Report on the Accounts of the States for the year ended 31st Dec 2008 - Ministerial Response - 26 April 2010

Findings

Comments

1

Lines  of  financial responsibility  remain unclear  across  several Departments,  leading  to confusion  and  the spending of considerable sums  of  public  funds which  cannot  be accounted for.

Accountability is clearly set out in the Public Finances Law. This law provides for the appointment of Accounting Officers with very specific responsibilities. The Law specifically states: "Although a function of an accounting officer may be carried out by another person the accounting officer remains personally accountable."

The  improvements  in  financial  management  currently  being implemented  will  ensure  that  delegations  and  responsibilities  within Departments  are  clearly  documented  and  understood  by  all  those involved. The following reminder was sent to Accounting Officers by the Chief Executive following a meeting with the PAC in July 2009:

Implementation of States Decisions:

On Monday 12 July 2009, I attended a PAC hearing with the Chief Minister. They are reviewing the process of letting the contract for the Incinerator  with  specific  attention  to  roles  and  responsibilities  for provision of funding.

The PAC were interested to know how Accounting Officers ensure that any States decision is properly and fully implemented in accordance with the agreed Proposition and the accompanying report.

Following the discussion I undertook to inform all Accounting Officers of this concern, which is the purpose of this note.

I do not intend to try and summarise the roles and responsibilities of Accounting Officers, they are set out within the Financial Directions in general and specific terms.

There are issues that I do want to draw to your attention.

When finalising the implementation of any States decisions you should ensure  that  you  have  met  the  requirements  of  the  proposition  in accordance with Financial Directions. The Public Accounts Committee asked whether Accounting Officers check and record that the conditions have been met. I could not guarantee that has occurred in every case to date. However I undertake to remind you to do so and I am doing so by means of this note.

In relation to some propositions the accompanying report presented by your Minister will describe the actions to be action in implementing the proposition. You should ensure that these actions are implemented and where it is not possible to do so the alternative course adopted should be recorded together with the reasons. In the event that you are called before the PAC you should seek to b able to justify these variations.

In most cases it is very clear which Accounting Officer is responsible for implementing decisions, delivering major projects etc. However from time to time there may be a lack of clarity. If you are in any doubt as to your responsibilities then you need to clarify matters with any other Accounting Officer who may have an involvement. I would ask that in such cases you inform the Treasurer and I. If there is any difficulty in resolving who is responsible and accountable for any specific issues please inform me and I will work with you to bring it to a resolution.'

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

1

The  independence  of  the Treasurer  is  paramount –  as are  clear  reporting  lines  and allocations of responsibilities. Where failures of accounting controls occur, there must be responsibility  taken from  the centre  to  correct  these problems. The significant and potentially  costly  lack  of clarity  within  Home  Affairs must be corrected as a matter of urgency.

Accept

The independence of the Treasurer is enshrined  in  the  Public  Finances (Jersey)  Law  2005  and  makes specific  provision  for  his independence:  "The  Treasurer  may not be directed on how a function of the  office  of  Treasurer  is  to  be carried out."

A  key  element  of  the  Treasury Restructuring  Plan  is  an  increased focus  on  financial  standards  and compliance with these standards and procedures  across  all  States Departments.

Under  the  new  arrangements, compliance  with  financial  controls and  procedures  will  be  overseen centrally  by  the  Treasury. Departmental Finance Directors will be held accountable for taking action to  ensure  that  controls  and procedures are complied with.

The accountability of individual Accounting Officers is clearly defined within the Public Finances Law.

2010

Findings

Comments

1

The  procedures  in relation to the provision of  grants  (which  is  in effect the handing-out of taxpayers'  money)  have been  tightened  and  the PAC  is  heartened  by this.

The Chief Executive is pleased to note the PAC's recognition of the improvements carried out by the Department.

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

1

The PAC is concerned that grants  are  still  being provided  to  organisations that  do  not  fulfil  all requirements.  The  PAC recommends  that  EDD adopt  a  zero  tolerance' approach  given  the  nature of the funding – regardless of any short-term impact.

The  PAC  is  concerned about the cost-effectiveness of some of Jersey Finance's speculative  activities,  and questions  whether  these should be publicly funded.

Accept

The  Chief  Executive  has  noted  the PAC's concern and has implemented a Zero Tolerance Policy with regard to all grants.

The  Department  is  constantly evaluating the value for money from its grant to JFL and ensures that industry funding is maximised by JFL.

As  mentioned  previously,  Jersey Finance  Limited  prepare  a  Business and Marketing Plan each year, and this is  submitted  to  the  Minister  for Economic Development for approval.

Immediate action

Findings

Comments

1

Jersey has no legislation regarding repatriation of prisoners,  which  is resulting in unnecessary expenditure  of  public funds on accommodating foreign nationals.

The drafting of a Repatriation of Offenders Law, enabling prisoners to serve their sentence in their home country where appropriate, is one of the Minister's priorities for 2010. There is Law Drafting time allocated in  the  2010  Programme.  The  Department  will  be  preparing  drafting instructions as soon as possible.

2

The  Accounting  Officer within the Home Affairs Department  is  currently unable  to  undertake  his role  due  to  the Departmental  Structure. The  PAC  is  concerned that the current position is open to abuse and that there  is  a  lack  of  clear accountability.

This is incorrect. I advised the Chair of the PAC through my comments on the draft report that I am the Accounting Officer for the whole of the Home Affairs budget and that I had never suggested otherwise.

I  made  the  point  that  the  events  surrounding  expenditure  on  the Historical  Child  Abuse  Enquiry  (HCAE)  placed  me  in  a  vulnerable position. I had not felt so exposed up until that point. Prior to this, there had never been any impediment to properly fulfilling the accounting officer responsibilities other than any particular issues mentioned in my annual Statement of Internal Control. However, action is needed and the Department is reviewing whether the accounting officer responsibilities can be split within the current provisions of the Public Finances (Jersey) Law 2005.

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

1

Using  the  UK's Repatriation  of  Prisoners Act  as  a  precedent, legislation  should  be brought  into  force  and agreements made with other countries to allow prisoners to be returned to their home countries.  This  should  not only  provide  significant savings  for  the  taxpayer – but  will  also  repatriate foreign  nationals  to  their homeland  where  they  can receive support from family and friends.

Accept

The  drafting  of  a  Repatriation  of Offenders  Law, enabling  prisoners to serve  their  sentence  in  their  home country  where  appropriate,  is  one  of the  Minister's  priorities  for  2010. There is Law Drafting time allocated in the 2010 Programme. The Department will be preparing drafting instructions as soon as possible.

2

The Accounting Officer role within Home Affairs needs to  be  strengthened  and clarified  as  a  matter  of urgency.  The  PAC  is  very concerned that this issue is still  outstanding,  despite being  raised  as  an  urgent problem some time ago. It is simply not acceptable that there  is  still  no  defined accountability in respect of taxpayers' funds.

Accept first part

The accounting officer role within the Home  Affairs  Department  is  quite clear – the Chief Officer Home Affairs is  the  Accounting  Officer.  The  issue that  arose  in  relation  to  the  Historic Child Abuse Enquiry is that the Chief Officer  Home  Affairs  has  no  line management  responsibility  or operational control over the States of Jersey  Police.  This  exposed weaknesses  in  the  accounting  officer arrangements.

Although no formal solution has been agreed, as a result of discussions with the  Acting  Chief  Officer  of  Police, there is now in place a Memorandum of Understanding (MOU) between the two  Chief  Officers  in  relation  to  the Management  of  Finance  and Exceptional  Areas  of  Expenditure'. The MOU is an interim measure which gives a shared understanding of how to discharge  financial  management responsibilities  under  the  current accounting officer framework and the Department  is  working  towards developing a system that will serve us better in ensuring compliance with the Public  Finances  (Jersey)  Law  2005. This is related to the ongoing work to establish a Police Authority which is likely  to  result  in  changes  to  the existing  accounting  officer arrangements  whereby  there  are 2 accounting officers in Home Affairs.

3

The PAC recommends that a Police Authority, to which police  expenditure  will  be accountable, is set up as a matter of urgency.

Accept

The  establishment  of  a  Police Authority  is  one  of  the  Minister's priorities for 2010.

The States approved P.23/2010 on 23rd March  2010  which  re-affirms  the States'  desire  to  establish  a  Police Authority. The Minister has already set up a consultative group of 6 members to review proposals.

Findings

Comments

1

Expenditure  on  Health and  Social  Services  is never  in  the  ratio  put forward in the Business Plan as technically they are  one'  Department with one' budget.

The H&SS SMT have traditionally retained a level of flexibility around resource  allocation  to ensure  that  changes  in  priority  or  service risk during any year can be managed by occasionally diverting resource from one service area to another.

2

The PAC found a lack of understanding  amongst senior  Health Management  in  respect of the true cost of Health provision.  For  example, patients  were  being retained  in  the  hospital rather  than  being transferred to the private sector  to  save  money – yet the cost of provision within the public sector was unknown.

One of the core functions of the H&SS Finance Team is to provide appropriately summarised service area cost information to assist senior Managers make effective business decisions.

Whilst the demands on the team are often in excess of the available skilled resource, the Director of Finance will prioritise these costing exercises to ensure the highest risk/high value business decisions receive an appropriate level of financial support.

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

1

Whilst  the  PAC acknowledges that there can be  advantages  in  the flexibility of the Health and Social Services split, it has concerns  that  sufficient controls are not currently in place to avoid the potential abuse  of  this  flexibility  to the detriment of the public. Consideration  should  be given  to  providing parameters  within  the Public  Finances  Law  to limit  deviation  from  the Annual  Business  Plan agreed  by  the  States Assembly.

Accept

The  H&SS  SMT  have  always  been alert to this risk and in recent years has comprehensively tried to ensure that all direct budgets allocated to Community and  Social  Services  i.e.  not  Acute Hospital  Service,  remain  assigned  to those areas for service delivery in year.

The  H&SS  management  structure  is highly  likely  to  undergo  significant change with the appointment of a new Chief  Officer.  It  is  expected  that clearer  divisions  between  Acute  and Social Services will be created, further reducing  the  risks  of  direct  resource being transferred from Social Services to the Acute Hospital Services.

est. September 2010

2

Health and Social Services must know the true cost of all  services  provided,  in order that comparisons with the private sector costs can be  made.  Management should  look  to  outsource' areas where savings can be made  and  must  have adequate  financial management information to enable  reviews  of  this nature to be undertaken.

Accept

Whilst H&SS does not routinely cost the provision of all its services (e.g. as per  NHS  "Reference  Costs"),  all significant  business  decisions  should be supported by an appropriate level of financial information and analysis.

If a significant service is identified as having  potential  for  outsourcing  the H&SS  finance  team  calculates  the costs of providing the existing service (or an enhanced service) in the public sector  to  ensure  an  appropriate  cost comparison is available at the point of decision making.

Immediate

Findings

Comments

1

Court and Case costs are an  unpredictable  and volatile  drain  on taxpayers'  money. Therefore,  this expenditure  cannot  be budgeted  for.  However, these costs can present a significant financial risk for  a  small  island community  and  their volatility makes prudent financial  management difficult.

The Department agrees wholeheartedly with this observation. A further review of Court and Case Costs is to form part of the Comprehensive Spending Review and the Department will of course co-operate fully with that review. One suggestion that the Department will be making to that review is that the budget should be allocated to each department rather than being spread across the various departments that have a call on it. In that way, each department would be more accountable for its own expenditure and there would be greater transparency.

2

The Department finds it problematic  to  recruit and  retain  senior  staff due  to  a  lack  of competitive  salaries, particularly  at  a  senior level  where  staff  find substantial  incentives  to move  to  the  private sector.

The Department competes directly with the private sector for most legal staff. The Department is unable to offer the salaries and other benefits that are available in the private sector but it seems unlikely that this position will be altered in the near future given the current pressures on States expenditure overall.

3

The recruitment of staff may also be problematic due  to  the  potentially public nature of the role.

Recent high profile events and comments in the media and by politicians are unlikely to make this situation any easier.

4

Unlike  in  the  private sector, the Law Officers' Department  has  no financial  incentive  to optimise  staff  time against  projects. However,  time management  is  vitally important  for  adequate cost control.

The Department does have a time recording system to monitor the work of staff and the time taken to complete projects but the Committee is correct in its finding that there is no financial incentive to optimise staff time. It could be argued however that it is more important to provide the right advice rather than quick but wrong advice, even if this takes some time.

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

1

Prosecution  costs  in  the Magistrates Court should be recovered on an ability to pay' basis. A more holistic approach  to  court  costs needs  to  be  undertaken  as matters  such  as  legal  aid provision need to be taken into  account.  The  PAC recommends  that  the Judiciary  undertakes  an internal  review  of  its funding  requirements  and looks  towards  the commerciality  of  all functions provided.

Accept

The Department would welcome such a review and would support any that the Judiciary undertakes.

Unknown

2

A significant proportion of remuneration  is  provided through  the  provision  of  a generous  final  salary pension  scheme  that  may not be fully appreciated on a salary comparison basis. By aligning  the  remuneration package  more closely with the private sector, the ability to recruit may improve.

Reject

As  mentioned  above, the  Department competes  with  the  private  sector  for most legal staff and the ability to offer higher salaries would ease recruitment and  retention  problems.  It  is understood  by  the  Department  that most  private  sector  employers  in  the Island do provide a pension scheme for their employees although not on a final salary  basis.  However,  salary  levels and  pension  arrangements  are  not things that the Department can change unilaterally nor are higher salary levels likely to be acceptable in the present financial climate.

3

The  conflict  between freedom of information and professional  confidentiality needs  to  be  addressed. Ultimately,  the  ability  to undertake  a  task  to  the highest  standard  must  take priority  over  freedom  of information  as  it  is  in  the best interests of the public.

Accept

The Department fully agrees with this comment. Any Freedom of Information Law  is  likely  to  present  significant challenges to the Department. Some of its  information  will  be  legally privileged but some not, and it will be a significant additional burden deciding between them. It is also very likely that other  departments  will  use  the Department to advise on the release or otherwise of their own information. It is for this reason that the Department has  pointed  out  on  a  number  of occasions  that  if  a  Freedom  of

Information  Law  is  introduced,  then additional staff will be required in the Department  to  cope  with  the anticipated additional workload.

4

The  Law  Officers' Department  should  ensure that  workload  matches resources available and that work  is  prioritised appropriately.  States Departments  utilising  the services of the Law Officers for  low  priority  advice should  be  instructed  to obtain a response from the private  sector –  albeit  at  a cost  to  themselves.  The Department must operate a triage  system  and  when necessary,  advise  that  it may  be  in  the  interests  of the  client  to  seek  advice elsewhere.

Reject

The  Department  does  advise  other departments  to  take  advice  from  the private sector where it is appropriate to do  so  either  because  the  Department does not have the necessary expertise in-house, or the resources such as in Children's  matters  to  deal  with  the matter  itself,  or  where  there  is  a conflict such as when the Department is  prosecuting  another  States organisation. It should be noted though that the cost of such advice is likely to be  considerably  greater  than  if  the advice is provided by the Department, and  its  value  for  money  might  be questioned.  More  importantly,  the Department  does  feel  that  as  much advice should be provided from its own resources so that there is a consistent approach across the States. It would be unfortunate,  for  example,  if  private sector advice was provided to a States organisation which differed from that offered by the Law Officers answering a question from a States member.

Findings

Comments

1

There is still no States- wide anti-fraud policy.

Discussions have been held between the principal Departments tackling fraud identifying opportunities for working closer together, for example through the sharing of data, and further progress will be made in 2010.

In  the  meantime,  the  Department  has  invested  resources  in  further researching a revised Fraud strategy and actions intended to prevent and identify potential fraud. The strategy will be fully implemented in 2010 and further manpower resources have been provided for in the 2010 Business Plan.

2

The summary of income and  expenditure appearing  under  Social Security (on page 119 of the  2008  accounts)  is incomplete  because material  amounts  of expenditure  (including staff  costs  of approximately

£3.3 million) are charged directly  to  the  Social Security  and  Health Insurance funds.

A fuller picture of the activities of the Social Security Department has for sometime been available in the Report accompanying the GAAP compliant Financial Statements of the Social Security, Social Security Reserve and Health Insurance Funds.

However the particular requirement of the PAC finding has now been addressed and in the Social Security Departmental Pages of the 2009 States Report and Accounts. Staff costs are reflected gross in the under the Social Security Department with a charge made to the Social Security Fund and Health Insurance Fund.

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

1

The  Committee  believes that benefit fraud should be treated  with  more  urgency as it is a problem that we are  experiencing  now  (not in 2011). Benefit fraud is a significant  drain  on taxpayers'  money  and  it should  be  prioritised  more highly.

Benefit  fraud  is  regarded  as  an important  matter  by  the  Department and  further  improvements  are  being addressed  as  a  priority  by  the Department.  A  revised  strategy  has been  agreed  which  seeks  to  improve controls  throughout  the  claims  and investigation process and reduce fraud and customer error.

The focus is to seek out and correct erroneous  claims  to  reduce  ongoing cost  and  deter,  detect  and  prevent fraud.

As  a  result  of  the  success  of investigations  in  2009,  further  posts have been allocated to the fraud team

Ongoing

Recruitment is expected to take

so that increased levels of investigative action  can  be  undertaken.  This  will include:  further  analysis  of  claims  to identify  potential  fraud;  setting  up  a fraud  hotline  and  raising  public awareness  of  fraud;  face  to  face interviews  in  the  claimant's  home  to verify  claim  discrepancies;  and, ultimately prosecution where intent has been  proven  (but  not  all  cases  are appropriate for this route).

place in April/May 2010

2

A summary of all overhead expenditure  for  the department  and  funds should be provided in future States Accounts analysed by the provider of those funds (i.e. States or the respective funds). This will allow users to  form  a  view  about  the efficiency  of  the Department  and  its  total operating  costs.  The problem of supplementation provisions  needs  to  be addressed  as  a  matter  of urgency.  The  PAC  was pleased  that  Proposition P.153/2009 was adopted on 18th  November  2009. However the PAC considers that  it  is  important  that  in addition to the question of funding,  there  is  also consideration  in  respect  of the  relevant  accounting practices.  Not  all governments  fund  Social Security  in  a  manner  as prudent  as  the  States  of Jersey  and  some  of  the concerns  are  in  relation  to the  relatively  short  notice under  which  funding  must be applied. If, for example the  funding  requirement  is in  arrears  on  a  two  year retrospective basis, financial planning can be undertaken without  an  element  of nasty surprises.'

Accept

Accept

Actioned in 2009 States Report and Accounts

The  Department  has  identified  a method  by  which  the  cost  of supplementation  can  be  made  certain for  any  particular  year  and  an assessment of that proposal has been made by the Government Actuary and their Report issued in 2009.

That method will be proposed (or an effective alternative) once decisions in respect  of  the  future  of supplementation  are  decided  upon, further to the Fiscal Strategy Review.

Findings

Comments

1

The  Committee  is concerned  that  central findings  in  2008/2009 may be repeated due to structural  deficiencies. The  poor  financial management  of  the Energy  From  Waste exchange  rate  strategy and  issues  of  an emotional  nature  (such as pandemic flu funding and  the  historic  abuse enquiry)  will  ultimately impact on the tax payer who  will  suffer  higher taxes  and/or  reduced services as a result.

Implementation of the Treasury Restructuring Plan is now underway with  the  purpose  of  bringing  about  improvements  in  financial management both in the Treasury and across all States Departments.

2

It is very difficult, if not impossible,  to satisfactorily  examine the States Accounts, due to  the  complications inherent  in  comparing budget and actual arising from the switch towards impending  GAAP Accounting.

Further improvements will be made in the 2009 report and accounts to enable  comparison  of  the  actual  out-turn  against  budget.  These improvements  are  based  on  International  Public  Sector  Accounting Standard (IPSAS) 24, "Presentation of Budget Information in Financial Statements".

3

As  the  Treasurer observed, we still have a long way to go.' The issuance  of  Financial Directions which are not acted  on  demonstrates that  a  rather  wayward and  uncertain  system currently  operates. Controls  and  insistence on  compliance  by  the centre are lacking.

A key element of the Treasury Restructuring Plan is an increased focus on  financial  standards  and  compliance  with  these  standards  and procedures across all States Departments.

4

The  Treasurer  of  the States  did  not  seem  to fully understand his role and  saw  himself  as something more akin to the States accountant.

The  Treasury  Restructuring  Plan  demonstrates  the  importance  the Treasurer places on his role in respect of leading and improving financial management across the States.

5

For  a  small  island jurisdiction  it  is important  that  all liabilities  are professionally  managed and  contained.  Whilst measures  have  been taken, it is questionable whether  continuation  of a  final  salary  based scheme is either feasible or achievable.

The review of terms and conditions of employment proposed as part of the comprehensive spending review in 2010 will cover a wide range of current benefits including pension provision. Nonetheless, a small island jurisdiction such as Jersey still needs to be able to provide a level of service expected by the wider community. It is, therefore, vital that the Island remains competitive in terms of recruitment and retention for such groups as consultants, doctors, nurses, other health professionals, social workers, teachers, etc. The public sector pension schemes in Jersey are already less valuable than many of those still available to public sector employees in the UK.

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

1

Whilst the PAC are pleased that  the  Minister  for Treasury and Resources has acknowledged  significant deficiencies  in  his Department, and support his endeavours in this area, we recommend  that  the  whole structure  of  responsibility for financial management is reviewed on a holistic level with  greater  emphasis  on financial  control  and accountability  across  the public sector. Open cheque book policies, regardless of circumstances,  must  be discouraged.

Accept

The  implementation  of  the  Treasury Restructuring  Plan  is  now  underway. The creation of a Director of Finance role  to  direct  and  oversee  financial management  across  all  States operations  encompasses  the recommended holistic view of financial management, procedures and control.

2010

2

The  move  to  GAAP compliant  accounting should  be  accelerated.  In addition,  trading  entities such as the Airport should provide proper accounts in order that performance can be  measured  against  other entities worldwide.

N/A

The move to GAAP accounting cannot be  further  accelerated –  it  has progressed  in  accordance  with  the planned  timetable  and  is  now  in operation. States departments are now preparing  their  accounts  on  a  GAAP basis.  Trading  Departments  are  also preparing GAAP-based accounts.

2010

3

The  re-organisation  of  the Treasury  structure  should alleviate some of the areas of concern. However, there have  to  be  controls  to ensure  that  all  Financial Directions are implemented in  full  by  all  relevant Departments.  All  Financial Officers  should  sign  off each  Financial  Direction and give an undertaking that it will be implemented.

Accept

A  key  element  of  the  Treasury Restructuring  Plan  is  an  increased focus  on  financial  standards  and compliance  with  these  standards  and procedures  across  all  States Departments.

Under  the  new  arrangements, compliance with financial controls will be overseen centrally by the Treasury. Departmental Finance Directors will be held  accountable  for  taking  action  to ensure that controls are complied with.

2010

4

The Treasurer of the States should  act  with  more independence, as prescribed by law, and be more vocal in  his  quest  to  keep  the States finances in balance. It is important that he is able to  provide  an  independent voice  free  from  undue influence from the Treasury Minister  and  other politicians.

Accept

The role of the Treasurer is enshrined in  the  Public  Finances  (Jersey)  Law 2005 and makes specific provision for his independence: "The Treasurer may not be directed on how a function of the office of Treasurer is to be carried out."

2010

5

The  PAC requires that the past  service  liability  be dealt  with  as  a  matter  of urgency. The PAC shall be reviewing  the  provision  of public  sector  pensions  in 2010  and  will  report  in more  detail  on  this important issue. The current rules assume that any deficit relating  to  the  service  of past  1987  members  is  not necessarily a liability for the States – it is a liability for members in the first place. This is generally dealt with by  amending  promised benefits.  The  scheme  is therefore  closer  to  a Defined  Contribution Scheme  than  many  might expect.  The  prudent approach would be to stop accrual of benefits under the old arrangements and move

Reject

The Past Service Liability was agreed with  the  scheme's  Committee  of Management  by  the  States  in  2005. The  States  considered  this  matter further in 2009 (P.110/2009).

The  accounting  treatment  adopted  in the States accounts is that agreed by the  States  auditors.  Values  disclosed are  calculated  independently  by  the States Actuary.

The  States  auditors  have  already considered the accounting treatment for the States pension schemes under UK GAAP  in  some  detail.  The  States auditors  will  review  the  accounting treatment  for  the  pensions  schemes again as part of their audit of the 2009 accounts.

to  a  simple  Defined Contribution  basis.  The financial engineering within the  Accounts  should  cease and  the  PAC  requests  that the States Auditors look to treat pension liabilities and surpluses on a similar basis rather than allow a disparity in accounting practices that is not reflective of the true position.