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(1)

Management and Financial Audit (MFA)

Sharing on Audit Findings - Management Aspects

2016/17

School Administration 3 Section

29 September 2017

(2)

MFA - Four Specific Aspects

 General Administration of the School Management Committee (SMC)/

Incorporated Management Committee (IMC)

 Human Resources and Personnel Matters

 Financial Management

 School Fee Remission and Scholarship Schemes

2

(3)

Major Observations:

Management Aspects

General Administration of SMC/IMC

Declaration of Conflict of Interests

HR Management

Quality Assessment and Compliance

HR and Personnel Management

Staff Recruitment

Fee Remission/Scholarship Scheme

Criteria for Awarding Fee Remission &

(4)

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 endorsed by

SMC/IMC

Records of declarations not properly kept

No proper records of the resolution regarding the declaration made by staff and necessary actions taken to avoid conflict of interest

4

(5)

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 (preferably 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.

Major Observations –

General Administration of SMC/IMC (2)

(6)

HR Management

Major observations:

HR policies were not endorsed by SMC/IMC

HR policies did not cover all paid staff (teaching and non-teaching; part-time and full-time)

Staffing/grade structure and remuneration policy for staff were not in place

Major Observations –

General Administration of SMC/IMC (3)

6

Points to note:

part-time staff ≠ temporary staff

(7)

HR Management

Recommendations:

School-based HR policies, including staff recruitment, remuneration, appraisal, promotion and disciplinary procedures, should:

cover all paid staff

be properly documented and endorsed by SMC/IMC

be updated regularly and made known to all staff for transparency

Reference:

EDBC No. 17/2012 (paras 2 and 5)

Independent Commission Against Corruption’s

Major Observations –

General Administration of SMC/IMC (4)

(8)

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 of the

Comprehensive Review/ External School Review reports and endorsement of school’s reply to the report

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”

Major Observations –

General Administration of SMC/IMC (5)

8

(9)

Quality Assessment and Compliance – SMC/IMC composition Major observations:

SMC did not comprise all the stakeholders as managers as required in the Service Agreement

The SMC was not functioning as expected

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

Major Observations –

General Administration of SMC/IMC (6)

Reference: Section 27 of the Education Ordinance, Cap. 279 “No person shall

(10)

Quality Assessment and Compliance – Additions, alterations or improvement works

Major observation:

No records of prior EDB’s approval for additions, alterations or improvement works in school premises

Recommendation:

To obtain prior EDB’s approval

Major Observations –

General Administration of SMC/IMC (7)

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” 10

(11)

General Administration of SMC/IMC

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 submitted its findings together with recommendations to the SMC/IMC for consideration

Restricted sessions should be arranged to finalize reports/findings

Example:

Complete the

2016/17 Checklist by November 2017

(12)

Major Observations:

Management Aspects

General Administration of SMC/IMC

Declaration of Conflict of Interests

HR Management

Quality Assessment and Compliance

HR and Personnel Management

Staff Recruitment

Fee Remission/Scholarship Scheme

Criteria for Awarding Fee Remission &

Publicity

12

(13)

Major Observations –

HR & Personnel Management (1)

Staff Recruitment

Major observations:

No open recruitment

No proper records throughout different stages of staff selection process (e.g. final interview, trial teaching, etc.)

No records showing the use of pre-set criteria to assess candidates at different stages of staff

selection (e.g. screening applications, interview, etc.)

(14)

Major Observations –

HR & Personnel Management (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 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” 14

(15)

HR & Personnel Management

Other reminder:

Check if there is school-based policy/

procedures on handling of staff grievances/

complaints

Reference:

Item 6.3.9 of ICAC’s “Best Practice Checklist:

Governance and Internal Control in Schools”

(16)

Major Observations on the Management Aspects

General Administration of SMC/IMC

Declaration of Conflict of Interests

HR Management

Quality Assessment and Compliance

HR and Personnel Management

Staff Recruitment

Fee Remission/Scholarship Scheme

Criteria for Awarding Fee Remission &

Publicity

16

(17)

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

Students were not granted fee remission or granted fee remission less favourable than government

financial assistance scheme owing to:

Miscalculation

Income proof provided by applicants (not recipients of Student Finance Office’s (SFO) financial

assistance schemes) not fully accepted/ not accepted

(18)

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

18

Link to SFO’s website:

http://www.wfsfaa.gov.hk/sfo/en/primarysecondary/tt/general/assessment.htm

(19)

Fee Remission/Scholarship Schemes

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 favourable than those of

government financial assistance schemes, if

(20)

Major Observations –

Fee Remission/Scholarship Schemes (3)

Publicity

Major observation:

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

Reference: EDBC No. 10/2012 (para 5) 20

(21)

Fee Remission/Scholarship Schemes

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 no. is provided,

ensure that parents’ enquiries on the schemes

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

(22)

Fee Remission/Scholarship Schemes

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

22

(23)

Sharing on good practices

& Case studies

(24)

Declaration of Conflict of Interest Sharing on good practices

Each staff member was asked to complete an annual declaration form to:

confirm if he/she had read and understood the school’s policy and procedures on declaration of conflict of interest (attached to the form/

circulated at school intranet)

report in particular if he/she and immediate family member had:

any direct or indirect financial interests in any organisation which had business

dealings with the school;

any kinship with the students and staff at school

24

(25)

Declaration of Conflict of Interest Sharing on good practices (Con’t)

Separate section in the standard declaration form to record school’s decision in handling the declared conflict, with options such as:

Request the declarant to surrender the interest;

Rearrange the employee’s post or duty;

Others

To table a summary of cases of declared interests in the IMC meeting for

discussion/decision

(26)

Declaration of Conflict of Interest Case Study 1

A school manager was…

appointed as one of the members of the Tender Approving Committee (TAC) in a school year

a non-executive director of a travel agency which was one of the bidders in a

procurement of overseas study tour service

drew other members’ attention verbally to his perceived conflict of interest at the start of the TAC meeting

26

(27)

Declaration of Conflict of Interest Case Study 1

Points to note: to keep a written record of the

disclosure as well as resolution with considerations of action(s) taken to handle the declared conflict even the conflict was verbally reported by school personnel.

(28)

Declaration of Conflict of Interest Case Study 2

Policy of a school:

Staff should declare in writing to the Principal when they, their family member(s) and close relatives, and personal friends have any direct or indirect interest in any person/

company which has business dealings with the school.

They should refrain from performing or getting involved in the duty which gives rise to a conflict.

The Panel Head of the English Department…

was assigned to be a recruitment board member for an English teaching post

one of the candidates was his former colleague in another school

reported the perceived conflict of interest in writing to the Principal

28

(29)

Declaration of Conflict of Interest Case Study 2

Points to note: If it is decided the person with declared conflict should continue to discharge the duties, ….and, as and when necessary, there should be sufficient monitoring by senior staff or a second party to ensure impartiality (Para 4 of Annex 1 of EDBC No. 17/2012).

(30)

HR & Personnel Management 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/ other tests, 1

st

interview, final interview, etc. based on school background and needs

30

(31)

Fee Remission/Scholarship Schemes

Government financial assistance schemes:

Extracts of SFO’s website:

(32)

Fee Remission/Scholarship Schemes

Government financial assistance schemes (2):

32

(33)

Remission

Levels SFO’s benchmark ($) (3/4-member families)

100% 0-37552

(45460 / 41824)

50% 37553 -72611

Ineligible >72611

Fee Remission/Scholarship Schemes Case study 1

School-based scheme ($)

0-40000 40001 – 78000

> 78001

(34)

Fee Remission/Scholarship Schemes Case study 1 (Assessment)

34

Remission

Levels SFO’s

benchmark ($) (3/4-member

families)

School-based

scheme ($) Assessment

100% 0-37552

(45460 / 41824) 0-40000 50% 37553 -72611 40001 - 78000 Ineligible >72611 > 78001

(40000 / 40000)

(35)

Fee Remission/Scholarship Schemes Case study 2

Remission

Levels SFO’s benchmark ($) (3/4-member families)

100% 0-37552

(45460 / 41824)

75% /

50% 37553 -72611

25% /

Ineligible >72611

School-based scheme ($) (3/4-member families)

0 - 40000 (45600 / 43000)

40001 - 51000 51001 - 69000 69001 - 79000

> 79001

(36)

Fee Remission/Scholarship Schemes Case study 2 (Assessment)

36

Remission

Levels SFO’s

benchmark ($) (3/4-member

families)

School-based scheme ($) (3/4-member

families)

Assessment

100% 0-37552

(45460 / 41824) (45600 / 43000)0 - 40000

75% / 40001 - 51000

50% 37553 - 72611 51001 - 69000

25% / 69001 - 79000

Ineligible >72611 > 79001

69001 - 72611 69001 - 79000

37553 - 72611

(37)

Fee Remission/Scholarship Schemes Case study 3

Remission Levels

School’s point system 100% >=16

75% 11-15

50% 7-10

25% 4-6

<=3

Family situation:

4 members (with spouse and 2 depending children)

Family monthly income ($16500)

Housing expenses (monthly rent: $2000/

Monthly income Point

$0-17500 10

$17501-24500 6

$24501-30500 4

>$30501 0

Monthly rent/mortgage can be deducted from monthly income

Each spouse and depending child (excluding student-

applicant) can score 1 point

(38)

Fee Remission/Scholarship Schemes Case study 3 (Assessment)

Remission Levels

SFO’s benchmark ($) (3/4-member

families)

School’s point system

100% 0-37552

(45460/ 41824) >=16

75% / 11-15

50% 37553-72611 7-10

25% / 4-6

Ineligible >72611 <=3

Family situation:

4 members (with spouse and 2 depending children)

Family monthly income ($16500)

Housing expenses (monthly rent: $2000/ month)

Monthly income:

($16500-$2000)= $14500 10 points

2 points

If calculate by AFI mechanism:

$16500 x 12 / 4+1 AFI=$39600

38

Monthly income Point

$0-17500 10

$17501-24500 6

$24501-30500 4

>$30501 0

Points to note:

No factors except the parents’ financial situation should be taken into consideration

(39)

Fee Remission/Scholarship Schemes Case study 4

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)

SFO

(40)

Contact Us

School Administration 3 Section

Ms Amy CHENG 3509 7490 Ms Isabel WONG 3509 7459 Mr Brian YU 3509 7491 Ms Agatha PAU 3509 8552

40

(41)

THANK YOU

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