake a review at the end of 2022 to establish whether the Police Authority

has been able to undertake the duties conferred on it by the legislative changes within the resources allocated.

R7  Ensure the Four-Year Policing Plan is brought up to date and approved and is

updated and approved on an annual rolling basis.

R8  Produce a detailed Annual Policing Plan for approval by the Minister for Home

Affairs.

R9  Establish, based on the aims of the Four-Year Policing Plan and Annual Policing

Plan:

• a performance baseline for the States of Jersey Police

• objectives and targets to meet strategic and operational aims; and

• arrangements to monitor performance and take action where targets are not achieve.

R10  Develop and publish Annual Reports for the States of Jersey Police in

accordance with statutory requirements.

R11  Document a clear plan for the proposed 2023 and future independent

inspections of the States of Jersey Police setting out when these will be undertaken, and by who.

R12  Consider formally whether the time commitment envisaged for independent

Police Authority members is realistic, and whether the current expectation in respect of time commitment and remuneration will continue to attract members with the right skills.

R13  Formalise the structure and documentation of Police Authority meetings to

include:  

• formal agendas

• papers posted in advance of the meeting

• records of all decisions taken at the meetings

• secure storage of records and minutes including appropriate back up facilities; and

• making minutes or summaries of meetings available in a transparent way.

R19  Formally determine in preparing the Annual Policing Plan whether the resources

attributed to States of Jersey Police are sufficient.

Cyber Security Arrangements 6 May 2022

R6  Formally document all deferrals and changes to project deliverables.

R7  Formally document at a programme level where deferrals and descoping have

been referred to Ministerial level.

R8  Make best use of scarce internal staff resources in future technology

programmes through:

• confirming availability during the planning phase; and

• engaging with other programme leads to identify activities in common.

R9  In planning future technology programmes, assess the risks and opportunities

associated with simultaneous delivery of multiple programmes.

R10  Deliver structured training to risk owners to develop their understanding of and

confidence in their role.

R11  Develop formal mechanisms for co-ordination between programmes regarding

the prioritisation and co-ordination of tasks.

R12  Designate internal owners for each workstream in major programmes.

R13  Identify individuals to deputise as alternates at key programme meetings when

designated individuals are not available.

R14  In Outline Business Cases document linkages to wider organisational strategies

and initiatives.

R15  Ensure that all workstream planning activities in major programmes are fully

documented.

R16  Routinely hold workshops with programme stakeholders to identify and

prioritise requirements for major programmes.

R17  Develop and roll out appropriate induction training for external project

managers.

R18  Introduce structured briefings for stakeholders at the commencement of their

involvement in a programme so that they have a clear understanding of their role.

R19  For major programmes, routinely evaluate benefits realised and delivery of

Outline Business Case tasks at programme level.

Governance and Decision Making during the COVID-19 Pandemic 6 May 2022

Background and Scope

The rapidly evolving nature of the COVID-19 pandemic has called for an extraordinary response from Government as it has sought to save lives and protect health and livelihoods in Jersey. The principles of good governance, transparency, value for money, effective internal control and accountability for the use of public funds however remain during a time of emergency. Whilst public financial management systems need to be responsive and flexible, it is essential that they continue to ensure value for money and minimise the risk of fraud and corruption.

The Government of Jersey established new groups at both political and officer level to support decision making without detracting from the constitutional roles of Ministers and Accountable Officers. Those groups had to operate at pace but at the same time demonstrate effective decision making.

Key Findings

• Despite the circumstances of the COVID-19 pandemic, a State of Emergency under the Emergency Powers and Planning (Jersey) Law 1990 was not declared. At the commencement of the COVID-19 pandemic, the Government of Jersey recognised that the legislation did not provide the best route forward for managing the pandemic. Indeed, plans for replacement legislation were already under consideration.

• The need for legislation to deal with the specific circumstances of the COVID-19 pandemic was recognised. The COVID-19 Enabling Provisions (Jersey) Law 2020 (the 2020 Law) was adopted by the States Assembly on 27 March 2020, empowering the States Assembly by Regulation to make provisions necessary or expedient as a direct or indirect result of the COVID-19 outbreak in Jersey or its aftermath.

• In addition to the existing Council of Ministers and Emergencies Council that were already established on a statutory basis, a non-statutory Competent Authorities Ministers Group was established to allow consultation between Ministers before decisions were made.

• Officer groups at Strategic, Tactical and Operational level were swiftly established at the outset of the pandemic.

• There are some ambiguities in the respective roles and responsibilities of different political level groups. In particular, there is ambiguity in the roles of:

the Emergencies Council in an emergency-like situation but where a State of Emergency has not been declared; and

the Competent Authorities Ministers Group.

Governance and Decision Making during the COVID-19 Pandemic

6 May 2022

R5  In establishing any group comprising a sub-set of the Council of Ministers,

explicitly consider and document:

• its relationship to the Council of Ministers

• its authority; and

• when and how it reports to the Council of Ministers.

R6  For political level groups routinely include an item at the start of agendas

considering:

• the relevance of interests previously declared to the Greffier of the States to items on the agenda

• whether there are any other interests that are relevant to items on the agenda; and

• the response to identified interests, including non-participation in items on the agenda.

R7  Apply similar arrangements for the declaration and management of conflicts of

interest for officers participating in such political level groups.

R8  Ensure that all declarations of interest and associated arrangements for

management of conflicts of interest are clearly minuted.

R9  Adopt and use a standard format for agenda papers for political decision

making groups that includes:

• the reasons for referral to the group in question

• the recommended course of action

• potential alternative courses of action; and

• the reasons for the recommended course of action.

R10  For political decision making groups routinely maintain and present to

subsequent meetings an action log that records the implementation of decisions made, for example through Ministerial Decisions and Orders.

R11  Ensure that there is clear delineation between meetings of different political

decision making groups.

R12  Adopt a clear timetable for preparation, consideration and approval of minutes

of political decision making groups.

COVID-19 Test and Trace and Vaccination Programmes 24 May 2022

Background and Scope

Both the Test and Trace and the Vaccination Programmes have been key tools as part of the Government of Jersey's COVID-19 pandemic strategy.

The Government of Jersey spent over £20.2 million on the Test and Trace Programme during 2020 and a further £41.7 million during 2021. At 31 December 2021, a total of £61.9 million has been spent on the Test and Trace Programme. A further £20 million of funding has been allocated to the programme in the Government Plan 2022-25.

At 31 December 2021, over £5 million had been spent on the Vaccination Programme against a budget of £5.5 million. A further £6.7 million has been allocated to the Vaccination Programme in the Government Plan for 2022-25 giving an overall programme total of up to £12.2 million.

Key Findings

Test and Trace Programme

• The Government of Jersey acted at pace and in a reasonably controlled and measured way to effectively introduce and scale up an Island-wide Test and Trace Programme commencing in May 2020.

• The scale of the testing programme in Jersey was significantly larger than in comparable jurisdictions.

• The rapidly evolving nature and increasing duration of the COVID-19 pandemic gave rise to the need for a significant number and value of business cases to support expenditure on the Test and Trace Programme. In some instances, I consider that the business cases lacked sufficient detail and justification.

• The strategic objectives set at the start of the Test and Trace Programme were consistently carried through in the Government's June 2020 COVID-19 Strategy, the November 2020 Winter COVID-19 Strategy update and the October 2021 COVID- 19 Winter Strategy Update 2021-22.

• Despite a lot of effort, both internal and external communication could have been improved, particularly when explaining the complexities of a long running pandemic in simple terms. There is evidence that some members of the public were sometimes confused by scientifically informed and evolving test, trace and isolation advice. In addition, despite comprehensive attempts at staff communication, some test and trace staff who were on zero hours contracts did not always understand why they were sometimes being stood up', stood down' and stood back up' again over the lifetime of the long running pandemic.

• During the course of the COVID-19 pandemic the Test and Trace Programme has had to significantly change how it operates to keep up with the evolution of the pandemic. Despite significantly increasing the Island's testing capacity, at key times

COVID-19 Test and Trace and Vaccination Programmes 24 May 2022

the combined test and trace service could not meet demand. In particular, there were times when attempts to trace all the contacts of infected Islanders within a short period of time, was compromised. This was particularly the case in the third wave (Delta variant) during the summer of 2021 and in the fourth wave (Omicron variant) in the late autumn of 2021.

• The planning assumptions underlying the set up and operation of the Test and Trace Programme, particularly from the summer of 2021 onwards, were significantly understated.

• The Test and Trace Programme did successfully produce health surveillance data to help track the progress of infections on the Island. In addition, the Test and Trace Programme did, to some extent, control the spread of COVID-19 infections on the Island. It is not possible however to conclude by what amount the rate of increase was minimised and whether that minimisation of infections represented value for money.

• As a consequence of the delay in opening the in-house testing laboratory the Government of Jersey incurred additional costs estimated to be in excess of £5 million.

Vaccination Programme

• The Government of Jersey decided to follow the UK mainland lead on the authorisation of vaccines. This was a logical decision given Jersey's involvement in the UK Joint Committee on Vaccination and Immunisation (JCVI) and Medicines and Healthcare products Regulatory Agency (MHRA).

• The overall objective of the Vaccination Programme was to maximise uptake, safely and with convenience.' The objectives and purpose of the programme were clearly stated in key strategic and project management documents.

• There have been clear lines of governance within the Vaccination Programme and good project management and control. There is also evidence that indicates that the Vaccination Programme communication was generally good.

• Vaccines were provided free of charge from the UK Government. This resulted in significant savings in the estimated cost of delivery of the first two doses which had assumed procurement by the Government of Jersey. This enabled the cost of the first phase of the booster (the third dose) to be met from the initial funding allocation for the first two doses. The cost benefit to the Government of the free vaccine provision from the UK Government is considered to be in excess of £3.5 million in 2021.

• The cost of administering each vaccine during 2021 was similar to the cost seen in Scotland and lower than the cost seen in England.

• Jersey has performed well in comparison to other jurisdictions in terms of the percentage of the population that has been vaccinated.

COVID-19 Test and Trace and Vaccination Programmes 24 May 2022

Conclusions

The Government of Jersey moved at pace to establish a large scale Island-wide Test and Trace Programme in the spring of 2020. The programme established was extensive. Over the course 2021 however there have been times when the programme has not kept pace with the pandemic.

The Government of Jersey performed well to deliver an effective Vaccination Programme under very tight time constraints. The delivery of the Vaccination Programme in Jersey has, in overall terms, been effective.

Summary of Recommendations

R1  Create and maintain a comprehensive live programme control document for

long running emergency programmes that cover multiple activities and are initiated by a single programme business case. The live programme control document should record all business cases and decisions relating to the programme.

R2  Undertake a comprehensive review of the Test and Trace Programme

communications, involving members of the public, representative community organisations and behavioural scientists, with the aim of creating a simple, robust communication plan for similar long running events of this type in the future.

R3  Require strategic programmes that fall outside the Public Finances Manual

definition of a capital or major project to set out in a Project Initiation Document the way in which the programme will be controlled and managed.

R4  Ensure that a reconcilable audit trail is maintained between business cases and

related expenditure for all significant projects when these might include changes over time.

R5  Review exemption and breach records in respect of expenditure on PCR testing

and the on-Island laboratory and ensure breaches have been recorded in compliance with the Public Finances Manual.

R6  Ensure that the full range of requirements for all users is captured when

compiling high-level IT systems specifications.

R7  Ensure that all IT and digital investments are validated by the Design Authority,

so that there is a clear view of systems interdependencies and to avoid the unnecessary duplication of data.

R8  Ensure all future IT systems developments are tested rigorously, both

functionally and non-functionally in-line with best practice principles.

R9  Require all major programmes to maintain a formal operational decision log.

States Employment Board – Follow Up 8 September 2022

Key Findings

• Considerable progress has been made during 2021 and 2022 in implementing many of the recommendations made in the 2019 C&AG Report. In addition, most of the recommendations made in the other relevant C&AG reviews have been implemented.

• However, the most significant recommendation in the 2019 C&AG Report relating to the need to fundamentally review the framework for the oversight of human resources of the States, involving both the SEB and the JAC, has not been implemented. The new Council of Ministers (CoM) and the new SEB should prioritise this review as recommended both by the C&AG and the Democratic Accountability and Governance Sub-Committee of the Privileges and Procedures Committee in its report in February 2022.

• Legislation to ensure the independence of the JAC in line with the C&AG recommendation is still in draft form. The new SEB should prioritise its review of this draft legislation and bring forward a proposition to the States.

• A People Strategy was published in November 2021 and sets out the high-level objectives and a clear strategy for developing the public service. It is accompanied by a detailed action plan for 2022. The Be Heard' staff survey planned for 2023 should help to test the impact of the changes.

• Significant work has been put into organisational development, as well as into developing the Government of Jersey workforce through initiatives including the Team Jersey, World Class Manager, Capable Manager Expresso programme, Apprenticeship and Intern schemes.

• Effective workforce planning is still in its infancy and workforce plans are being developed. Currently separate records are held in Treasury and Exchequer (T&E) and People and Corporate Services (P&CS) on the funded establishment. The Integrated Technology Solution (ITS) currently being implemented should provide an opportunity to streamline records and ensure appropriate reconciliations are in place between key systems.

• Good progress has been made over the last year in respect of health and safety with regular reports presented to the SEB together with a risk register. However, there is more to be done. Compliance with health and safety requirements and the resources applied to the function are inconsistent across departments. One Ministerial department does not have any qualified resource to deliver the action necessary.

• Work has been on-going to update all the Employee Codes of Practice during 2022, along with a full suite of accompanying HR policies. A new People Policy Framework has also been developed.

States Employment Board – Follow Up 8 September 2022

R3  Ensure effective arrangements are in place to monitor compliance with

mandatory health and safety training requirements including providing regular reports to the SEB on the extent of compliance.

R4  Publish a formal Executive Response to the six recommendations made by the

JAC in its 2021 Annual Report.

R5  Produce a consolidated report on progress against the People Strategy for

consideration by the SEB on a regular basis.

R6  Ensure that establishment data held by Treasury and Exchequer and by People

and Corporate Services is reconciled on a regular basis.

R7  Update the protocol for the operation of the People Hub and monitor

performance against the agreed protocol.

R8  Fully document decisions made and actions agreed by the SEB to mitigate the

risks on the corporate workforce register and follow up at subsequent SEB meetings.

R9  Enhance the reporting of health and safety mitigating actions to SEB to include:

• an assessment of the resources required to deliver minimum standards across the estate; and

• demonstration of the mitigating actions being put in place in the meantime to minimise exposure to risk.

R10  Review the Scheme of Delegation in respect of P.59 forms.

R11  Consider how to make the SEB more transparent and visible to staff, the States

Assembly and the public by:

• reviewing the Part A' and Part B' meeting content to consider whether any more could go into a public agenda

• considering the flow of documentation both to the SEB and from the SEB and ensure that the senior team is fully sighted of both the agenda and the decisions made

• publishing a summary for staff, the States Assembly and the public on the business and key issues discussed at each SEB; and

• improving further the content of the SEB Annual Report to include a clear narrative as to whether the SEB has met its plan for the year and what actions are required in the following year.

R12  Review the content of the Annual Governance Statements required from

Accountable Officers to ensure that compliance with all aspects of Employment

States Employment Board – Follow Up 8 September 2022

Codes of Practice and supporting policies is confirmed. This should include a requirement to report on compliance with the appraisal system.

R13  Introduce a standardised approach to evaluation and documentation of

performance of Directors General, including formal input from Ministers.

R14  Update the documentation requirements of appraisals to ensure that they

encompass relevant professional standards where appropriate.

R15  Put in place arrangements that ensure compliance with the requirements of the

performance appraisal system. Provide regular reports to the SEB on compliance.

R16  Undertake a review to ensure the nature and role of all advisors to the Government, including those who are unpaid, are documented.

R17  Ensure that the minutes from the previous SEB meeting are circulated with the

papers and signed off at the next meeting.

R18  Introduce a decisions and action log for all decisions from the minutes and

ensure that this is placed on the agenda and progress formally monitored.

Current work planned that should be prioritised

P1  Determine the requirement for independent advisors to the SEB and commence

the process of recruitment.

P2  Give priority to ensuring that workforce planning is delivered consistently and

accurately across departments by the end of 2022.

P3  Ensure that, as part of the migration to ITS, the people data is fully cleansed and

that data is accurate, is recorded on a timely basis and is monitored, including sickness absence data and return to work data.

P4  Work to complete the updates to the Employment Codes of Practice and

supporting policies as planned. This should include completion and implementation of the revised Whistleblowing Policy.

P5  Review the scope of matters explicitly covered in the contracts for ELT members

against best practice.

P6  Implement the planned system for storing key SEB documents and ensure that

the relevant minutes are kept with the papers in an accessible form.

P7  Finalise the Service Level Agreement in respect of minute taking.

Child and Adolescent Mental Health Services 22 September 2022

• There are early signs that new ways of managing referrals and the evolving service structure for CAMHS are having a positive impact on waiting times.

• Most community CAMHS is provided by the Government. Commissioning of community services from other on-Island providers is relatively under-developed but opportunities for partnership working are increasingly being identified.

• For those small numbers of children and young people who require inpatient mental health care, Jersey does not have a dedicated facility. There are two developments intended to relieve this sub-optimal arrangement – Clinique Pinel and the Our Hospital Project. The timescales for these developments are not clear although I have been informed that the current forecast for the opening of Clinique Pinel is the end of 2022.

• In circumstances where facilities on-Island are not adequate to meet the child or young person's need, services are commissioned from the UK. I identified some weaknesses with these commissioning arrangements.

• Governance arrangements for CAMHS have not been robust and have not operated effectively. Since June 2019, the Health and Community Services Department (HCS) and CYPES have had joint responsibility for delivering CAMHS. However there has not been a robust, agreed Memorandum of Understanding (MoU) in place to govern this relationship and to assure the safe and high-quality delivery of services. Whereas draft versions of the MoU have been considered and agreed in principle', there is no one version that all signatories to the MoU have approved. In addition, the Terms of Reference (ToRs) for the required Governance and Oversight Group have never been finalised and the Group has not fulfilled its overarching role of securing and assuring clinical and professional standards.

• New governance arrangements are being established in 2022 - however the ToRs for key groups and boards within the new structure are yet to be finalised.

• There has been no overarching and co-ordinated approach to consideration of CAMHS performance and risk data. There has been a disconnect in the management of clinical' (which is viewed as HCS's responsibility) and operational' (CYPES) performance and risk information. Alignment of data and information, to enable joint clinical and operational oversight of the quality of services, has been lacking.

• For both CYPES and HCS, the range and quality of service data relating to CAMHS is recognised as in need of improvement. The data requirements of the Children and Young People's Emotional Wellbeing and Mental Health Strategy 2022-2025 are, I understand, now identified and being built into data sets for both CAMHS and for Public Health. The Children's Health and Wellbeing Operational Policy dated March 2022 sets out an aspirational Minimum Data Set (MDS) for CAMHS. The MDS is dependent on systems changes currently being implemented.

• Compared to UK benchmarks, in 2019/20 the CAMHS caseload was twice as high as the UK average. The benchmark data indicated that Jersey CAMHS keeps children

Child and Adolescent Mental Health Services 22 September 2022

R3  Ensure improvements to on-Island inpatient care for children and young people

are implemented, including by setting and monitoring Key Performance Indicators (KPIs) to demonstrate improved service user experience.

R4  Ensure that the IPP considers and commissions services to meet all needs of the

service user when deciding on a package of care.

R5  Ensure that the due diligence' items set out in the Procurement Strategy are

supported by high quality information and are used consistently when making decisions about off-Island placements.

R6  Agree, adopt and communicate a Memorandum of Understanding between

CYPES and HCS for the governance and operation of CAMHS.

R7  Agree, adopt and communicate a Terms of Reference for the joint Governance

and Oversight Group, ensuring that this documents:

• how all accountabilities are satisfied

• how the joint principles identified at the away day' will be carried forward; and

• how the stated objectives of the move of CAMHS to CYPES will be assured.

R8  Agree, adopt and communicate Terms of Reference for newly developed

governance groups including the Mental Health System Partnership Board and the Children's Health and Wellbeing Programme Board. Ensure that these Terms of Reference document the groups' relationships to:

• the Jersey Care Model; and

• the Our Hospital' project.

R9  Ensure arrangements are in place to monitor and manage compliance with all

governance processes.

R10 After a suitable period, evaluate how effectively all governance processes are

working in practice.

R11  Document and implement a comprehensive quality and safety programme

across CAMHS.

R12  Establish a process to ensure that all relevant departments, not just the lead

department, are aware of and properly engaged in implementing actions in response to accepted C&AG recommendations. Include this process in the Tracker Manual which covers roles, responsibilities, accountabilities and Tracker operation.

Child and Adolescent Mental Health Services 22 September 2022

R13  Agree, map out and implement roles, responsibilities and arrangements for

CAMHS performance management across all areas of Government and all relevant structures, covering:

• setting standards

• identifying and capturing data for Key Performance Indicators

• establishing ambitious targets and benchmarking arrangements

• monitoring and overseeing performance against standards and targets

• reporting; and

• taking action to resolve identified weaknesses and implement improvements.

R14 Agree, map out and implement roles, responsibilities and arrangements for

CAMHS risk management across all areas of Government and all relevant structures. As part of this, review arrangements for ensuring all risks relevant to CAMHS are logged and can be appropriately cross-referenced in one document.

R15 Set standards for documenting the output and outcome of CYPES strategic and

key operational management meetings. As a minimum this should include attendance, items to be logged as risks, decisions made and actions agreed. Ensure these are appropriately accessible so that they can be meaningfully used by officers.

R16 In finalising a Minimum Data Set for CAMHS, make it sufficiently comprehensive

to encompass all data to be routinely collected, including as a priority data to identify potential inequalities in access to services.

R17  Formalise plans to improve the richness and quality of performance dashboards

within Children's Health and Wellbeing. Ensure the needs of all parts of the governance and advisory structure are considered, including the Annual Report planned for 2023.

R18  When using online live' data at a meeting or group, ensure sufficient

information is recorded so that:

• risks identified, decisions made and actions agreed are clear; and

• the basis for those decisions and actions is evident – for example a screen shot of the relevant data.

R19  Ensure that learning from Jersey's participation in the NHS Benchmarking

Network for CAMHS is routinely captured as part of action plans to improve data quality and performance.

Child and Adolescent Mental Health Services 22 September 2022

R20  Implement a process for regular CAMHS caseload review to ensure that

caseloads are managed consistently and in line with agreed criteria.

R21  Risk assess recruitment practices against relevant lessons from the issues

experienced in retaining social workers and take mitigating actions to reduce the risk to CAMHS recruitment and retention.

R22  Undertake a post implementation review of the new process for receiving

CAMHS referrals to understand whether:

• including examples would help referrers phrase their concerns and improve information provision

• use of urgent' by those making referrals is in line with expectations; and

• there are issues caused by duplicate referrals.

R23  Establish criteria against which against to monitor the impact of self-referrals,

including as part of understanding inequalities of access to CAMHS and other Children's Health and Wellbeing services.

R24  Explore options for automating the process of logging referral information

across multiple systems (Mosaic, Care Partner and TrakCare), to reduce the risk of error.

R25  Keep a log of decisions made and action agreed at the weekly Health and

Wellbeing Service Referral Management meetings, including any actions to update the risk register.

R26  Ensure that arrangements to keep in touch with those referred and accepted for

assessment meet good practice.

R27  Ensure triage' target times are widely understood by, and performance is

reported to, referrers and the public.

R28  Although this is implicit in the triage process described, explicitly set and

communicate waiting times standards for assessment for young people with psychosis and with eating disorders.

R29  Set out clear discharge protocols to provide explicit and tailored information on:

• how to stay well

• a summary of how the child or young person felt about being discharged; and  

• whether they achieved the goals they identified or modified the goals.

Risk Management – Follow Up 7 October 2022

R5  Undertake a full review of the Corporate Risk Register to ensure consistent

interpretation of risks that may impact on delivery of Common Strategic Policy priorities and the Government Plan.

R6  Review the Managing Risk section in future Government Plans to ensure that it

reflects high level risks of delivering the priorities in the Government Plan rather than a small sample of risks taken from the Corporate Register.

R7  Include significant risks that may impact on delivery of departmental business

plans in these business plans.

R8  Undertake a full review, led by ELT of all risks on the Corporate Risk Register to

confirm that:

• inclusion as a risk and scoring is justified and a consistent interpretation of the guidance

• controls recorded are appropriate and meaningful; and

• recorded mitigating actions are robust and timetables are realistic.

R9  Enhance mechanisms to hold Accountable Officers to account for the

effectiveness of mitigating controls and actions recorded on the risk register. In doing so, review the purpose and operation of the deep dive' processes operated by the Head of Risk and the Risk and Audit Committee to consider their effectiveness and ensure that they do not duplicate one another.

R10  Review the Terms of Reference of the DRG to maximise its effectiveness. In

doing so, clarify the purpose and corresponding information and access needs for the DRG as a resource to add value to the corporate risk management framework.

Work planned that should be prioritised

P1  Complete the planned update to the Community Risk Register.

P2  Integrate CLS fully into the Enterprise Risk Management system.

P3  Complete the development of core objectives for risk management for Tier 1-3

staff, as part of the Performance Management Framework.

P4  Complete the work on Competency Framework including a reference to risk

management as a core competency.

Areas for consideration

A1  Review the detailed content of the Risk Management Strategy alongside its

supporting guidance to ensure that balance and level of detail are appropriate for users.

Annual Reporting 9 November 2022

Key Findings

I am pleased to see that most entities reviewed have made improvements to their annual reports, some significantly:

• three-quarters of 2021 annual reports set out information on performance, accountability and (where relevant) their finances in single annual reports. This compares to just over half in 2020

• 66% of 2021 annual reports' overall content (43% in 2020) is fair or good compared to best practice; and

• 79% of annual reports (62% in 2020) demonstrated fair or good compliance with best practice principles.

Progress in respect of accountability and sustainability reporting has however been slower:

• more than 40% of accountability reports are still poor or very poor compared to best practice. In particular, over 70% of remuneration and staff reporting (including disclosure of directors' pay and directors' interests) fell below best practice; and

• just under half of annual reports made no reference to climate issues and only five reported on sustainability using a relevant sustainability framework.

There has been a mixed picture in respect of timeliness for publishing 2021 annual reports:

• 14 entities published their 2021 annual reports in an earlier month than for the previous year compared to 10 that published their annual reports in a later month

• more entities missed their deadlines for their 2021 annual reports than for their 2020 annual reports; and

• fewer annual reports were published by 31 July in 2022 than has been the case in 2021and 2020.

Conclusions

Annual reporting is fundamental to ensuring accountability of public entities.

I am pleased with the improvements I have seen in the annual reports of many States controlled and States established entities. I encourage entities to consider the issues raised in this report and my Good Practice Guides and continue to make further improvements.

Annual Reporting 9 November 2022

The States of Jersey have an opportunity to build on the progress made by individual entities by specifying the requirements for annual reporting. In doing so, the States should pay particular attention to:

• accountability reporting, especially staff and remuneration disclosures; and

• sustainability reporting.

So as to help the States of Jersey and individual entities focus their actions, I have consolidated the findings from this report and recommendations from my 2020 and 2021 reports into a single set of recommendations.

Summary of Recommendations

Recommendations for the States of Jersey

R1  Finalise and set out minimum requirements for annual reports and accounts for

States established and States controlled entities. In doing so, consider:

• setting out different requirements depending on the nature and size of entities

• specifying minimum requirements for reporting on performance, accountability and finances

• requiring specific disclosures of remuneration of directors and staff

• for entities required to publish financial statements:

• specifying the accounting framework; and
• specifying the degree of independent assurance that should be provided over the financial statements; and

• for all entities, setting out the requirements for making the annual report and accounts public.

R2  Introduce a requirement for Statistics Jersey to produce an annual report.

R3  Set out a public ambition and timetable for the production of a States of Jersey

annual sustainability report. In doing so, consider:

• the Jersey Performance Framework and the Taskforce on Climate-Related Financial Disclosures (TCFD) recommended disclosures

• whether the sustainability report should form part of the States of Jersey Annual Report and Accounts or be a separate report

Grants to Arts, Heritage and Culture Organisations 23 December 2022

The Government should agree stretched targets with Arm's Length Bodies which are in receipt of additional grant funding that demonstrate delivery of key aspects of the Arts and Heritage Strategies.

A clear plan is required to deliver the identified refurbishment needs at the Opera House and Arts Centre. Roles and responsibilities for future maintenance at the Opera House must be determined and agreed

Summary of Recommendations, Work planned that should be prioritised and Areas for Consideration

Recommendations

R1  Undertake further analysis to review and assess options for all Jersey arts

venues.

R2  Prepare and publish implementation plans for both the Arts and the Heritage

Strategies. These implementation plans should include:

• prioritised and costed actions

• clarity on alignment of workstreams and task and finish group proposals with priority themes

• indicative implementation timetables; and

• clearly allocated responsibilities.

R3  Review all arts and heritage KPIs to ensure that data is readily available and a

baseline is determined as a reference point for trend measurement.

R4  Develop a holistic approach to grant funding of the three main arts bodies which

recognises individual offers as well as the collective contribution to delivery of the Arts Strategy.

R5  Introduce a requirement for each ALB to submit a formal grant funding request

with business case and needs assessment each year. The formal request should include details of:

• the funding being requested

• the outcomes that will be achieved with the funding granted; and

• how those outcomes contribute to the implementation of the relevant Arts or Heritage Strategy.

R6  Liaise with each ALB and encourage development of longer-term business plans

with stretched targets that link to the Arts and Heritage Strategies.

Thinkpiece: Governance and Accountability of Independent Bodies and Office Holders 30 December 2022

Background and Scope

The States of Jersey have established several entities which operate, to varying degrees, on an independent arm's-length basis. In some instances, the establishment of these entities on an arm's-length basis is a matter of policy choice. In other instances, the activities undertaken by the entity include those of a regulatory, audit, oversight or challenge nature. These, by their nature, need to operate with an element of independence from the Government of Jersey.

The particular arrangements for the governance and accountability of individual independent bodies and office holders have arisen through both policy choices reflected in legislation and through the operating models adopted by different entities.

Key Findings

In my view, there are opportunities to:

• strengthen operational independence of the bodies and office holders included in my review through:

• ensuring a principle of independence in the discharge of functions is enshrined in legislation for each body and office holder
• justifying differences in the arrangements for appointment, terms of office and arrangements for removal of members of independent bodies
• adopting clear principles to underpin the funding mechanisms in place for independent bodies and office holders including protections from inappropriate pressures on their budgets from the Government of Jersey; and
• introducing consistent provisions to reinforce that States employees working for the independent body or office holder shall be treated as if they were an employee of the independent body or office holder

• enhance accountability of the independent bodies and office holders included in my review through:

• adopting a requirement for bodies and office holders to comply with the Public Finances Manual (PFM), with appropriate and necessary adaptations
• specifying requirements in respect of annual reports, including in respect of content and timing; and
• where appropriate, strengthening requirements in respect of internal audit and the appointment of external auditors; and

• review and consolidate support services used by many independent bodies and office holders through:

Thinkpiece: Governance and Accountability of Independent Bodies and Office Holders 30 December 2022

A3  Where appointments of Chairs and members of independent bodies and office

holders are made by a Minister, review the arrangements for the appointment, including whether there is a compelling reason for not requiring a two week notice period to the States Assembly.

A4  Consider the rationale for differences in the initial terms of office of Chairs of

independent bodies.

A5  Ensure that legislation reflects the Jersey Appointments Commission Guidance

that the maximum term of office for independent members of Boards does not exceed nine years.

A6  Ensure appropriate processes are in place in cases where the removal of

members of independent bodies and of individual office holders is proposed. A7  Introduce a clear, understandable and objectively justifiable framework for

funding of independent bodies and office holders by the:

• development of overarching principles for when a body should be funded by fees, levies, grants or revenue heads of expenditure; and

• adoption of a consistent pattern of responsibility for setting of fees and levies.

A8  Where independent bodies and office holders operate within the States of

Jersey, ensure that there is a clearly identified separate revenue head of expenditure and that the senior officer within the independent body has Accountable Officer status.

A9  Introduce legislation for all independent bodies and office holders to specify

that States of Jersey employees working for an independent body or office holder shall be treated as if they were the staff of the independent body or office holder.

A10  Introduce minimum good employer standards for independent bodies

empowered to employ their own staff.

Enhance accountability

A11  Apply the PFM with suitable adaptations to independent bodies and office

holders.

A12  Document minimum standards for the responsibilities of an Audit Committee or

similar body for all independent bodies and office holders.

A13  Specify minimum mandatory content of annual reports for independent bodies

and office holders.

Thinkpiece: Governance and Accountability of Independent Bodies and Office Holders 30 December 2022

A14  Introduce standardised requirements for the timing of annual reports of

independent bodies and office holders.

A15  Specify minimum standards for annual financial reporting, even where the

financial performance of independent bodies and office holders is already reflected in the annual accounts of the States of Jersey.

A16  Introduce a presumption in favour of internal audit provision for independent

bodies and office holders unless there is a clearly documented case that the costs would outweigh the benefits.

A17  Where independent bodies and office holders are required to prepare full

annual accounts and their expenditure exceeds a specified threshold, introduce a requirement that they should be subject to audit by auditors appointed by the Comptroller and Auditor General. In other cases, introduce a requirement for an assurance engagement providing a lower level of assurance by an independent examiner appointed by the Comptroller and Auditor General.

Review and consolidate support services

A18  Document the services and standards for the provision of services by the Government of Jersey to independent bodies and office holders.

A19  Independent bodies and office holders should continue to work collectively to

explore opportunities to share support services and, in some cases, accommodation.

The policy framework

A20  Develop a clear policy framework for the governance and accountability of

independent bodies and office holders, including consideration of the nature and extent of independence that is required in each case and how such independence can be secured, having regard to relevant international standards and the experience of other jurisdictions.

A21  In light of any policy framework adopted, consider framework legislation for

governance and accountability of independent bodies and office holders including consistent provisions for independent bodies and office holders, or groups of independent bodies and office holders, in the absence of a clear rationale to the contrary.

A22  In light of any policy framework adopted, beneath legislation develop common

standards for the governance and accountability of independent bodies and office holders addressing the areas covered in this Thinkpiece.

Summary of Government Response Not yet submitted.

62 | Annual Report of Findings 2022