DETAILED FINANCIAL POLICIES INCLUDING THE … FINANCIAL POLICIES INCLUDING THE OPERATIONAL SCHEME OF ... with input from Neil Moore, ... the Operational Scheme of Delegation (and financial

Page 1 of 18 Review – Dec 2013

GB 15/054

DETAILED FINANCIAL POLICIES

INCLUDING THE OPERATIONAL SCHEME OF DELEGATION

MARCH 2015

VERSION 4

Version No

Author Date Comments Approved by

1

Clare

Hopewell

Nov 2012

Agreed with South Nottinghamshire CCGs’

Senior Management Team with input from Neil Moore,

Technical Procurement Lead

Accountable Officer and Governing Body at the

Governing Body Meeting on the 20

th November 2012


2

Clare

Hopewell

Dec 2013

Annual Review – South Notts CCG’s Senior Management and Finance Team and GEM

procurement expert

Accountable Officer and Governing Body at the

Governing Body Meeting on the 21

st January 2014

3

Clare

Hopewell

May 2014

Revision Section 3c in light of the internal audit report “Key Financial Systems &

Payroll”

Governing Body meeting 20

th

May 2014

4. Hazel Buchanan

Mar 2015 Revised to align delegation across roles relative to

responsibilities in operational scheme of

delegation

Introduction ............................................................................... Error! Bookmark not defined.

Background ............................................................................... Error! Bookmark not defined.

Detailed Financial Policies ...................................................... Error! Bookmark not defined.

1. Custody of Seal, Sealing of Documents and Signature of DocumentsError! Bookmark not defined.

2. Budgetary Delegation and Budgetary Control & ReportingError! Bookmark not defined.

3. Tendering and Contracting .................................... Error! Bookmark not defined.

4. Payroll ........................................................................ Error! Bookmark not defined.

5. Non-Pay Expenditure .............................................. Error! Bookmark not defined.

6. Disposals and Condemnations, Losses and Special PaymentsError! Bookmark not defined.

7. Acceptance of Gifts by Staff and Link to Standards of Business ConductError! Bookmark not defined.

Appendix 1 – Operational Scheme of Delegation ................................................................. 3


Appendix 1 – Operational Scheme of Delegation

1.1. The arrangements made by the CCG as set out in the Overarching Scheme of Reservation and Delegation of decisions shall

have effect as if incorporated in the CCG’s Constitution.

1.2. The CCG remains accountable for all of its functions, including those that it has delegated.

1.3. Appendix D of the Constitution is the Overarching Scheme of Reservation & Delegation (Schedule of Matters Reserved to the CCG and Scheme of Delegation) and details the arrangements made by the CCG for discharging its functions.

1.4. The Schedule below details the Operational Scheme of Delegation (and financial authority limits). These should be read in

conjunction with the Prime Financial Policies (Appendix E of the Constitution).

1.5. This is prepared by the Accountable Officer and sets out those key operational decisions delegated to individual employees of the CCG (it is not for inclusion in the CCG’s Constitution).

1.6. The approval of the CCG’s Operational Scheme of Delegation that underpins the CCG’s “Overarching Scheme of

Reservation and Delegation” as set out in its Constitution, is reserved to the Governing Body.


Ref Matter delegated Delegated to Reference Documents

1

Management of Budgets (responsible for keeping pay and non-pay expenditure within approved budgets and retaining income levels)

Approval of Budgets Level of delegation to CCG Senior Management Team Level of delegation to Budget Managers Responsibility for maintaining expenditure within approved budgets:

(a) at individual budget level (pay and non-pay) (b) for the totality of services covered by the area (c) for all other areas e.g. Reserves

Approval to Spend Monitoring of Financial Performance Delegated Virement Limits Approval of overspends or reductions in income that can not be met by virement Staff establishment changes.

Governing Body (see overarching Scheme of Delegation) Accountable Officer (AO) CCG Senior Manager (8c and above) (a) Designated budget holder (b) CCG Senior Manager (8c and above) (c) Chief Finance Officer (CFO) Budget Holder/Manager is permitted to incur costs in accordance with their budgets & authorisation limits (see Section 3 below) CFO Virements within a budget holders approved budget are permitted in accordance with virement rules. CFO

Prime Financial Policies S.7 Budget Managers Manual Detailed Financial Policies S.2



2

Bank accounts

Opening of new (Government Banking Services) Bank Accounts Notification of changes to banking arrangements, with the exception of changes in signatories Banking procedures

Approved by the CFO and reported to the next Governing Body meeting. Approved by the CFO and reported to the next Governing Body meeting. CFO

Prime Financial Policies S.11



3a

Revenue Administrative (Non Commissioning Spend) Spend on Goods and Services - Limits for Requisition and Invoice approval, includes procurement of professional services ie legal advice, specialist advice, specific projects (all values are inclusive of VAT irrespective of whether this is reclaimable or not):

(a) up to £10,000 (b) from £10,001 to £50,000 (c) from £50,001 to £75,000 (d) from £75,001 to £100,000 (e) from £100,001 to £250,000 (f) from £250,001 to £500,000 (g) £500,001 and above

Procurement of Professional Services (additional controls are required due to the need to closely monitor Running Costs) Delete and include above – not clear why separate

(a) Legal Advice (b) Specialist advice e.g. IT, clinical enquiries (c) Specific Projects e.g. specific reviews

In line with budget management responsibilities (i.e. delegated budgets) and subject to quoting & tendering as required (see Section 5 below):- (a) Band 7 and above (b) Band 8a and above (c) Band 8b and above (d) Band 8c and above (e) AO or CFO (f) AO and CFO (g) AO, Following Governing Body Approval

(a) AO or deputy AO (b) AO or deputy AO (c) AO or CFO

Budget Managers Manual Detailed Financial Policies S.2 & S.3


3b

Revenue Programme Spend: Commissioning contracts with Providers including other NHS bodies, contracts with Foundation Trusts, and partnership agreements with local authorities

(a) For the commissioning of NHS healthcare services:

(i) up to £999,999 (contract variation up to £99,999)

(ii) from £1m to £4,999,999 (contract variation £100,000 - £499,999)

(iii) from £5m to £50m (contract variation £500,000 - £999,999)

(iv) above £50m (contract variation £1m or more)

(b) For the commissioning of non-NHS healthcare services: (i) up to £99,999 (contract variation up to £9,999) (ii) from £100,000 to £499,999 (contract variation

£10,000 - £49,999) (iii) from £500,000 to £5m (contract variation

£50,000 - £500,000) (iv) above £5m (contract variation above £500,000)

(c) For the provision of non-healthcare services:

(i) up to £14,999 (contract variation up to £999) (ii) from £15,000 to £99,999 (contract variation

£1,000 - £4,999) (iii) from £100,000 to £499,999 (contract variation

£5,000 - £24,999) (iv) above £500,000 (contract variation above

£25,000)

For (a)(b)

(i) Equivalent of two senior managers (8c and above) one of whom must be from Finance (ii) Director of Contracting, Chief Officer or Deputy Chief Officer and CFO (or Deputy Chief Finance Officer) (iii) AO and CFO (iv) AO, after approval by Governing Body

For (c) (i)Equivalent of two senior managers (8c and above) (ii) Equivalent of a senior manager and CFO or senior Finance manager (iii) and (iv) AO and CFO



3b

(d) For the provision of primary care services (per provider):

(i) up to £14,999 (contract variation up to £999) (ii) from £15,000 to £99,999 (contract variation £1,000 -£4,999) (iii) from £100,000 to £499,000 (contract variation £5,000 - £24,999) (iv) above £500,000 (contract variation above £25,000)

For (d) (i) Equivalent of two senior managers (8c and above) (ii) and (iii) Primary Care Commissioning Committee (iv) Primary Care Commissioning Committee and AO


3c

Commissioning expenditure: payments under SLA, contracts with Foundation Trusts, or partnership agreements with local authorities:

(a) up to £499,999

(b) from £500,000 to £5 million

(c) from £5,000,001 to £10 million

(d) £10,000,001 and above (Note there are limitations to the CCG’s financial systems in respect of 3a & 3c, therefore additional internal controls have been implemented – see Budget Managers Manual)

a) Senior Manager (8c and above)

b) Director of Contracting or Deputy Chief Officer

c) CFO or Deputy CFO or AO

d) CFO

Budget Managers Manual Detailed Financial Policies S.2

4

Capital schemes

(a) Appointment of architects, quantity surveyors, consultant engineers and other professional advisors within EU regulations.

(b) Granting, terminating or extending leases with an

annual charge of: (i) up to £99,999 (ii) £100,000 and above

(a) Senior Manager (8c and above) (b) Deleted reference to prop co

(i) CFO (ii) AO & CFO



5

Quotation, Tendering & Contracting Procedures Limits for quotes, tenders & EU procurement for all Budget Holders (all values are inclusive of VAT irrespective of whether this is reclaimable or not):

(a) up to £9,999

(b) from £10,000 to £49,999 (annual contract value) obtaining at least 3 written competitive quotations for goods/services.

(c) from £50,000 to £101,322. Decision for quotations or tender to be made by two senior managers and CFO

(d) £101,323* and above * values vary according to Euro/Sterling conversion

(e) Responsibilities in the Tendering Process:-

Issuing of tender documentation

Receipt and custody of tender documentation

Opening of Tenders

Post tender negotiation

(a) Delegated Budget Manager responsibility (b) Budget Managers and Senior Managers (c) Quote or formal tender process – senior managers (8c and above) and CFO (d) EC tendering limit: OJEC procurement process to be applied (e)

Per authorised limits

Accountable Officer or his/her nominated representative.

2 senior managers designated by the Accountable Officer and not from the originating department. A CCG Director should be one of the two, where the tender is estimated to be in excess of £100,000. At least three of the lowest (highest if sale) tenders shall be informed that the Governing Body wishes to enter into post offer negotiations. Each of the offerors shall be invited to attend a separate meeting at the CCG Headquarters. Negotiation with each offeror may continue over a series of meetings and the offeror, in writing, shall confirm any amendments finally negotiated.

Detailed Financial Policies S.3


Acceptance of tender other than lowest.

Single Quote Authorisations

Single Tender Authorisations

Waiving of quotations/tenders subject to SO’s

Accountable Officer (reported to the Governing Body). Reasons for acceptance set out in a permanent record.

Accountable Officer or Chief Finance Officer. Where only one quote is sought/received the CCG shall as far as practical, determine that the price to be paid is fair and reasonable and details of the investigation recorded.

Accountable Officer or Chief Finance Officer. Where only one tender is sought/received the CCG shall as far as practical, determine that the price to be paid is fair and reasonable and details of the investigation recorded.

Accountable Officer or Chief Finance Officer with delegated responsibility (to be reported annually to the Audit Committee)

Detailed Financial Policies S.3

6

Setting of Fees and Charges Fees and Charges e.g. course fees, private use of NHS equipment and facilities (photocopying, rooms)

CFO



7

Personnel & Pay

Engagement of Staff not on the establishment (a) Authority to appoint staff to post not on the formal

establishment (b) Authority to permanently amend the formal establishment (c) All Non-Medical Consultancy Staff where aggregate

commitment in any one year (or total commitment) is less than £20,000

(d) Other than (c) where aggregate commitment in any one year (or total commitment) is greater than £20,000

(e) Engagement of CCG’s solicitors (f) Booking of bank staff from approved lists (g) Booking of agency staff (h) Authority to fill funded post on the establishment with

permanent staff

Payroll Forms (i) Authority to complete standing data forms effecting pay,

new starters, variations and leavers (j) Authority to authorise overtime, travel claims and study

leave and associated expenses (k) Renewal of Fixed Term Contract Other Personnel & Pay Issues (l) Staff Retirement (m) Redundancy (n) Dismissal (o) Requests for upgrading/re-grading (p) Approval of Changes to Allowances paid to Employees(i.e.

Not included within & subject to Whitley Council Regulations)

(q) Removal Expenses, Excess Rent & House Purchases

(a) Senior Manager (8c and above) & Senior Manager Finance (b) AO and CFO (c) Senior Manager (8c and above) (d) AO or CFO (e) Senior Manager who is Governance Lead (f) Senior Manager (8c and above) (g) Senior Manager (8c and above) (h) Budget Holder within overall financial budget (i) Budget Holders & Senior Manager Finance within overall financial budgets (j) Budget Managers (in line with policy) (k) Senior Manager (8c and above) and Senior Manager Finance (l) In line with Policy (m) In line with Policy (n) In line with Policy (o) In line with procedure (p) RATs Committee (q) AO and CFO

Detailed Financial Policies S.3 For (a) and (b) an Establishment Change Form must be completed. (deleted policy) Travel & Expenses Policy for Staff, and, Flexible Working Policy Retirement Policy Workforce Reduction, Redundancy & Redeployment Policy Disciplinary Policy & Procedure


8

Agreements/Licenses

Preparation and signature of tenancy agreements/licenses Extensions to existing leases Letting of premises to outside organisations Approval of rent calculation

CFO (All delegations subject to prior approval by NHS Property Services/NHS England as required).

Detailed Financial Policies S.3 Prime Financial Policies S.12

9

Condemning & Disposal

Items obsolete, obsolescent, redundant, irreparable or cannot be repaired cost effectively.

(a) With current purchase price < £250 (b) With current purchase new price < £250

(c) Disposal of mechanical and engineering plant

(a) Budget Holder

(b) Senior Manager (8c and above)

(c) Chief Finance Officer

Detailed Financial Policies S.8 Losses & Special Payments Procedure


10

Losses, Write-off & Compensation

Losses (a) Losses and Cash (due to theft, fraud, overpayments and

others) (b) Fruitless Payments (including abandoned Capital

Schemes) (c) Bad Debts and Claims Abandoned (Private Patients,

Overseas Visitors & Other) (d) Damage to buildings, loss of equipment and property (

culpable causes and other causes) Special Payments

(e) Compensation payments made under legal obligations (f) Extra Contractual payments to contractors (g) Ex-gratia payments:-

To patients and staff for loss of personal effects For clinical negligence (negotiated settlements following legal advice) where the guidance relating to such payments has been applied For personal injury claims involving negligence where legal advice obtained and relevant guidance has been applied Other clinical negligence cases and personal injury claims Other, except cases of maladministration where there was no financial loss by the claimant Maladministration where there was no financial loss by claimant (h) Extra statutory and extra regulatory payments

Necessary reporting to the NHS Commissioning Board for “novel, contentious or repercussive” cases or general lessons learnt in line with guidance.

(f) AO and CFO

(a) to (e) and (g) to (l) CFO or nominated deputy

Liaison with the CCG’s Local Counter Fraud Specialist & Police as required and in line with the CCG’s Fraud, Corruption & Bribery Policy. The CFO to report all categories to the Audit & Governance Committee quarterly in arrears for review. The CFO will report any cases they consider to be “novel, contentious or repercussive “ to the Chair of the Audit Committee Chair as soon as they become aware of the case. CFO (following recommendations from Audit & Governance Committee -“novel, contentious or repercussive” cases or general lessons learnt).

CCG’s Fraud, Corruption & Bribery Policy Losses and Special Payments Procedure


11

Reporting of Incidents to the Police

(a) Where a criminal offence is suspected

(b) Where fraud is involved

(a) AO/On Call Manager together (b) In accordance with advice from the CCG’s Local Counter Fraud Specialist

Detailed Financial Policies S.6 CCG’s Fraud, Corruption & Bribery Policy

12 Petty Cash Petty cash disbursements up to £50 per item

Petty cash float replenishment up to £500 per week

Designated budget holder Finance Senior Manager

Budget Managers Manual

13

Implementation of Internal and External Audit Recommendations

Actioning Officer as identified by Internal Audit and specified in individual audit reports. Overseen by Chief Finance Officer or nominated deputy and reported to the Audit (& Governance) Committee

Audit Committee Terms of Reference

14

Maintenance & Update of CCG’s Financial Policies and Procedures To be reviewed on an annual basis

Chief Finance Officer


15

Insurance Policies and Risk Management Risk Management Decision on what level of insurance arrangements will be maintained Claims

AO (in conjunction with the CCG’s Lead for Governance) CFO via NHS Litigation Authority AO (in conjunction with the CCG’s lead for Governance)

Prime Financial Policies S.15 Procedure for the Management of Claims


16

Medicines Management Delegated authority to the Nottinghamshire Area Prescribing Committee (APC) for making x commissioning decisions on the use of medicines. Decisions will be reviewed through the APC annual report.

APC

Agreed APC Mandate

17

Patients & Relatives Complaints Overall responsibility for ensuring that complaints are dealt with effectively Relationship with Press

AO or nominated deputy (in conjunction with the Director of Quality & Patient Safety) AO or nominated deputy

Guidance for conducting investigations of complaints, incidents and claims

18

Health and Safety (a) Review of Fire Precautions (b) Overall responsibility for Health and Safety (c) Establishment and maintenance of effective health and

safety policies, procedures and systems

(a) AO or nominated deputy (b) AO (c) Quality & Risk Committee (South)

19

Review of CCG’s compliance with the Data Protection Act and the establishment/responsibilities of a Senior Information Risk Owner

Director of Outcomes and Information

Confidentiality and Data Protection Policy

20

Monitor proposals for contractual arrangements between the CCG and outside bodies

AO

MOU – collaborative commissioning arrangements

21

Review the CCG’s compliance with the Access to Records Act – Caldicott Guardian

Director of Quality & Patient Safety

Subject access request procedure (health records) SAR procedure - non health records


22

Review of the CCG’s compliance with the Code of Practice for handling confidential information in the contracting environment and the compliance with “safe haven” per EL 92/60

Director of Outcomes and Information

Safe Haven Procedure

23

Keeping of a Declaration of Interests Register

CCG’s Lead for Governance

Conflicts of interest and declarations of interest policy

24

Keeping of a Register of Sealings (including Attestation)


Detailed Financial Policies S. 1

25

Signing of Documents Signing of legal agreements or other documents not required to be executed as a deed

Approved and signed by the AO (if absent by the CFO or any other CCG Senior Manager not associated with the originating department prior to sealing).

Detailed Financial Policies S. 1

26

Keeping of the Gifts and Hospitality Register


Gifts & Hospitality Policy

27 Management of Land, Buildings and other Assets owned or leased by the CCG (in conjunction with PropCo)

Maintenance of Asset Register Maintaining legal documents of Title (including Leasehold) Inventory for items less than £5,000

AO AO Budget Managers



28

Maintenance and Control of Computer Systems and Facilities Financial data and Accounting systems Other Computer Systems

CFO Director of Outcomes & Information

Prime Financial Policies S.9 & S.10

29

Emergency Planning

(The Department of Health defines a major incident as “an event or a situation which threatens serious damage to human welfare in a place in the UK, the environment of a place in the UK, or war or terrorism which threatens serious damage to the security of the UK.”)

The Finance Representative on the incident team during a major incident has delegated authority to incur any necessary expenditure as agreed by the team.

The On Call Manager has delegated authority to make urgent financial decisions relating to both the CCGs within the CCG unit of planning and other NHS organisations within the health community as appropriate during a major incident.

Major Incident Plan/On Call Handbook