Full Implementation of
Management and Financial Audit (MFA)
Sharing on Audit Findings - Management Aspects
2017/18
School Administration 3 Section
5 October 2018
MFA ‐ Four Specific Aspects
General Administration of the School Management Committee (SMC)/ Incorporated Management Committee (IMC)
Human Resources and Personnel Matters
Financial Management Matters
Fee Remission/ Scholarship Schemes
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Major Observations –
General Administration of SMC/IMC (1)
Declaration of Conflict of Interest
Major observations:
School-based policy/procedures for school personnel, including managers and staff, were not in place and/or not endorsed by SMC/IMC
Records of declarations not properly kept/
documented
No proper records of the resolution regarding the
declaration made by staff and necessary actions
taken
Major Observations –
General Administration of SMC/IMC (2)
Declaration of Conflict of Interest
Recommendations:
Draw up school-based policies/procedures to require SMC/IMC members and/or staff to declare conflict of interest, which should be deliberated and endorsed by SMC/IMC
Keep proper records of all declarations made verbally or in writing (using a standard form)
Properly record the necessary actions taken together with considerations to all the declared conflicts, such as refraining from handling the duties, reasons for the declarant to continue to discharge the duties, etc.
Reference: EDBC No. 17/2012 (Para 4 and Annex 1)
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Major Observations –
General Administration of SMC/IMC (3)
HR Management
Major observations:
not endorsed by SMC/IMC
did not cover non-teaching staff
did not cover major aspects such as recruitment, promotion, appraisal, remuneration packages
not promulgated to all staff Recommendations:
School-based HR policies, including staff recruitment, remuneration, appraisal, promotion, disciplinary procedures and staff complaint, should:
cover all paid staff
be properly documented and endorsed by SMC/IMC
be updated regularly and made known to all staff for
Reference:
• EDBC No. 17/2012 (paras 2 and 5)
• ICAC’s “Best Practice Checklist:
Governance and Internal Control in Schools"
Major Observations –
General Administration of SMC/IMC (4)
Quality Assessment and Compliance – School
Development and Accountability (SDA) Framework
Major observations:
No records of SMC/IMC’s endorsement on the School Development Plan, Annual School Plan or School Report
No records of SMC/IMC’s discussion and endorsement of school’s reply to the Comprehensive Review/ External School Review reports
No records of SMC/ IMC’s discussion on the management/ advisory/
warning letter(s) issued by the EDB Recommendation:
Put up self-evaluation under the SDA Framework to their SMC/IMC for discussion and approval
Reference: EDBC No. 7/2012 (para 15) “Essential items to be discussed at the SMC/IMC meetings”
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Major Observations –
General Administration of SMC/IMC (5)
Quality Assessment and Compliance – SMC/IMC composition Major observations:
SMC/ IMC did not comprise all the stakeholders as managers as required in the Service Agreement/ Education Ordinance
SMC/IMC composition did not fulfil the requirements in the Memorandum and Articles of Association/ the Education ordinance
Managers not registered in accordance with the EDB’s requirements
Recommendations:
Fulfil the requirement in accordance with the SMC/IMC’s Memorandum &
Article of Association, Constitution and/or Service Agreement
The SMC shall be responsible for ensuring that the school is managed satisfactorily and the education of the pupils is promoted in a proper manner in accordance with section 32 and 33 of the Education Ordinance, Cap. 279 Reference: Section 27 of the Education Ordinance, Cap. 279 “No person shall act as a manager of a school unless he is registered as a manager of the school
Major Observations –
General Administration of SMC/IMC (6)
Quality Assessment and Compliance – Additions, alterations or improvement works
Major observation:
No records of prior EDB’s approval for additions,
alterations or improvement works at the school premises
Recommendation:
To obtain prior EDB’s approval
Reference
SSB/IMC/SMC Service Agreement - Conditions for Admission to the DSS:
“Any application for additions, alterations or improvements to the school premises for which approval by the Government is required shall be submitted in duplicate to the Government for approval, and copied to the Director of Architectural Services/Director of Housing.”
Regulation 10 of the Education Regulations, Cap. 279A: “Except with the consent in writing of the Permanent Secretary there shall not be made -
(a) any structural alterations to the school premises” 8
General Administration of SMC/IMC (7)
Advice on the Operation of Governance Review Sub-committee (GRSC):
Self-evaluation Checklist (ALL four parts)
should be completed by schools by end-November and forwarded to GRSC annually
GRSC should review the completed checklist and submit its findings together with recommendations to the SMC/IMC for consideration
Review schedule: 3 domains should be spread within a three-year cycle
Restricted sessions should be arranged to finalize reports/
findings
Example:
Complete the
2017/18 Checklist by November 2018
Major Observations –
Human Resources and Personnel Matters (1)
Staff Recruitment
Major observations:
No open recruitment
No proper records throughout different stages of staff selection process (e.g. first interview, final interview, trial teaching, etc.)
No records showing the use of pre-set assessment criteria at different stages of staff selection (e.g.
screening applications, first and final interview, trial teaching/ other test, etc.)
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Major Observations –
Human Resources and Personnel Matters (2)
Staff Recruitment
Recommendations:
Conduct staff recruitment in a transparent, fair and open manner
Draw up policies and procedures on staff recruitment, which include pre-set criteria for shortlisting and assessing candidates
Keep proper records throughout the selection process
Check if there is/ are school-based policy/ procedures on handling of staff grievances/ complaints
Reference:
• “Recommendations on
Administration of Teaching Staff in Schools under DSS” from ICAC in the EDB’s circular letter dated 21.5.2007
• ICAC’s “Best Practice Checklist:
Governance and Internal Control in Schools”
• Guidelines for Handling School Complaints (Revised on 30.5.2018)
• Item 6.3.9 of ICAC’s “Best Practice Checklist: Governance and Internal Control in Schools”
• Item 4.4.1 of School
Administration Guide
Major Observations –
Fee Remission/Scholarship Schemes (1)
Criteria for Awarding Fee Remission
Major observations:
Adopted eligibility benchmarks less favorable than those of the government financial assistance schemes owing to:
more levels of assistance (e.g. 25%, 50%, 75%, 100%) with disposable family income falling into ranges which lead to a lower granting;
AFI thresholds for full level of assistance adjusted for 3 and 4- member families not being included;
30% of annual income of unmarried child(ren) residing with family not being included or percentage increased; and
Composition of income including items outside the list set out by SFO e.g. Provident Fund/ MPF, gratuity, retraining allowance.
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Major Observations –
Fee Remission/Scholarship Schemes (1)
Criteria for Awarding Fee Remission (con’t)
Major observations:
Students not granted fee remission or granted fee remission less favorable than government financial assistance scheme owing to:
miscalculation;
school’s own discretion after home visit/ interview; and
no provision of space in application form for fee remission
for putting down all family members.
Major Observations –
Fee Remission/Scholarship Schemes (2)
Criteria for Awarding Fee Remission
Recommendations:
The set of eligibility criteria should be no less favorable than the government financial assistance schemes across all levels of remission
Establish a check and balance mechanism to ensure that fee remission is offered in accordance with the school-based eligibility criteria, which should be no less favourable than the government financial assistance schemes for needy students.
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Link to SFO’s website:
http://www.wfsfaa.gov.hk/sfo/en/primarysecondary/tt/general/assessment.htm
Fee Remission/Scholarship Schemes (3)
Advice on adoption of eligibility criteria:
Review school-based eligibility criteria regularly
Consult and seek endorsement from SMC/IMC for any revisions of eligibility criteria
Set up a mechanism to check against the results of school-based assessment with students’ eligibility for Comprehensive Social Security Assistance and SFO result – to uphold the no less favorable principle
Apply to EDB for exemption from the requirement to
adopt eligibility criteria for fee remission scheme no less
favorable than those of government financial assistance
schemes, if required, after seeking SMC/IMC’s approval
Major Observations –
Fee Remission/Scholarship Schemes (4)
Publicity
Major observations:
No records of consultation with the SMC/ IMC or PTA on the publicity of the fee remission scheme
No sufficient transparency as required under paragraph 5 of EDBC No.
10/2012
Recommendations:
Application form for admission, letter offering admission, school website, school profile and prospectus (along with their attachments) should include where appropriate:
Details - school fee, eligibility criteria and levels of remission
Clear statement - needy students including those receiving assistance under CSSA and SFO could apply & be eligible for fee remission
Contact information – designated telephone number for enquiry 16
Fee Remission/Scholarship Schemes (5)
Advice on publicity:
If for environmental reasons, the SMC/IMC and PTA find it will suffice to provide on the application form for admission, letter of offer, prospectus, etc.
a hyperlink through which details of the schemes can be obtained from the school website,
state clearly on the above admission documents that information sheet containing details of the schemes is available upon request
attach the information sheet to the application form for admission and letter of offer on a need basis
If general enquiry telephone number is provided,
ensure that parents’ enquiries on the schemes will be handled by designated staff members.
Points to note:
Consult parents on how the related information should be presented to ensure that it can be easily
understood by parents/
prospective parents
Points to note:
Consult parents on how the related information should be presented to ensure that it can be easily
understood by parents/
prospective parents
Fee Remission/Scholarship Schemes (5)
Advice on publicity (con’t):
When being notified of students’ application results for financial assistance from SFO,
ensure eligible students are provided with an application form for fee remission.
To review school’s publicity of the schemes regularly,
refer to the updated Checklist on the Operation of the Fee Remission/ Scholarship Schemes in the Management Toolkit
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SMC/IMC managers were required to declare any actual or perceived conflict of interest over the agenda of meetings before start, to determine if the member(s) concerned needed to withdraw from relevant session(s) of the meeting when it came to discussing the issue(s)
Declaration was recorded in SMC/IMC minutes
Broad coverage of staff declaration on any direct or indirect interests in:
any organization which had business dealings with the school;
any kinship with the students and staff at school;
any kinship with prospective students during student admission; and
any kinship with candidates in a recruitment exercise (including interview and preparation for remuneration packages for the newly appointed staff)
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Provision of major vendor list available in shared drive for staff to refer to when completing the annual declaration form (regarding procurement) to minimize negligence in reporting any actual or perceived conflict of interest at best efforts
Detailed design of the staff annual declaration form with three parts to show a clear procedure of handling
Part 1: to indicate the different types of conflict of interest;
Part 2: to provide practical resolution choices for the school
Part 3: to invite acknowledgement from the declarer.
Situation:
Remunerated SMC/ IMC members (Principal and teacher manager) proposed or seconded resolutions related to staff salary scales and staff benefits/ performance bonus at the SMC meeting.
Justification:
The Principal could provide most accurate information about the school’s situation to facilitate the stipulation/
revision of any (new) policies or scheme.
He had to know about the decision passed at the SMC meeting and notify school staff.
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The remunerated SMC/ IMC members should withdraw from the SMC/ IMC meeting over the discussion item of school’s remuneration.
Points to note:
According to Memorandum and Articles of Association, which stipulates that:“A remunerated Director shall not be entitled to attend and vote at all meetings and discussions concerning his own appointment, conditions of service and remuneration”.
Points to note:
According to Memorandum and Articles of Association, which stipulates that:“A remunerated Director shall not be entitled to attend and vote at all meetings and discussions concerning his own appointment, conditions of service and remuneration”.
Human Resources and Personnel Matters Sharing on good practices
Separate sets of selection criteria to assess candidates:
for teaching and non-teaching positions respectively
in different stages of selection process, e.g. trial teaching/ skill tests, 1
stinterview, final interview, etc.
Job advertisement posted on the school website apart from newspaper to ensure high transparency of the open recruitment.
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Background/ Situations behind the absence of open recruitment and assessment records
1. The staff member had been hired as a supply teacher in the previous year and he was ‘transferred’ to a full‐time position in the current year.
2. It was too hard to hire a person for such position e.g. janitor due to a high turnover rate and thus recommendations or referral by internal staff or contact persons (persons of acquaintances) in the relevant fields was the final.
3. There was only one candidate left after shortlisting as all other applicants did not fit the job requirement. The school found the candidate suitable for the job after interview while no assessment records were kept.
Schools should ensure that staff recruitment is conducted in a transparent, fair and open manner, and there should be proper staff recruitment procedures in place with SMC/IMC’s endorsement.
Advertise job vacancies publicly
Assessment of even one candidate should be properly documented throughout the whole selection process.
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Very scrupulous vetting procedures, including the provision of different income certification forms for applicants of different employment nature, as well as the requirements for applicants to make declaration on the provision of their information and to submit a letter of consent for income check.
Websites, guidance notes and application forms for
fee remission and prospectus which contained the
information about the fee remission scheme were
provided with bilingual versions to cater the different
language needs of parents.
Fee Remission/Scholarship Schemes
Government financial assistance schemes (1):
Extracts of SFO’s website:
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Fee Remission/Scholarship Schemes
Government financial assistance schemes (2):
Fee Remission/Scholarship Schemes Case study 1
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Remission
Levels SFO’s benchmark ($) (3/4-member families)
100% 0 - 38603
(46733 / 43995)
75% /
50% 38604 - 74644
25% /
Ineligible > 74644
School-based scheme ($)
0 - 40000
40001 - 51000 51001 - 69000 69001 - 79000
> 79001
Fee Remission/Scholarship Schemes Case study 1 (assessment)
Remission
Levels SFO’s
benchmark ($) (3/4-member
families)
School-based
scheme ($) Assessment
100% 0 - 38603
(46733 / 43995) 0 -
4000075% /
40001- 51000
50% 38604 - 74644 51001 - 69000
25% / 69001 - 79000
Ineligible > 74644 > 79001
69001 - 74644 69001
- 79000
38604 -
74644
40001 – 46733/ 43995
Fee Remission/Scholarship Schemes Case study 2
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Policy of a school:
Salary (including salary of applicant, applicant’s spouse and student-applicant’s unmarried sibling(s) residing with the applicant for full-time, part-time or temporary jobs, contributions to Provident Fund/ MPF)
