FPOL12 Income by Provide Community

Income

Version: V6

Ratified by: Finance & Investment Committee

Date ratified: 03/04/2024

Job Title of author: Director of Finance

Reviewed by Committee or Expert Group Finance & Investment Committee

Equality Impact Assessed by: Director of Finance

1. Introduction

Invoices should be generated as a consequence of a contract/service level agreement to provide goods/services, or for the provision of ad hoc goods/services.

2. Definitions

Fraud is where any person who dishonestly makes a false representation to make a gain for himself or another or dishonestly fails to disclose to another person, information which he is under a legal duty to disclose, or commits fraud by abuse of position, including any offence as defined in the Fraud Act 2006.

Bribery is the giving or receiving a financial or other advantage in connection with the ‘improper performance’ of trust or a function that is expected to be performed impartially or in good faith. Where the Provide Group is engaged in commercial activity it could be considered guilty of a corporate bribery offence if an employee, agent, subsidiary or any other person acting on its behalf bribes another person intending to obtain or retain business or an advantage in the conduct of business for the Provide Group and it cannot demonstrate that it has adequate procedures in place to prevent such. The adequate procedures that the Provide Group is required to have in place to prevent bribery being committed on their behalf are performed by six principles – proportionate procedures, toplevel commitment, risk assessment, communication (including training), monitoring and review. The Provide Group does not tolerate any bribery on its behalf, even if this might result in a loss of business for it. Criminal liability must be prevented at all times.

3. Counter Fraud

If any member of staff has good reason to suspect a colleague, patient or other person of fraud, bribery and / or corruption, involving the Provide Group, they should report their genuine concerns to the LCFS or Chief Finance Officer immediately. The LCFS will then decide on the next course of action and advise the member of staff accordingly. All calls are dealt with in the strictest of confidence and callers may remain anonymous.

Suspicions of fraud, bribery or corruption should be reported to the Local Counter Fraud Specialists on 01473 945843, Provide Group Chief Finance Officer or NHS Fraud and Corruption Reporting Line via an online reporting form: http://www.reportnhsfraud.nhs.uk/ or telephone 0800 028 4060. Further details including email addresses for those responsible can be found on the Provide Intranet.

Individuals suspected of committing an offence of fraud, bribery or corruption may be subject to criminal and/or disciplinary investigation, which could result in criminal and/or disciplinary action being taken, including prosecution and/or dismissal. For more information, please refer to the Local Anti-Fraud, Bribery and Corruption Policy or to the Provide Counter Fraud intranet page https://www.providecommunityplatform.co.uk/Interact/Pages/Content/Document.aspx?id =2254&SearchId=530713.

4. General

Budget holders are responsible for notifying the finance team that invoices need to be generated for any income that is due to the Group which falls within his/her sphere of management.

The budget holder should supply enough information to the finance team to enable an invoice to be raised. This should include but is not limited to the customer name and full address, contact name, the reason for the invoice, the amount, and the cost centre of the budget to be credited with the income.

Consideration should be given to whether VAT is applicable, and advice sought from the finance team where necessary.

Invoices should not cover periods which fall into two or more financial years – separate invoices should be issued for each financial year.

5. Agreements with other Organisations

Where a member of the Group enters into an agreement with another Organisation, the Finance Department should be notified at the earliest possible time of the amounts to be invoiced, frequency of billing and any references to be included on the invoice.

The Finance Assistant will complete enter the details within the appropriate finance system when an invoice needs to be raised.

An official invoice will be produced and sent to the customer. The narrative on the invoice will include a brief description of the goods or services for which the charge is being levied (e.g. refer to the agreement or relevant section of the agreement) and will specifically refer to the period covered by the invoice.

The Finance team will retain documentation to support the raising of the debt and the calculation of the charge.

6. Other Goods/Services Provided

The relevant budget holder is responsible for ensuring that the Finance Team are advised of any income of an adhoc nature that is due to the Group Following notification, the finance team will follow the process in section 3 above.

Where income is received that is not as a result of an invoice being raised, the income will be recorded on thefinance system and a matching invoice will only be created if specifically requested by the customer for their records

7. Debtor Control Listing

The Finance Team will keep a Debtor Control listing of all invoices due to be raised and check via a monthly report from the finance system that they have been issued

The maintenance of the Debtor Control listing and the review arrangements do not dilute the Budget Holder’s prime responsibility for ensuring that income due to the Group is collected.

8. Credit Notes

Where an invoice has been raised in error or the amount is incorrect, the relevant budget holder is responsible for requesting that the Finance Department raise a Credit Note.

There should be sufficient information to accompany the request, (either backing documentation or a full written explanation) to enable the Finance Team to ensure that the Credit Note will be correctly generated.

The Finance Department will generate a credit note via the appropriate finance system.

9. Debtor Reconciliations

The Sales Ledger will be closed down monthly by NHS SBS in accordance with the agreed timetable for the CIC, and by the finance team in respect of subsidiaries.

Aged debt reports will be reconciled by NHS SBS and reported to the Group on a monthly basis, and the finance team are responsible for the same in respect of subsidiaries not on the Oracle system.

10.Debt Recovery Procedures

NHS SBS is responsible for carrying standard debt recovery procedures and time-frames for the Group, and the finance team are responsible for the same in respect of subsidiaries not on the Oracle system

11.Bad Debts

If all attempts to recover monies owing to the Group fail, the case will be referred to the Chief Finance Officer for write-off approval in line with the Group Scheme of Delegation.

Once write-off approval has been obtained, the Director of Finance will allocate a sequential number in the Losses and Special Payments register and enter details of the loss. Where the amounts are small, the write-offs may be reported as a cumulative total.

The Director of Finance will ensure that the correct accounting entries are made, clearing the debt from the Sales Ledger and charging it to an agreed general ledger code.

The Director of Finance will maintain a file of supporting documentation, the documentation clearly numbered in the top right hand corner, to correspond with the sequential numbering in the Losses and Compensations register.

The Losses and Compensations register is reported regularly to the Audit Committee

EQUALITY IMPACT ASSESSMENT

TEMPLATE: Stage 1: ‘Screening’

Name of project/policy/strategy (hereafter referred to as “initiative”):

Income

Provide a brief summary (bullet points) of the aims of the initiative and main activities: Provides guidance on how to ensure that all income due to Provide Group is received.

Project/Policy Manager: Director of Finance

Date: March 2024

This stage establishes whether a proposed initiative will have an impact from an equality perspective on any particular group of people or community – i.e. on the grounds of race (incl. religion/faith), gender (incl. sexual orientation), age, disability, or whether it is “equality neutral” (i.e. have no effect either positive or negative). In the case of gender, consider whether men and women are affected differently.

Q1. Who will benefit from this initiative? Is there likely to be a positive impact on specific groups/communities (whether or not they are the intended beneficiaries), and if so, how? Or is it clear at this stage that it will be equality “neutral”? i.e. will have no particular effect on any group.

Neutral

Q2. Is there likely to be an adverse impact on one or more minority/under-represented or community groups as a result of this initiative? If so, who may be affected and why? Or is it clear at this stage that it will be equality “neutral”?

Neutral

Q3. Is the impact of the initiative – whether positive or negative - significant enough to warrant a more detailed assessment (Stage 2 – see guidance)? If not, will there be monitoring and review to assess the impact over a period time? Briefly (bullet points) give reasons for your answer and any steps you are taking to address particular issues, including any consultation with staff or external groups/agencies.

Guidelines: Things to consider

Equality impact assessments at Provide take account of relevant equality legislation and include age, (i.e. young and old,); race and ethnicity, gender, disability, religion and faith, and sexual orientation.

The initiative may have a positive, negative or neutral impact, i.e. have no particular effect on the group/community.

Where a negative (i.e. adverse) impact is identified, it may be appropriate to make a more detailed EIA (see Stage 2), or, as important, take early action to redress this – e.g. by abandoning or modifying the initiative. NB: If the initiative contravenes equality legislation, it must be abandoned or modified.

Where an initiative has a positive impact on groups/community relations, the EIA should make this explicit, to enable the outcomes to be monitored over its lifespan.

Where there is a positive impact on particular groups does this mean there could be an adverse impact on others, and if so can this be justified? - e.g. are there other existing or planned initiatives which redress this?

It may not be possible to provide detailed answers to some of these questions at the start of the initiative. The EIA may identify a lack of relevant data, and that data-gathering is a specific action required to inform the initiative as it develops, and also to form part of a continuing evaluation and review process.

It is envisaged that it will be relatively rare for full impact assessments to be carried out at Provide. Usually, where there are particular problems identified in the screening stage, it is envisaged that the approach will be amended at this stage, and/or setting up a monitoring/evaluation system to review a policy’s impact over time.