Auditor General’s overview
The 2019-20 financial year marked the third year of a 4-year transition of local government financial auditing to the Office of the Auditor General, following proclamation of the Local Government Amendment (Auditing) Act 2017. We performed the 2019-20 audits for 132 of the State’s 148 local government entities (LG entities), of which we completed 117 audits by 31 May 2021. Fifteen remained outstanding.
In addition to summarising the results of the audits for Parliament, I have taken the opportunity to provide further insight into our financial audits of the local government sector. 2020 was an extraordinary year for local government financial reporting. The COVID-19 pandemic created resourcing pressures, while the new revenue accounting standards proved particularly difficult for many entities in the sector to adopt. Furthermore, amendments to the Local Government (Financial Management) Regulations 1996, gazetted on 6 November 2020, were retrospectively applicable from 30 June 2020. This caused unprecedented delays in entities finalising their financial reports as almost half of them needed to be recast after they had been submitted. The number of LG entities recasting and submitting many versions of their financial statements (the highest being 27 versions) during the audit process is also disappointing as this results in significant additional work for both the LG entity and the auditor and delays the finalisation of the audit.
I have delayed tabling this report until almost 90% of the auditor’s reports have been issued. Of the 117 auditor’s reports issued to 31 May, 1 included a qualified opinion on the financial report (page 10). There may be further qualifications in the opinions yet to be issued. There is little room for complacency as a clear audit opinion is the minimum we should all expect. Although most entities had satisfactory audit outcomes, it is concerning that we reported 101 material matters of non-compliance in the auditor’s report for 45 entities, and 890 significant or moderate weaknesses in financial management and information systems controls in our management letters. Some of these were unresolved from the previous year. These omissions and exposures increase the risk of financial loss, error or fraud.
As we conclude our third year of transition into the financial audits of LG entities, I am encouraged that entities are adapting to the audit processes of my Office and embracing the changes suggested during our audits. Our recent seminar for audit committee chairs was open to local government representatives and I am pleased many attended online. With better informed and active audit committees, they will be equipped to quality review the financial report and assess the accountability and integrity of reporting and the operational activities of their entity.
Our audits again highlighted the need for the Department of Local Government Sport and Cultural Industries (DLGSC) to provide centralised professional support to assist entities to fulfil their financial reporting requirements. This includes professional advice on preparing for changes in accounting standards and legislation. This would be both financially beneficial and time efficient for all entities. However, my recent report into how effectively the DLGSC regulates and supports the local government sector found the Department has much work to do to provide the desired centralised sector support function.1
Further, we continue to support the need for the DLGSC to lead change in the sector’s financial reporting requirements. This includes adopting reduced reporting principles, updating the long-standing legislative requirements for entities to report 7 financial ratios, and for the auditor’s report to disclose any adverse trends. In the absence of cohesive advice for the Western Australian public sector, my office has recently produced a better practice guide to assist local and State government entities with the preparation of their annual financial statements.
I wish to thank my incredibly hardworking staff, our contract audit firm partners and staff in the LG entities who contributed to this year’s audit process. Their adaptability, professionalism, skill and cooperation in working through uncommon challenges to complete the audits is appreciated.
This Audit Results Report contains findings from our 2019-20 financial audits of local governments and regional councils (LG entities).
Following proclamation of the Local Government Amendment (Auditing) Act 2017 (Amendment Act), the Auditor General has progressively assumed responsibility for the annual financial audits of LG entities. We were responsible for 132 audits for 2019-20, the third year of the transition, and will have responsibility for all 148 Western Australian LG entities by 2020-21.
Our annual financial audits focus on providing assurance over an entity’s annual financial report. During an audit we also make related recommendations in respect to compliance, financial management and information system controls. This report summarises our findings.
- We issued auditor’s reports for the 2019-20 financial year for 65 of the 132 LG entities by the required date of 31 December 2020 (96 of 112 in 2019) and a further 52 entities by 31 May 2021. The results of the remaining 15 will be tabled in Parliament once complete. (page 10)
- All but 1 auditor’s report included a clear (unqualified) audit opinion on the financial report (page 10). However, we reported 101 material matters of non-compliance with the Local Government Act 1995, Local Government (Financial Management) Regulations 1996 (FM Regulations) or other written law in 45 of our auditor’s reports. (page 12)
- An Emphasis of Matter was included in the auditor’s report of most entities as the FM Regulations require vested land to be measured at zero cost and vested improvements at fair value. This is a departure from the Australian Accounting Standards AASB 16 Leases which requires LG entities to measure the vested improvements also at zero cost. (page 11)
- We issued 120 certifications to LG entities to acquit funding received under Commonwealth and State Government programs for projects such as Roads to Recovery and other capital works projects. We also certified 12 LG entities’ annual claims for pensioner deferments of rates and charges. (page 17)
- We reported the following control weaknesses to LG entity management, those charged with governance (mayor, president or chairperson of the council) and to the Minister for Local Government:
- 704 financial management control weaknesses at 117 entities, (802 at 107 entities for all entities last year). We considered 88% to be significant or moderate risk if not resolved in the short term (86% last year). Eighty percent of the weaknesses related to expenditure, financial management, payroll and human resources, and revenue. (page 18)
- 328 information system (IS) control weaknesses at 50 entities (202 at 38 entities last year). Our capability assessments at 11 of the 50 LG entities showed that 79% of the audit results were below our minimum benchmark. (page 23)
- We continue to support the need for the DLGSC to develop more thorough and balanced performance assessment criteria to replace the existing reporting and audit of 7 financial ratios and any adverse trends in these ratios. (page 16)
- Sixty-seven of the 132 audits were not completed by 31 December 2020. Reasons mainly include entities adjusting their financial report to comply with late FM Regulation amendments that were not gazetted until 6 November 2020, and poor quality financial reports. We also acknowledge that our audit teams could not always immediately re-prioritise audits of entities not completed in their schedule.(page 9)
- In addition to the FM Regulation amendments, entities were required to apply 3 new accounting standards from 1 July 2019. Many entities were not adequately prepared for the impact of these changes and this resulted in further delay in finalising their financial report. (page 26)
- The quality of financial reports submitted for audit varied significantly across entities. Quality issues included multiple instances of statements that did not balance, not taking up prior year balances for the current year, and many entities not applying the new accounting standards or FM Regulations correctly. This resulted in significant additional audit work and consequential delays in finalising the audits. (page 29)
- During this, our third, year of performing annual financial audits in the local government sector, we have made further general observations included in this report, with a view to minimising the cost of financial reporting and auditing in the future. These relate mainly to:
- amendment of the FM Regulations from 6 November 2020 simplifies entities’ reporting of certain classes of assets and reduces the cost burden of having external valuations of plant and equipment assets (page 25)
- valuation of assets transferred between entities must be appropriately disclosed in accordance with the Australian Accounting Standards in the financial reports of both entities (page 24)
- opportunities to reduce the financial reporting burden on small and medium sized entities, as the quantity of detail that is being reported is onerous and exceeds that reported by most WA State government entities. (page 28)
- Entities benefited from the Local Government (COVID-19 response) Act 2020 being enacted and amendments to a variety of the local government regulations being gazetted to allow modified operations during the COVID-19 pandemic. These changes temporarily remove restrictions on entities’ operations for the benefit of the district or part of the district while a state of emergency declaration is in force. These changes included holding public meetings electronically, access to information when the council offices were closed and revised budgetary requirements, such as re-purposing money. (page 32)
- Entities generally did not separately account for COVID specific expenditures. They considered that any extra cleaning costs were offset by savings at their closed community facilities. However, there was added budgetary pressure on each entity as a result of their community facilities raising no revenue, and other financial waivers for local households, businesses, tenants and sporting and community groups to reduce their financial hardship. (page 34)
- The budget implications of the Minister for Local Government’s Circular No 3-2020 that LG entities freeze their rates for 2020-21 will extend well beyond 1 year, as entities’ current year budget restraint deals with only the short term ramifications. There will be significant challenges for entities preparing their long term financial plans and budgets for some years. (page 35)
- The Department of Local Government, Sport and Cultural Industries (DLGSC) should assess whether the current financial ratios in the FM Regulations remain valid criteria for fairly measuring and reporting the performance of each LG entity. This could also include a simplification of LG entity reporting requirements for financial ratios, and review of the requirement under the FM Regulations for the auditor to report on any adverse trends in the ratios as part of the annual financial audit. (page 17)
- LG entities should ensure they maintain the integrity of their financial control environment by:
- periodically reviewing and updating all financial, asset, human resources, governance, information systems and other management policies and procedures and communicating these to staff
- conducting ongoing reviews and improvement of internal control systems in response to regular risk assessments
- regularly monitoring compliance with relevant legislation
- promptly addressing control weaknesses brought to their attention by our audits, and other audit and review mechanisms
- maintain currency with new and revised accounting standards for their impact on financial operations in order to prepare a compliant financial report at year end.
- The DLGSC should seek ministerial approval for any proposed regulatory amendments well in advance of the financial year end to ensure timely gazettal to facilitate action and avoid rework by all entities when finalising their end of year financial report. (page 26)
- LG entities should complete their assessment of the impact of any new regulations or accounting standards and prepare a position paper on the necessary adjustments to their financial report. If required, entities should seek external consultation when completing their assessment and adjust their financial report, prior to submitting it for audit. (page 26)
- DLGSC should provide timely guidance to assist LG entities to update their accounting practices to ensure that their future reporting is compliant with all current accounting standards. (page 27)
- DLGSC should re-assess the amount of detail required to be included in annual financial reports, in particular for small and medium sized LG entities. (page 28)
- To improve the quality of financial reports and achieve greater consistency across LG entities, the DLGSC should prepare timely regulation amendments for the Minister’s approval which improve the sector’s financial report framework. The DLGSC should also provide accounting support services to the sector. Proper management of financial resources is the most basic priority as from there all else is enabled or eroded. (page 31)
- We encourage entities to make use of our WA Public Sector Financial Statements – Better Practice Guide to improve their financial management and reporting practices, processes and procedures. (page 31)
About our financial audits
Our office was responsible for 132 LG entity audits for 2019-20. This year, OAG staff performed 21 of these, with the other 111 performed by contract audit firms on our behalf.
Our oversight of the local government audits, coupled with our in-house audits, has provided our staff with valuable insight and understanding of the sector. We will increase the number of audits we perform in house over time. However, we anticipate a large proportion will continue to be performed by our accredited contract audit firms. These will be periodically re-tendered to provide open and fair competition, and to ensure value for money.
We are committed to supporting the regions and, where possible and appropriate, we use local financial auditing professionals. From 2021 onwards we are seeking to leverage efficiencies by allocating sub-regions to a single firm.
Almost $43 billion of total assets were audited for the 117 LG entities. Their combined total operating revenue was $3.9 billion, of which rates contributed $2.3 billion (58%) and fees and charges $1.0 million (26%). The combined total operating expenditure was $4.0 billion.
Annual financial reporting framework, timeline and audit readiness
Reporting framework and content
Each LG entity is required to prepare an annual financial report that includes:
- a Statement of Financial Position, Statement of Comprehensive Income by Nature or Type, Statement of Comprehensive Income by Program, Statement of Changes in Equity and Statement of Cash Flows
- a Rate Setting Statement
- 7 financial ratios required under section 50(1) of the Local Government (Financial Management) Regulations 1996 (FM Regulations), to be reported in the Notes to the annual financial report
- other note disclosures such as trading undertakings and major land transactions.
The quantity of detail reported is onerous and exceeds that reported by most WA State government entities and by local governments in other jurisdictions. On page 28 we have recommended that the DLGSC re-assess the amount of detail required in annual financial reports.
Financial reporting timeliness
Under section 6.4(3) of the Local Government Act 1995 (LG Act), entities must submit their annual financial reports to the OAG for audit by 30 September. Although many entities had supplied their financial reports within this timeframe, they could not be officially finalised because amendments to the FM Regulations, applicable to all entities for their 30 June 2020 year end reporting, had not been progressed by the DLGSC. These regulations impacted the asset values reported in the financial report of LG entities for their year ended 30 June 2020. The amendments were only provided for consideration on 3 November 2020 and gazetted on 6 November 2020, some 4 months after the end of the reporting year.
Many entities prepared their financial reports with the proposed changes in anticipation of gazettal of the amendments. However, we were unable to issue our auditor’s report until the amendments were gazetted.
Of the 132 entities we audited for 2019-20, 18 received approval from the Minister to extend their submission deadline to beyond 30 September, the latest being 30 November. Other entities did not meet the statutory deadline and did not have approval.
We completed 65 of the 132 audits (49%) by 31 December 2020 (compared to 96 of 112 (86%), by the same time last year) as required by section 7.9 of the LG Act. The main reason for the delay was that entities could not submit their finalised financial reports for audit on time. In addition to the late gazettal of regulation amendments, many entities had not revised their financial reporting for the recent accounting standards amendments relating to revenue recognition and leases. Their statements needed to be revised or notes added to inform users of their limitations on this matter. Some entities also experienced problems with insufficient evidence to support the financial report, numerous errors requiring correction or resignation of key persons preparing their financial report.
Overall, while there are some LG entities whose financial management procedures are sound and their teams are well prepared for audit, we again found the quality and timeliness of information provided by LG entities is lower than for the State sector.
Generally, those entities that could not provide turnaround amendments following the regulation changes, or had significant other audit issues, staffing or skills shortages, were not finalised by 31 December.
With our tertiary audit cycle (December year-end for universities and TAFEs) peaking from January to mid-March, and State sector interim audits commencing in March, OAG teams and contract firms have had to schedule LG audit finalisation so as to minimise impact on the rest of the work program. This has resulted in regrettable delays that have frustrated LG entities and our Office.
Timely LG regulation changes and financial reporting advice to the sector is a core responsibility of the DLGSC and we trust such delays will not recur in the future.
By 31 May 2021 we had completed a further 52 of the 67 audits that were incomplete at 31 December 2020, with 15 still outstanding.
Summary of audit results
At 31 May 2021, we had issued auditor’s reports for 117 entities for the financial year ending 30 June 2020 (89% of the LG sector audits to be completed by the OAG this year).
The auditor’s report includes:
- the audit opinion on the annual financial report
- any significant non-compliance in relation to the financial report or other financial management practices
- any material matters that indicate significant adverse trends in the financial position of the entity.
Under the Amendment Act, an entity’s chief executive officer (CEO) is required to publish their annual report, including the audited financial report and the auditor’s report, on the entity’s website within 14 days of the annual report being accepted by the LG entity’s council. Appendix 1, from page 36, outlines the date we issued each LG entity’s 2019-20 auditor’s report.
Qualified audit opinions on annual financial reports
An unqualified audit opinion in the auditor’s report indicates the LG entity’s annual financial report was based on proper accounts and records, and fairly represented performance during the year and the financial position at year end. All but 1 entity received an unqualified (clear) audit opinion. There were 6 qualified auditor’s reports issued the previous year.
We issue a qualified opinion in our auditor’s report on an annual financial report if we consider it is necessary to alert readers to material inaccuracies or limitations in the financial report that could mislead readers. The following entity received a qualified opinion on their 2019-20 financial report:
Shire of Goomalling
We issued a qualified opinion to the Shire as we identified that the balances for rates revenue and corresponding expenses for the year ended 30 June 2019 are not comparable to the balances for the year ended 30 June 2020. The Shire recognised rates revenue totalling $110,140 from its own properties during the year ended 30 June 2019. This is not in accordance with the presentation requirements of the Australian Accounting Standard AASB 101 Presentation of Financial Statements, and overstated the total revenue and total expenses for the year ended 30 June 2019 by $110,140. We issued a qualified opinion for the year ended 30 June 2019 in relation to this matter.
We also were unable to obtain sufficient appropriate audit evidence to confirm that roads, drainage and footpaths infrastructure assets reported in the financial report represent fair value, or whether any adjustment to the values were necessary. These assets have not been revalued since June 2015. We were unable to determine whether the infrastructure assets of $38,841,166 are stated at fair value in the Statement of Financial Position.
Audits in progress
Audits yet to be finalised may result in modified opinions. Generally, audits in progress relate to entities that have more significant or complex issues to be resolved from a financial reporting and auditing perspective, or the LGs do not have the in-house expertise needed to manage their financial reporting. While some LGs collaborate and seek help to overcome these issues, this is often informal and ad-hoc. In the absence of formal support from the DLGSC or other sources, these issues have an impact on finalisation of the financial audits.
Prior year qualified opinions removed in 2019-20
Shire of Bruce Rock
An independent valuation of infrastructure assets of the Shire was undertaken and disclosed in note 10(b) of the Shire’s 2019-20 financial statements. This action addressed the 2018-19 asset valuation qualification which has now been removed.
Shire of Ravensthorpe
The Shire’s 2018-19 qualified opinion related to the reported valuation of assets at 30 June 2018. This balance is not included in the 2019-20 financial report, so the qualification has been removed.
Shire of Wagin
The Shire’s 2018-19 audit opinion was qualified as the year end value of drainage assets for 2018 and 2019 may not have been comparable, as the 30 June 2019 value was adjusted following an independent valuation. As the 2018 value is not included in the 2019-20 financial report, the qualification has been removed.
Emphasis of Matter paragraphs included in auditor’s reports
If a matter is appropriately presented or disclosed in the financial report but, in our judgement, is of such importance that it should be drawn to the attention of readers, we may include an Emphasis of Matter paragraph in our auditor’s report.
This year, we again drew attention to the notes in each entity’s annual financial report describing the basis of accounting. For 2019-20 this related to application of the new leases accounting standard from 1 July 2019 and entities being required to report some aspects of these standards differently due to the requirements of the FM Regulations. Further explanation of this matter is on page 25.
We did not modify our auditor’s opinion but included an Emphasis of Matter in the auditor’s report to state that entities continued their previous recognition of some categories of land, including land under roads, at zero cost. This treatment complies with the following amendments of the FM Regulations:
(i) Regulation 17A requires a LG entity to measure vested improvements at fair value and the associated vested land at zero cost. This is a departure from AASB 16 Leases which would have required the entity to measure the vested improvements also at zero cost.
(ii) In respect of the comparatives for the previous year ended 30 June 2019, regulation 16 did not allow a LG entity to recognise some categories of land, including land under roads, as assets in the annual financial report.
The following were other noteworthy matters that we highlighted through Emphasis of Matter paragraphs:
City of Stirling – Infrastructure Assets Revaluation
Our Emphasis of Matter highlighted the City’s note 8(f) which explains the basis for their infrastructure assets revaluation in the year ended 30 June 2020 and the associated change in estimates. The opinion was not modified in respect of this matter
Mindarie Regional Council – Contingent Liability
The Council’s opinion included an Emphasis of Matter drawing attention to Note 34 ‘Contingent liabilities’ which disclosed a contingent liability relating to the Tamala Park Waste Management Facility site. The opinion was not modified in respect of this matter.
Town of Victoria Park – Land Assets Revaluation
The Town’s opinion included an Emphasis of Matter drawing attention to Note 7 of the financial report which explains the basis for the significant land revaluation decrement in the year ended 30 June 2020. The opinion was not modified in respect of this matter.
Material matters of non-compliance with legislation
Under Regulation 10(3)(b) of the Local Government (Audit) Regulations 1996 (LG Audit Regulations), we are required to report any matters indicating that a LG entity is non‑compliant with:
- part 6 of the LG Act
- FM Regulations
- applicable financial controls in any other written law.
The matters may relate to the financial report or to other financial management matters.
In determining which matters to report, we apply the principles of materiality, as required by Australian Auditing Standard ASA 320 Materiality in Planning and Performing an Audit. Factors that we consider include the extent and frequency of the non-compliance, and the effect or potential effect.
We also consider regulation 5(1) of the FM Regulations to be particularly important, because failure to effectively apply those requirements can result in significant financial loss, inefficiency, financial misreporting or fraud.
If we find matters of non-compliance at an LG entity, we will report this in the auditor’s report which becomes part of their annual report published on their website. There was no discernible trend regarding the type or size of entity to which these findings relate. For the convenience of Parliament and the public, we have summarised in Table 1 the noteworthy matters of the 101 matters of non-compliance we reported to 45 LG entities.
Controls over accounting journal entries
At 8 entities we found that accounting journal entries were often posted with no evidence of independent review and approval by another person.
Accounting journals can represent significant adjustments to previously approved accounting transactions, and could result in, for example, one type of expenditure being re-coded to another type of expenditure. If not closely controlled, unauthorised journals could result in errors in financial reports, or fraud. Journals should therefore be subject to independent review.
Bank reconciliation process incomplete
At 5 entities bank reconciliations of their municipal, reserve and/or trust accounts were not prepared, had long outstanding unreconciled items and/or there was no independent review by management.
While we considered these instances to warrant reporting in the auditor’s report, several other less significant control shortcomings in relation to bank reconciliations were reported to entities in our management letters.
Other reconciliation findings
At several entities we reported weaknesses in key controls for ensuring the completeness and accuracy of financial data within the general ledger and reported in the financial report:
Quotes not obtained or no evidence retained
At 10 entities between 2% and 77% of purchase transactions sampled had inadequate or no evidence that a sufficient number of quotations was obtained to test the market and no documentation to explain why other quotes were not sought. This practice increases the likelihood of not receiving value for money in procurement or favouritism of suppliers.
Tender register details
The tender register at 1 entity did not include details of each tender and the names of the successful tenders.
Procurement without purchase orders
At 10 entities purchase orders were not prepared or were prepared after the suppliers’ invoices were received.
Procurement without required procedures
At 2 entities approximately 30% of their purchase orders did not state a dollar value, quantity procured or there was inadequate or no evidence that a sufficient number of quotations were obtained to test the market, and no documentation to explain why other quotes were not sought.
Procurement without appropriate segregation of duties
At 2 entities the same officer requisitioned, approved and raised the purchase order then also approved the associated invoice payment for approximately 26% to 28% of sampled purchase transactions.
Procurement transactions without payment approval
At 1 entity 6% of the purchase transactions did not have evidence of payment approval prior to payment occurring.
We reported other instances of non-compliance with procurement policies and procedures:
Records not presented to Council meetings as required by FM Regulations
The list of accounts paid from the municipal and trust funds and the statement of financial activity were not presented to Council within the timeframe specified in the FM Regulations for periods of 5 to 7 months.
Financial ratios not reported
Nineteen entities did not report the Asset Renewal Funding Ratio, mostly for the 3 years, 2020, 2019 and 2018, in their annual financial report as required by FM Regulation 50(1)(c). Reasons for non-reporting included:
Review not performed of financial management systems and procedures
At 3 entities a review of the financial management systems and procedures was not completed at least once every 3 financial years as required by FM Regulation 5(2)(c).
Review not performed of risk management, internal control and legislative compliance
At 2 entities a review of systems and procedures in relation to risk management, internal control and legislative compliance was not completed at least once every 3 years as required by LG Audit Regulation 17.
No review and authorisation of changes to masterfiles
There was no evidence of independent review and authorisation of changes made to the creditor masterfile at 8 entities, the payroll masterfile at 3 entities and debtors and rate assessment masterfiles at 1 entity. This increased the risk of unauthorised changes to key information.
Payroll and human resources findings
Several findings of payroll and employment non-compliance were also reported:
There was an increased risk that discounts, refunds or price changes may be unauthorised or go undetected, resulting in a loss of revenue. Findings included:
Asset control finding
One entity did not have formal policies and procedures for proper control over its fixed assets.
General computer control findings
In depth findings of our IS audits at a selection of 50 LG entities are detailed in our Local Government General Computer Controls Report, Report 23, tabled on 12 May 2021.
We reported 328 control weaknesses to 50 LG entities, with 10% (33) of these rated as significant and 72% (236) as moderate. As these weaknesses could significantly compromise the confidentiality, integrity and availability of information systems, the LG entities should act promptly to resolve them.
Our financial audit approach to reporting IS issues and general computer controls changed partway through our 2019-20 audit cycle. This has resulted in audits completed later in our cycle having material matters of non-compliance with their IS and general computer controls included in the auditor’s reports.
In 2019-20 the following material matters of non-compliance were included in our auditors’ reports:
Table 1: Material non-compliance with legislation reported in auditor’s reports
Adverse trends in the financial position of LG entities
We are required by Regulation 10(3)(a) of the LG Audit Regulations to report ‘any material matters that in the opinion of the auditor indicate significant adverse trends in the financial position or the financial management practices of the local government’.
We conducted a high level assessment of whether the 7 financial ratios reported in each LG entity’s financial report achieved the standards set by the DLGSC. When determining whether a trend was significant and adverse, in some instances we allowed for a ratio to be slightly lower than the DLGSC standard, in recognition that failing to meet some standards are more significant and representative of an entity’s financial position than failing to meet others.
Our financial audit assessments of the ratios are conducted objectively on the audited figures from the financial report on a comparable and consistent basis. Our assessments do not consider other aspects of the entity’s finances, or the inter-relationships between the ratios. These considerations are outside the scope of the legislative audit requirement of regulation 10(3)(a) and more relevant to a performance audit into adverse trends.
Entities report their ratios for the current year and the preceding 2 years. Our trend analysis is therefore limited to these 3 years. This year, we reported that 139 ratios at 89 entities indicated adverse trends. Last year, for the 2018-19 audits, the comparative figures were 113 ratios with adverse trends at 76 entities.
Review of financial ratios
It continues to be our view that the annual financial report audit does not provide the opportunity for a thorough assessment of any adverse trends that may be apparent from the ratios, and that a more thorough performance assessment is needed to conclude on the overall financial position of an entity. For this reason, after completing our first year of auditing the local government sector for 2017-18, we identified the need for the DLGSC to review Regulation 10(3)(a) of the LG Audit Regulations.
We have also previously recommended that the DLGSC give consideration to simplifying and streamlining the ratios defined in FM Regulation 50(1). This may include using different financial indicators, possibly fewer in number, that are more commonly used in the not-for-profit and government sectors.
WALGA formed a Working Group in 2020 to review the current suite of ratios and provide recommendations going forward. The Working Group is comprised of sector representatives together with officers from the DLGSC, Office of the Auditor General and WA Treasury Corporation.
The Working Group’s Local Government Financial Ratios Report was provided to the WALGA State Council Meeting on 5 May 2021. The report includes recommendations for prescribed ratios and other financial reporting related matters. WALGA State Council is the decision making representative body of all member councils with responsibility for advocating on sector-wide policy and strategic planning on behalf of local government.
The report’s recommendations were carried by the WALGA State Council who resolved that WALGA advocate the recommended changes to the Minister for Local Government. Along with ratio changes the group also recommended the DLGSC prepare a model set of financial statements and annual budget statements, in consultation with the local government sector.
Our Office continues to support the need for change in financial ratio reporting and auditing and commends WALGA for its work. However, we also consider that the DLGSC should be taking a more proactive role in this change process.
- The Department of Local Government, Sport and Cultural Industries (DLGSC) should assess whether the current financial ratios in the FM Regulations remain valid criteria for fairly measuring and reporting the performance of each LG entity. This could also include a simplification of LG entity reporting requirements for financial ratios, and review of the requirement under the FM Regulations for the auditor to report on any adverse trends in the ratios as part of the annual financial audit.
132 audit certifications issued
In addition to the auditor’s report on the annual financial report, we also conduct audit work to certify other financial information produced by entities. These audit certifications enable entities to meet the conditions of State or Commonwealth funding or specific grant requirements or legislation. Our audit certification of these statements may be required to enable entities to receive ongoing funding under existing agreements or to apply for new funding.
Appendix 2, commencing on page 40, lists the 132 certifications issued and the date of issue under 3 headings:
- 12 claims by administrative authorities for pensioner deferments under the Rates and Charges (Rebates and Deferments) Act 1992
- 112 statements acquitting Roads to Recovery Funding under the National Land Transport Act 2014
- 8 other certifications for projects by entities.
Management control issues
We also report control weaknesses related to expenditure, financial management, human resources, revenue and asset management to LG entity management in our management letters. Controls weaknesses that represent matters of material non-compliance form part of the overall auditor’s report that we provide under section 7.12AD of the LG Act to the mayor, president or chairperson, the CEO and the Minister for Local Government. During 2019-20, we alerted 117 entities of control weaknesses that needed their attention. Twelve percent of these were reported in our auditor’s report as matters of material non-compliance.
Our management letters provide a rating for each matter reported. We rate matters according to their potential impact and base our ratings on the audit team’s assessment of risks and concerns about the probability and/or consequence of adverse outcomes if action is not taken. We consider the:
- quantitative impact – for example, financial loss from error or fraud
- qualitative impact – for example, inefficiency, non-compliance, poor service to the public or loss of public confidence.
|Risk category||Audit impact|
|Significant||Finding is potentially a significant risk to the entity should the finding not be addressed by the entity promptly.|
|Moderate||Finding is of sufficient concern to warrant action being taken by the entity as soon as practicable.|
|Minor||Finding that is not of primary concern, but still warrants action being taken.|
Table 2: Risk categories for matters reported to management
We give LG entity management the opportunity to review our audit findings and provide us with comments prior to the completion of the audit. When they respond, we request they set a time frame for remedial action to be completed. Often management improves policies, procedures or practices soon after we raise them and before the audit is completed. Other matters may take longer to remedy and we will follow them up during future annual financial audits.
We reported 704 control weaknesses across the 3 risk categories as shown in Figure 1. The first chart shows the number of weaknesses in each risk category for the differing number of entities we audited during our first 3 years of LG entity transition into our audit program. The second chart shows the comparative proportion of weaknesses in each risk category.
The charts show that the proportion of control weaknesses with a significant rating have increased in number and by proportion over the last 3 years, and that weaknesses with a minor rating have decreased. The decline in minor weaknesses is in part because entities have been addressing minor issues detected in the early years of the OAG auditing the sector.
The 704 control weaknesses identified in our 2019-20 management letters are presented in their different financial management control categories in Figure 2. The control weaknesses relating to expenditure, financial management, and payroll and human resources accounted for 494 or 70% of the control weaknesses reported, compared to 487 or 61% in 2018-19.
Examples of the weaknesses are below. We recommend that entities take timely action to improve their current practices and procedures to strengthen the accountability and integrity of their financial reporting and to comply with their legislated requirements.
We reported that good procurement procedures, such as obtaining quotes and completing purchase orders to start the ordering process and accountability trail, were not routinely practiced. These included:
- Quotes were not obtained as required by the entities’ policy guidelines. There were also instances where evidence of the quotes received was not retained for the items purchased. This increases the risk of favouring specific suppliers and/or not obtaining value for money.
- We found purchase order control weaknesses at 47 entities. Purchase orders were often raised after the goods had been supplied or after the supplier’s invoice had been received. The lack of adequate controls over purchase ordering increases the risk of inappropriate purchases or the entity being committed to pay for purchases made by officers who do not have authority or who have exceeded their delegated purchase limits.
- In some entities there was not adequate separation of tasks between ordering and receiving goods. Without this segregation, the entity needs other controls to ensure that all payments for goods are reviewed and authorised by an independent officer.
- Some entities’ tender processes were not conducted in accordance with the entity’s policies and procedures, including panel members not declaring their interests.
At 29 entities we reported that changes were made to the supplier masterfile without appropriate evidence of authorisation of the change or there was no independent review to confirm checking for related party interests, authorisation, completeness and accuracy. These review procedures are essential as technology has increased the risk of fraud.
We found payment acquittal procedures at 24 entities need improvement. Full supporting documentation for payments needs to be retained, along with the correctly coded payment acquittal approved by an appropriately authorised or delegated officer.
Of the 15 entities with control weaknesses over their purchasing cards, we found that 4 entities did not have evidence of signed purchasing card agreements with cardholders. These agreements set out the terms, conditions and the entity’s level of authority for the cardholder’s use of their purchasing card. Untimely acquittal and late cancellation of purchasing cards were also reported.
The accounting procedures and practices of the financial management team should include appropriate controls for preparing the entity’s financial report and mandatory annual reporting requirements.
- Fifty-three entities had not completed their review to assess and recognise the initial and subsequent application of the new accounting standards for revenue recognition and leases. Non-compliance with the revenue standards may result in earlier income recognition, which means the entity’s 2019-20 revenue may be overstated. Non‑compliance with the lease standard can result in depreciation and interest expense being understated and lease expenses being overstated for the 2019-20 year. Further details and information on these accounting standards issues are on page 26.
- Bank reconciliations were not routinely prepared on a monthly basis or were not reviewed by a second officer. Where long outstanding cheques continue to be reported, entities need to review these debts to locate the supplier and, if not found, action these funds as unclaimed money. Entities also recorded unreconciled items, which were not investigated and resolved when they were identified and remain unreconciled. The bank reconciliation is a key control. If not performed regularly and independently reviewed, there is a risk of erroneous or unusual (including fraudulent) reconciling items not being detected and investigated in a timely manner.
- Journal entries were made without supporting documentation or were not reviewed by an independent officer. These can represent significant adjustments to previously approved accounting transactions, and unauthorised journals could result in errors in financial reports, or fraud. They should therefore be clearly explained and subject to independent review.
- Access to the financial management, payroll and human resources systems was not restricted to appropriate staff. In some instances, we considered more staff than necessary for the efficient operation of the entity had passwords to access the key systems. Monitoring of access privileges needs to be conducted on a regular basis by a senior staff member.
Payroll and human resources
Payroll and human resource management are essential elements of any employer’s business. During our interim and final audits of entities we reported:
- Some employees were not taking their annual and long service leave entitlements and therefore accumulating excessive leave balances. Entities should have a leave management plan to ensure suitable staff can undertake the roles of key staff while they are on leave and to continue to deliver the entity’s required services. Infrequent taking of leave and associated rotation of staff roles, increases the likelihood of any frauds remaining undetected.
- Commencement and termination processes were not completed promptly to ensure timely and accurate processing and payment of staff. Evidence needs to be retained of all employment contracts, which should be signed by both parties on execution.
- Changes made to employee masterfiles need to be supported by appropriate authorisation from the employee. Masterfile changes also need to be independently reviewed for accuracy and completeness, to reduce the risk of payroll errors or fraud.
- Payroll reports sent to cost centre or business managers for confirmation of employees to be paid were not returned. Without regular checks by relevant managers on their current employees and their hours worked, especially for casual and contract staff, there is an increased risk of payment errors, ghosting or fraud passing undetected.
2. LG entities should ensure they maintain the integrity of their financial control environment by:
- periodically reviewing and updating all financial, asset, human resources, governance, information systems and other management policies and procedures and communicating these to staff
- conducting ongoing reviews and improvement of internal control systems in response to regular risk assessments
- regularly monitoring compliance with relevant legislation
- promptly addressing control weaknesses brought to their attention by our audits, and other audit and review mechanisms
- maintain currency with new and revised accounting standards for their impact on financial operations in order to prepare a compliant financial report at year end.
Information system controls
Information systems (IS) underpin most aspects of government operations and services. It is important that entities implement appropriate controls to maintain reliable, secure and resilient information systems.
Audits of general computer controls help to support our financial audits and are a major part of the IS audit work we undertake. These audits provide insights about the extent to which entities’ IS controls support reliable and secure processing of financial information.
We reported 328 control weaknesses to 50 LG entities, with 10% (33) of these rated as significant and 72% (236) as moderate. Last year we reported 202 control weaknesses to 38 LG entities. As these weaknesses could significantly compromise the confidentiality, integrity and availability of information systems, the LG entities should act promptly to resolve them.
Our capability assessments at 11 of the 50 LG entities show that none met our expectations across 6 control categories, with 79% of the audit results below our minimum benchmark. We found weaknesses in controls for information security, business continuity, change management, physical security and IT operations. Entities also need to improve how they identify and treat information risks. Five of the entities were also included in last year’s in-depth assessment and could have improved their capability by promptly addressing the previous year’s audit findings but, overall, did not discernibly do so
Of the weaknesses identified in 2019-20:
- 49% related to information security issues. These included system and network vulnerabilities and unauthorised and inappropriate access to systems and networks
- 28% related to information technology (IT) operations issues. In particular, poor controls over the processing and handling of information, inadequate monitoring and logging of user activity, and lack of review of user access privileges
- 10% related to business continuity. For example, inadequate disaster recovery and business continuity plans
- 13% related to inappropriate IT risk management, poor environmental controls for the server room, and a lack of change management controls.
The information provided above is included in our Report 23, May 2021, Local Government General Computer Controls, tabled on 12 May 2021. Further details of the IS audit work and case studies from our IS audits of LG entities are included in the report.
Financial reporting issues for 2019-20
Valuation of assets
We continue to have concerns about inconsistencies in the valuation of property and infrastructure in the WA local government sector. Our Report 15: March 20192 and Report 16: March 20203 detailed concerns about the variety of valuation methodologies used, especially for land with restricted use.
Valuation concerns arise from LG entities engaging different valuers who use different methodologies or interpret some principles of the Australian Accounting Standards differently. This is particularly apparent for restricted assets. Consequently, LG entities can see significant valuation swings when they change their valuer, depending on which assumptions the valuer uses when assessing restricted land. Most entities revalued these assets in 2017 or 2018, in accordance with the LG FM Regulations, and their next 3‑5 yearly valuations are due at the latest by 2022 or 2023.
As mentioned last year, the International Public Sector Accounting Standards Board and the Australian Accounting Standards Board have projects under way relating to fair value of public assets. Our Office will work with other audit offices to prepare a submission to this fair value project.
Valuation of assets transferred between entities
Our State government audit work in 2019-20 highlighted the need for entities to act fairly and openly where assets are transferred between them.4
Our role as auditor is to ensure that land sales and asset transfers are properly disclosed. The value or benefit of the asset to the ultimate owners, as well as any trade-offs must be adequately communicated and disclosed to residents and ratepayers. These particular transactions can represent significant value.
During 2019-20 the State Government decided to progress the Ocean Reef Marina project following community consultation on this development proposal, including its impact on the community and the City of Joondalup, which was undertaken over a number of years.
Following this, the City of Joondalup reviewed the fair value of the land assets included within scope of this development proposal. After seeking independent valuation advice and in consultation with Development WA, it was agreed that the City would transfer the associated land assets to Development WA in 2021 for $1 per lot for each of the two parcels of land in order for land development to proceed.
Following this decision, the City reclassified the associated land assets from Property, Plant and Equipment with a fair value of $63.1 million to Inventory (Land held for transfer) with a net realisable value of $1 per lot. The City recognised the resulting land revaluation decrement in its asset revaluation reserves in accordance with the accounting standards, and disclosed the decrement at note 6 in its 2019-20 annual financial report.
Documenting agreements between the parties of any transaction is prudent as it provides essential evidence of both parties’ agreement to the transaction. The financial report of each entity must provide sufficient disclosure of the transaction in accordance with accounting standards. Transparency of all such transactions – their costs and benefits – is paramount.
Local government financial management regulations
Amendments to the FM Regulations were gazetted on 6 November 2020. As requirements in these regulations impacted the financial reporting of entities for the year ending 30 June 2020, finalising and signing off each entity’s financial report was delayed until after this gazettal.
Following the gazettal, we issued a position paper on 6 November 2020 (Appendix 3) to assist entities to meet the new reporting requirements. Any changes in reporting from the previous year are disclosed in the financial report of each entity. The key changes relate to the revaluation of certain asset classes, revenue recognition and accounting for leases.
Valuation of certain classes of assets
Amendment of FM Regulation 17(A) simplified LG entities’ reporting of some classes of assets and reduced the cost burden of having valuations undertaken.
Plant and equipment
Entities no longer have to revalue plant and equipment assets they own and needed to transition to the cost model from the beginning of 2019-20, and report all plant and equipment at depreciated cost at year-end on 30 June 2020. Previously these assets were held at fair value.
Land, building, infrastructure and investment property
These assets continue to be carried at fair value, with the revaluation cycle reduced to a 5‑year cycle rather than 3-yearly, unless the fair value is materially different from the carrying value.
Lease right-of-use assets controlled by entities
Amendment of regulation 17A removed the requirement to fair value all assets, including right-of-use assets. Removal of regulation 16 from 6 November 2020 impacts on the way LG entities are now required to report on commercial and concessionary leases under Accounting Standard AASB 16 Leases.
Leases of assets such as vehicles, machinery, offices and ICT equipment from 2019-20 are now recognised on the balance sheet as the right-of-use asset and corresponding liability.
These peppercorn type leases relate to assets controlled or managed but not owned by the entity. They include vested crown land and other land, such as land under roads. These concessionary lease right-of-use assets are to be reported at cost, which in most cases is zero.
Previously, entities reported land under roads at zero cost, and this continues. However, adjustments were needed for land underneath buildings or other infrastructure, such as golf courses, showgrounds, racecourse or any other sporting or recreational facilities, so that this land is also reported at zero cost. Previously these lands were reported at fair value.
The FM Regulations retain reporting of improvements on these vested lands at fair value.
3. The DLGSC should seek ministerial approval to any proposed regulatory amendments well in advance of the financial year end to ensure timely gazettal to facilitate action and avoid rework by all entities when finalising their end of year financial report.
4. LG entities should complete their assessment of the impact of any new regulations or accounting standards and prepare a position paper on the necessary adjustments to their financial report. If required, entities should seek external consultation when completing their assessment and adjust their financial report, prior to submitting it for audit.
Accounting standards reporting changes for 2019-20
LG entities were required to apply 3 new accounting standards of the Australian Accounting Standards Board (AASB) from 1 July 2019. Unfortunately, entities could not adequately prepare as the DLGSC did not advise entities what FM Regulation changes in accounting treatments would be gazetted on 6 November 2020. Consequently, entities were delayed in finalising their financial reports and some incurred additional audit costs.
Fifty-three entities received a management letter issue as they had not taken appropriate steps to implement the new standards for their 30 June 2020 reporting.
Entities that applied the standards elected to apply the modified retrospective option for their transition. This approach meant comparative figures for prior years did not need to be restated, therefore reducing the amount of work required. A note in the financial report disclosed the impact of these changes in accounting treatment from 1 July 2019.
Reporting revenue and income under AASB 15 and AASB 1058
From 1 July 2019, revenue from contracts (AASB 15), such as grant money received with specific performance obligations, is reported by allocating the grant money to each performance obligation and recognising the revenue as or when the obligations are satisfied. Similarly, grant money received with an obligation to acquire or construct an asset that will be retained by the entity (i.e. a capital grant under AASB 1058) is recognised as income as or when the obligation to acquire or construct the asset is satisfied.
For example, LG entities receiving Roads to Recovery funding from the Commonwealth Government were required to report their grants in this manner. This means a grant received for the construction of an asset is recognised as income in stages during the construction. The full value of the grant is recognised by the time the constructed asset is put into operation.
Under AASB 1058, transactions relating to assets acquired at significantly less than fair value also have new recognition principles.
Where these standards were implemented, the LG entities adjusted their opening equity and recognised their contract liabilities and capital grant liabilities as required.
Reporting of leases – AASB 16
The key change in AASB 16 is that most operating leases, which were previously recorded off-balance sheet, are now required to be capitalised on the balance sheet (Statement of Financial Position). Accordingly, most property, motor vehicle and equipment operating leases are now accounted for as right-of-use assets with their associated lease liability. A note in the financial report explains the impact of this standard.
Using this approach, on initial application of AASB 16 from 1 July 2019, LG entities were required to recognise right-of-use assets and the lease liabilities.
Future impact of changes to accounting standard
The new standard, AASB 1059 Service Concession Arrangements: Grantors, applies for years beginning on or after 1 January 2020 (2020-21 reporting year). This standard is applicable to LG entities (grantors) that enter into service concession arrangements with generally private sector operators.
It requires grantors to recognise a service concession asset and, where applicable, a service concession liability on the balance sheet. The initial balance sheet accounting, as well as the ongoing income statement impacts, will have significant financial statement implications for grantors.
5. DLGSC should provide timely guidance to assist LG entities to update their accounting practices to ensure that their future reporting is compliant with all current accounting standards.
Opportunities to improve the efficiency of financial reporting
This section includes opportunities for LG entities that may contribute to savings in financial reporting costs and improved governance. It is important to note that while some of these issues may relate to all entities, others may only be applicable to some.
Reduced disclosure reporting by LG entities
As noted on page 8, the quantity of information that is being reported in the annual financial reports of LG entities is onerous and exceeds that reported by most State government entities. Western Australian State and LG entities also include several disclosures that are not common practice in other states. This contributes to the time and cost to prepare annual financial reports, and to audit costs.
The changes made to the FM Regulations gazetted on 6 November 2020 simplified some reporting by LG entities for 2019-20. Refer page 25.
However, other opportunities still exist to introduce a tiered reporting structure and reduce the amount of detail in local government financial reports without impacting the usefulness and completeness for users. We encourage efforts to streamline financial framework obligations, particularly for small and medium sized entities, wherever it does not impair accountability and transparency.
The AASB has a project to revisit the financial reporting framework for public sector entities, which may reduce the reporting burden on LG entities. Currently the LG Regulations do not provide LG entities as much opportunity to reduce financial report disclosures as State government entities.
6. DLGSC should re-assess the amount of detail required to be included in annual financial reports, particularly for small and medium sized LG entities.
Quality of financial reports submitted for audit
The quality of financial reports submitted for audit varied significantly across LG entities. This is not unexpected as some entities have finance staff without formal accounting qualifications and professional support is not readily available in some regions. We found that many entities were unable to implement the new accounting standards without professional assistance.
Our audits also noted that various LG entities:
- had poor record keeping practices and were unable to locate requested records, such as prior period valuations
- had conflicting priorities and urgency to comply with requests for information as part of normal operations and council business, plus audit and other independent investigations
- were unable to provide information within 2 weeks of a request by audit
- experienced finance staff turnover and attrition during crucial times in the financial year, or key personnel were not available to respond to the auditors at key times as they had taken leave.
We identified numerous errors that were corrected by the LG entities during the audit process. These errors included:
- incorrect or no adjustments made for adoption of the new revenue and lease standards due to lack of understanding of the standards and no assistance or direction on what action was needed, until raised by the auditor
- financial reports that did not balance
- data errors, such as the incorrect take up of closing balances from the prior year as opening balances for the current year
- accounting differently for the same transactions, balances or disclosures
- not recognising contingent liabilities or remediation provisions for contaminated sites
- not correctly accounting for their share of a joint arrangement with another party or parties, such as a library or contribution towards the local regional council
- prior year errors that had not been corrected.
Also disappointing was the number of LG entities submitting many versions of their financial statements to us during the audit process. This results in significant additional work for both the LG entity and the auditor and delays the finalisation of the audit. For example, 1 entity submitted 27 versions of its financial statements and our auditor’s report was not issued until 20 May 2021.
We are pleased to support audit committees in State and local government through our audit committee forums. These seminars aim to improve audit committee members’ knowledge and understanding of their role and responsibilities in the entity’s financial management review process. These audit committees are becoming more active in their control oversight and quality review roles. This will assist entities to ensure the completeness and accuracy of their financial report and the supporting working papers presented for audit.
To ensure timely and accurate financial reports it is important that management in each reporting entity keeps proper accounts and records. Management should undertake various best practice initiatives throughout the financial year and after year end to improve the quality of their financial reporting.
Well before the beginning of the financial year, entities should confirm the accounting policies and accounting standards to be applied in the coming year. Entities should also determine, at that time, whether expert assistance is required in order to accurately adopt standards. Sharing specialist resources across LG entities may be cost effective and result in more timely resolution.
Before year end, entities need to:
- prepare a project plan of human and financial resources, assign responsibilities for tasks and set time frames for financial reporting
- avoid receiving asset valuations late in the financial year or after year end and ensure that management reviews the valuations before they are included in the financial reports
- identify and review changes to accounting standards and reporting requirements and confirm the approach to any changes with the auditors.
After year end, entities need to:
- analyse variations between actual and budget as well as previous year results to identify and correct omissions and/or errors
- ensure the draft financial report has received an internal quality assurance review, preferably by internal audit or other suitably qualified professionals.
Many LG entities would benefit from centralised support from the DLGSC, similar to that provided to State government entities by the Department of Treasury through the Treasurer’s Instructions. The DLGSC’s support should address timely regulation amendments to improve the financial report framework and offer practical accounting assistance. Actions should include:
- decluttering entities’ financial reports
- implementing tiered reporting for different size of entities or the complexity of their operations
- providing a model financial report with current sample notes
- providing technical and accounting standards support to entities through a help desk.
These improvements would improve the quality of the sector’s financial reports and also reduce the reporting burden on smaller LG entities.
Our Report 21: Regulation and Support of the Local Government Sector tabled on 30 April 2021 reports that LG entities’ expectations are that the DLGSC should be providing support, guidance and education on the financial reporting framework and other sector issues, such as adoption of new accounting standards, to assist them to achieve good governance and reporting.
To assist public sector entities to assess their financial management and reporting practices, we have tabled a guide later titled Western Australian Public Sector Financial Statements – Better Practice Guide. This guide should assist entities to implement better practices, processes and procedures and achieve more efficient and timely financial reporting for their entity.
7. To improve the quality of financial reports and achieve greater consistency across LG entities, the DLGSC should prepare timely regulation amendments for the Minister’s approval which improve the sector’s financial report framework. The DLGSC should also provide accounting support services to the sector. Proper management of financial resources is the most basic priority as from there all else is enabled or eroded.
8. We encourage entities to make use of our WA Public Sector Financial Statements – Better Practice Guide to improve their financial management and reporting practices, processes and procedures.
Impact of COVID-19 on LG entities and our audit approach
In response to COVID-19, we engaged extensively with audited LG entities and State government entities around audit flexibility, key priorities, and other considerations. We communicated with all stakeholders on the need to work together and maintain good governance and controls during the time of disruption.
Advice to LG entity management
On 27 March 2020 we emailed all mayors, presidents and CEOs, recognising that LG entities have a role to play in the State Pandemic Plan.
We advised of our commitment to working with entities to minimise any disruption our audit work may have while still needing to deliver a level of essential assurance to the Parliament, local government councils, the public and other stakeholders on public sector finance and performance during the pandemic period and subsequently.
As a workforce accustomed to conducting audit work remotely, our well-established systems and processes only required some adjustments. Our strategies included:
- working with entities to identify audit areas that could be done earlier or later
- reducing the amount and length of audit meetings, conducting these via audio or video conference wherever possible or postponing them
- making increased use of technology to enable the collection of evidence and analysis of financial and performance data
- continuing to use a secure portal to transmit and receive all audit documents electronically
- re-evaluating our forward performance audit program.
At an early stage of the pandemic, we sent the following advice to entities about key risks that can be heightened in times of crisis:
- Good business governance and controls can be at risk during times of disruption, particularly in environments of crisis and urgent response. There are some who may seek to take advantage of any sense of chaos for their own interests. We encourage entities to maintain good controls, particularly over cash, expenditure and assets throughout this period.
- Information systems may be the subject of increased cyber-attacks and phishing attempts, so there needs to be continued focus on information security.
We also published on our website a guidance paper ‘COVID-19 Financial controls matters’ and an extract from our Report 18: 2019-20 – Information Systems Audit report 2020 – State Government Entities, ‘Security considerations for remote working arrangements’. These guidance papers are presented as Appendix 4, page 46, and Appendix 5, page 48. For other better practice guidance published by our office, refer to the index at Appendix 6, page 50.
LG regulations amended for COVID-19 response
The Local Government (COVID-19 Response) Act 2020 received Royal Assent on 21 April 2020. This allows LG entities to suspend a local law or part of it to temporarily remove restrictions for the benefit of the district or part of the district during the state of emergency.
The Act also enables the Minister, where such an order is necessary to deal with the consequences of the COVID-19 pandemic, to modify or suspend provisions of the LG Act. Some of these gazetted changes related to the requirement to hold public meetings, access to information when council offices are closed and budgetary matters.
Other amendments were detailed in specific regulations and also applied during the period the district or part of the district was in a state of emergency.
Local Government (Functions and General) Regulations 1996
Amendments to the procurement regulations allowed LG entities to:
- extend the use of their own purchasing policy and apply local content provisions more readily to acquire good and services via written quotes to the increased threshold of $250,000, similar to the State Government tendering thresholds
- source and secure essential goods or service to address needs arising from or impacts or consequences of the hazard to which the emergency relates, without publicly inviting tenders
- use discretion to renew or extend a contract that expires, even if not an option in the original contract. There were some limitations on this exemption
- purchase goods or services from an extended list of recognised goods or services supplied by Aboriginal businesses.
Local Government (Financial Management) Regulations 1996
These regulation amendments increased the flexibility of LG entities, to:
- decide and minute the reasons for changing the ‘use of money’ set aside in a Reserve Account without the public notice period, where it was used to address a need relating to the pandemic
- borrow money or re-purpose borrowed money, without the public notice period, to address a need arising from the pandemic. Any decision and reasons must be recorded in the council minutes.
Local Government (Long Service Leave) Regulations 1996
These regulation amendments gave local government employees who had been stood down during the state of emergency greater access to paid leave.
Local Government (Administration) Amendment Regulations 1996
Gazettal of these amendments on 25 March 2020 allowed local government councils to hold meetings electronically via teleconference, video conference or other electronic means during a public health emergency. This included committee meetings.
Provision for notice of any meeting and public question time were also amended to allow electronic facilitation of meetings.
Minister for Local Government’s Circular No 03-2020, Local Government (COVID-19 Response) Order
The Minister’s Circular of 8 May 2020 requested LG entities to freeze rates, and fees and charges during the pandemic period. Furthermore, residential and small business ratepayers suffering financial hardship as a consequence of the pandemic would not be charged interest in the 2020-21 financial year. The Circular also detailed maximum instalment interest charges and late payment interest charges. The Minister noted that removing red tape and compliance requirements were other means of assisting LG entities and the community to deal with the pandemic.
COVID-19 impacts on LG entities
As part of our audits we considered the impact of COVID-19 on each entity’s financial reporting process and control environment. Risk assessment and responsive procedures were updated and additional attention was given to transactions testing for the March to June 2020 period.
We noted that the majority of staff generally continued to work from the office, sometimes on a rotation basis.
The Small Business Development Corporation’s website has detailed information about local government COVID-19 initiatives. This includes a summary of the initiatives put in place by LG entities for their local small business community, and concludes with a link to the LG entity’s own website for further details.
Information on the pandemic’s impacts appear in each entity’s annual report which are available on their websites. Some of the key or recurring disclosures are summarised below.
Disruption of services and reduced revenue
Local government venues were closed including council offices, recreational and sporting facilities, swimming pools, libraries and community facilities. These closures were intended to safeguard the health and wellbeing of residents, visitors, businesses, employees and volunteers but resulted in reduced revenue collections.
Larger LG entities also reported a reduction in parking fees and infringement revenue. Some city councils also reduced parking fees for on-street, carparks or all day parking.
Creation of COVID-19 emergency reserve
The FM Regulation amendments permitted entities to re-purpose reserves to address a need relating to the pandemic. At 31 May 2021 17 of the 117 audited to date had transferred $19.4 million of their funds into a reserve fund for this purpose during 2019-20. At 30 June 2020, 2 entities had cleared their emergency reserve accounts, while the remaining entities held a total of $17.0 million in their COVID reserve accounts.
LG entities’ expenses for directly managing the impact of COVID-19
Differentiating between COVID specific expenditure and normal expenditure was difficult as entities generally did not separately account for these expenses. Extra cleaning was incurred at certain facilities, while other facilities were closed and did not incur their normal cleaning fees. In general, LG entities did not report incurring any significant expenditure as potential extra expenses were offset by savings elsewhere.
Stimulus or initiatives administered by LG entities
LG entities’ actions supporting their local households, businesses, tenants and sporting and community groups included:
- stopping all interest charges on outstanding payments to the LG entity
- waiving loan repayments for sporting clubs and associations
- waiving lease payments for not-for-profit groups and sporting associations, and for commercial tenancies where hardship was demonstrated.
Future potential effect of COVID-19
LG entities generally prepared their 2020-21 budgets on the basis of no rate increase as requested by the Minister for Local Government’s Circular No 3-2020. Entities were therefore challenged to rationalise services to pare back their budgeted expenses or seek other revenue sources to comply with this request when finalising their 2020-21 budget.
The impact of budget restraint for 2020-21 may impact on entities and the services they can reliably deliver in the short term. Although these 2020-21 budgetary constraints may provide significant short term challenges, the ongoing ramifications will continue to be experienced in the forward estimates and budgets of entities for some years.
Appendix 1: 2019-20 LG entities audits by OAG
We completed 117 of the 132 audits for 2019-20 by 31 May 2021. The auditor’s reports issued are listed by entity in alphabetical order in the table below.
|Local government||Opinion issued|
|Bunbury-Harvey Regional Council||15/12/2020|
|City of Albany||03/12/2020|
|City of Armadale||11/12/2020|
|City of Bayswater||08/02/2021|
|City of Belmont||13/11/2020|
|City of Bunbury||02/12/2020|
|City of Busselton||17/11/2020|
|City of Canning||22/12/2020|
|City of Cockburn||02/12/2020|
|City of Fremantle||01/04/2021|
|City of Gosnells||15/02/2021|
|City of Greater Geraldton||10/02/2021|
|City of Joondalup||07/12/2020|
|City of Kalamunda||03/12/2020|
|City of Kalgoorlie – Boulder||17/12/2020|
|City of Karratha||07/04/2021|
|City of Kwinana||08/12/2020|
|City of Melville||04/12/2020|
|City of Nedlands||Audit in progress|
|City of Perth||10/12/2020|
|City of Rockingham||23/11/2020|
|City of South Perth||03/12/2020|
|City of Stirling||25/02/2021|
|City of Subiaco||Audit in progress|
|City of Swan||18/12/2020|
|City of Vincent||08/12/2020|
|City of Wanneroo||09/12/2020|
|Eastern Metropolitan Regional Council||25/11/2020|
|Mindarie Regional Council||08/03/2021|
|Murchison Regional Vermin Council||16/02/2021|
|Pilbara Regional Council||Audit in progress|
|Rivers Regional Council||11/11/2020|
|Shire of Ashburton||23/02/2021|
|Shire of Augusta-Margaret River||17/12/2020|
|Shire of Beverley||07/05/2021|
|Shire of Boddington||Audit in progress|
|Shire of Boyup Brook||Audit in progress|
|Shire of Bridgetown-Greenbushes||07/12/2020|
|Shire of Brookton||22/02/2021|
|Shire of Broome||26/11/2020|
|Shire of Broomehill-Tambellup||24/03/2021|
|Shire of Bruce Rock||19/05/2021|
|Shire of Capel||27/11/2020|
|Shire of Carnarvon||18/05/2021|
|Shire of Carnamah||29/03/2021|
|Shire of Chapman Valley||29/01/2021|
|Shire of Chittering||26/03/2021|
|Shire of Christmas Island||30/11/2020|
|Shire of Cocos (Keeling) Islands||26/11/2020|
|Shire of Coolgardie||10/12/2020|
|Shire of Coorow||17/02/2021|
|Shire of Corrigin||14/12/2020|
|Shire of Cranbrook||11/02/2021|
|Shire of Cuballing||24/02/2021|
|Shire of Cue||12/02/2021|
|Shire of Cunderdin||19/03/2021|
|Shire of Dalwallinu||15/12/2020|
|Shire of Dandaragan||13/11/2020|
|Shire of Dardanup||14/12/2020|
|Shire of Denmark||19/02/2021|
|Shire of Derby-West Kimberley||16/02/2021|
|Shire of Donnybrook-Balingup||11/12/2020|
|Shire of Dowerin||17/12/2020|
|Shire of Dumbleyung||16/12/2020|
|Shire of Dundas||26/02/2021|
|Shire of Exmouth||11/12/2020|
|Shire of Gnowangerup||09/12/2020|
|Shire of Goomalling (Qualified opinion. Refer page 10.)||27/04/2021|
|Shire of Halls Creek||16/12/2020|
|Shire of Harvey||03/12/2020|
|Shire of Irwin||04/02/2021|
|Shire of Jerramungup||11/12/2020|
|Shire of Katanning||08/03/2021|
|Shire of Kellerberrin||16/12/2020|
|Shire of Kojonup||Audit in progress|
|Shire of Kondinin||14/12/2020|
|Shire of Koorda||17/12/2020|
|Shire of Kulin||30/03/2021|
|Shire of Lake Grace||17/12/2020|
|Shire of Laverton||Audit in progress|
|Shire of Leonora||17/02/2021|
|Shire of Manjimup||11/05/2021|
|Shire of Meekatharra||16/12/2020|
|Shire of Menzies||31/05/2021|
|Shire of Merredin||Audit in progress|
|Shire of Mingenew||11/12/2020|
|Shire of Moora||04/05/2021|
|Shire of Morawa||21/12/2020|
|Shire of Mount Magnet||07/04/2021|
|Shire of Mount Marshall||03/03/2021|
|Shire of Mukinbudin||18/12/2020|
|Shire of Mundaring||07/12/2020|
|Shire of Murchison||Audit in progress|
|Shire of Murray||19/02/2021|
|Shire of Nannup||18/03/2021|
|Shire of Narembeen||04/12/2020|
|Shire of Narrogin||Audit in progress|
|Shire of Northam||21/12/2020|
|Shire of Northampton||04/02/2021|
|Shire of Nungarin||11/03/2021|
|Shire of Peppermint Grove||Audit in progress|
|Shire of Perenjori||Audit in progress|
|Shire of Pingelly||16/12/2020|
|Shire of Ravensthorpe||11/03/2021|
|Shire of Sandstone||Audit in progress|
|Shire of Serpentine-Jarrahdale||22/12/2020|
|Shire of Shark Bay||19/02/2021|
|Shire of Tammin||23/12/2020|
|Shire of Three Springs||16/12/2020|
|Shire of Trayning||09/03/2021|
|Shire of Upper Gascoyne||17/12/2020|
|Shire of Victoria Plains||25/02/2021|
|Shire of Wagin||19/02/2021|
|Shire of West Arthur||10/12/2020|
|Shire of Westonia||18/12/2020|
|Shire of Wickepin||16/12/2020|
|Shire of Williams||04/12/2020|
|Shire of Wiluna||Audit in progress|
|Shire of Woodanilling||20/04/2021|
|Shire of Wyalkatchem||01/04/2021|
|Shire of Yalgoo||Audit in progress|
|Shire of York||04/12/2020|
|South Metropolitan Regional Council||23/12/2020|
|Town of Bassendean||16/02/2021|
|Town of Cambridge||16/04/2021|
|Town of Claremont||08/03/2021|
|Town of Cottesloe||18/02/2021|
|Town of East Fremantle||22/12/2020|
|Town of Mosman Park||22/12/2020|
|Town of Port Hedland||16/03/2021|
|Town of Victoria Park||20/05/2021|
|Western Metropolitan Regional Council||14/12/2020|
Appendix 2: LG entities’ certifications issued
In addition to annual auditor’s reports, some entities needed to acquit moneys received from other sources under grant agreements or other legislation. We issued the following 132 certifications on statements of income and expenditure of entities, to help them discharge their financial reporting obligations, some being for Commonwealth grants.
|Local government certifications||Certifications issued|
|Claims by administrative authorities – Pensioner deferments under the Rates and Charges (Rebates and Deferments) Act 1992|
|City of Belmont||26/10/2020|
|City of Busselton||20/10/2020|
|City of Gosnells||26/11/2020|
|City of Joondalup||05/11/2020|
|City of Kalamunda||23/11/2020|
|City of South Perth||09/11/2020|
|City of Vincent||30/10/2020|
|Shire of Brookton||28/05/2021|
|Shire of Dandaragan||05/11/2020|
|Shire of York||16/12/2020|
|Town of Cambridge||06/05/2021|
|Town of Mosman Park||05/11/2020|
|Local government certifications||Certifications issued|
|Roads to Recovery Funding under the National Land Transport Act 2014|
|City of Albany||21/10/2020|
|City of Armadale||28/10/2020|
|City of Bayswater||30/10/2020|
|City of Belmont||28/10/2020|
|City of Bunbury||21/10/2020|
|City of Busselton||29/10/2020|
|City of Canning||30/10/2020|
|City of Cockburn||30/10/2020|
|City of Fremantle||27/10/2020|
|City of Gosnells||13/10/2020|
|City of Greater Geraldton||30/10/2020|
|City of Joondalup||27/10/2020|
|City of Kalamunda||21/10/2020|
|City of Kalgoorlie-Boulder||01/04/2021|
|City of Karratha||30/10/2020|
|City of Kwinana||30/10/2020|
|City of Melville||02/11/2020|
|City of Nedlands||30/10/2020|
|City of Rockingham||30/10/2020|
|City of South Perth||27/10/2020|
|City of Subiaco||09/11/2020|
|City of Swan||30/10/2020|
|City of Vincent||28/10/2020|
|City of Wanneroo||29/10/2020|
|Shire of Augusta-Margaret River||23/10/2020|
|Shire of Beverley||27/10/2020|
|Shire of Boyup Brook||10/11/2020|
|Shire of Bridgetown-Greenbushes||28/10/2020|
|Shire of Brookton||30/10/2020|
|Shire of Broome||27/10/2020|
|Shire of Bruce Rock||28/10/2020|
|Shire of Capel||23/10/2020|
|Shire of Carnamah||27/10/2020|
|Shire of Carnarvon||15/12/2020|
|Shire of Chapman Valley||21/10/2020|
|Shire of Chittering||17/12/2020|
|Shire of Christmas Island||09/10/2020|
|Shire of Cocos (Keeling) Islands||31/03/2021|
|Shire of Coorow||06/10/2020|
|Shire of Corrigin||19/10/2020|
|Shire of Cuballing||21/10/2020|
|Shire of Cue||29/10/2020|
|Shire of Cunderdin||26/02/2021|
|Shire of Dalwallinu||26/10/2020|
|Shire of Dandaragan||30/10/2020|
|Shire of Dardanup||20/10/2020|
|Shire of Denmark||08/02/2021|
|Shire of Derby-West Kimberley||23/02/2021|
|Shire of Donnybrook-Balingup||26/10/2020|
|Shire of Dowerin||29/10/2020|
|Shire of Dumbleyung||28/10/2020|
|Shire of Dundas||29/10/2020|
|Shire of Exmouth||21/10/2020|
|Shire of Gnowangerup||20/10/2020|
|Shire of Goomalling||22/03/2021|
|Shire of Halls Creek||10/02/2021|
|Shire of Harvey||28/10/2020|
|Shire of Irwin||22/10/2020|
|Shire of Katanning||12/02/2021|
|Shire of Kellerberrin||22/10/2020|
|Shire of Kojonup||27/10/2020|
|Shire of Kondinin||29/10/2020|
|Shire of Koorda||26/10/2020|
|Shire of Kulin||29/10/2020|
|Shire of Lake Grace||30/10/2020|
|Shire of Laverton||21/10/2020|
|Shire of Leonora||28/10/2020|
|Shire of Manjimup||26/10/2020|
|Shire of Meekatharra||27/10/2020|
|Shire of Menzies||27/04/2021|
|Shire of Merredin||18/12/2020|
|Shire of Mingenew||29/10/2020|
|Shire of Moora||24/11/2020|
|Shire of Morawa||29/10/2020|
|Shire of Mount Magnet||26/10/2020|
|Shire of Mount Marshall||10/10/2020|
|Shire of Mukinbudin||24/11/2020|
|Shire of Mundaring||26/10/2020|
|Shire of Murray||02/11/2020|
|Shire of Nannup||12/02/2021|
|Shire of Narembeen||16/10/2020|
|Shire of Northam||08/12/2020|
|Shire of Northampton||28/10/2020|
|Shire of Nungarin||30/10/2020|
|Shire of Peppermint Grove||28/10/2020|
|Shire of Perenjori||28/10/2020|
|Shire of Pingelly||28/10/2020|
|Shire of Ravensthorpe||10/11/2020|
|Shire of Sandstone||18/03/2021|
|Shire of Serpentine-Jarrahdale||10/11/2020|
|Shire of Shark Bay||11/11/2020|
|Shire of Tammin||09/11/2020|
|Shire of Three Springs||22/10/2020|
|Shire of Trayning||21/10/2020|
|Shire of Victoria Plains||29/10/2020|
|Shire of Wagin||28/10/2020|
|Shire of West Arthur||27/10/2020|
|Shire of Westonia||22/10/2020|
|Shire of Wickepin||27/10/2020|
|Shire of Williams||20/10/2020|
|Shire of Wiluna||20/10/2020|
|Shire of Wyalkatchem||29/10/2020|
|Shire of Yalgoo||28/10/2020|
|Shire of York||26/10/2020|
|Town of Bassendean||29/10/2020|
|Town of Cambridge||10/12/2020|
|Town of Claremont||15/12/2020|
|Town of Cottesloe||27/10/2020|
|Town of East Fremantle||28/10/2020|
|Town of Mosman Park||29/10/2020|
|Town of Port Hedland||30/10/2020|
|Town of Victoria Park||30/10/2020|
|Local government certifications||Certifications issued|
|City of Bunbury – UATToilet Facility to Des Ugles Park Public Toilet Facility||10/11/2020|
|City of Bunbury – Koombana Bay Community / Southern Ports Recreational Fishing and Crabbing Platform||10/11/2020|
|City of Joondalup – Community Sport Infrastructure Grant Program – Whitfords Nodes Park Health and Wellbeing Hub||30/03/2021|
|City of Kalamunda – Development Contribution Area 1 – Forrestfield Light Industrial Area||08/12/2020|
|Shire of Dandaragan – Bushfire Risk Management Plan||08/07/2020|
|Shire of Dandaragan – Jurien Bay Civic Centre Outgoings for Department of Biodiversity, Conservation and Attractions Tenancy||04/11/2020|
|Shire of Dandaragan – Regional Airports Development Scheme||16/07/2020|
|Town of East Fremantle – Better Bins kerbside Collection Program||16/02/2021|
Appendix 3: Position paper on local government financial management regulation changes
We issued this to all LG entities on 6 November 2020 following gazettal of regulatory changes
Appendix 4: COVID-19 Financial control matters
We issued this to all public sector entities on 6 April 2020
Appendix 5: Security considerations for remote working arrangements
This was included in our Information Systems Audit Report 2020 – State Government Entities report tabled in Parliament on 6 April 2020
Appendix 6: Better practice guidance
We continue to develop better practice guidance to help the Western Australian public sector perform efficiently and effectively. This includes:
- practical guidance in the application of standards
- case studies
- checklists to assess existing frameworks and processes
- information to help entities to better understand how to comply with legislation and standards.
|Grants administration||Grants Administration||28 January 2021|
|Western Australian Public Sector Audit Committees||Western Australian Public Sector Audit Committees – Better Practice Guide||25 June 2020|
|Managing technical vulnerabilities||Information Systems Audit Report 2020 – Local Government Entities||25 June 2020|
|Contract management – extensions and variations||Local Government Contract Extensions and Variations||4 May 2020|
|Controls for the management of monies held for specific purposes||Control of Monies Held for Specific Purposes||30 April 2020|
|COVID-19 financial and governance matters||Stand alone guidance||6 April 2020|
|Security considerations for remote working arrangements||Information Systems Audit Report 2020 – State Government Entities||6 April 2020|
|Purchasing cards||Controls over Purchasing Cards||25 March 2020|
|Effective fee-setting||Fee-setting by the Department of Primary Industries and Regional Development and Western Australian Police Force||4 December 2019|
|Fraud prevention||Fraud Prevention in Local Government||15 August 2019|
|Regulating building approvals||Local Government Building Approvals||26 June 2019|
|Project management||PathWest Laboratory Information System Replacement Project||19 June 2019|
|Verifying employee identity and credentials principles||Verifying Employee Identity and Credentials||19 June 2019|
|Engaging consultants for strategic advice||Engaging Consultants to Provide Strategic Advice||5 June 2019|
|Cloud application (software as service agreement)||Information Systems Audit Report 2019||15 May 2019|
|Records management||Records Management in Local Government||9 April 2019|
|Management of supplier master files||Management of Supplier Master Files||7 March 2019|
|Procurement||Local Government Procurement||11 October 2018|
|Online services||Delivering Services Online||25 May 2016|
|Contract management||Health Department’s Procurement and Management of its Centralised Computing Services Contract||17 February 2016|
Glossary and acronyms
|AASB||Australian Accounting Standards Board|
|Amendment Act||Local Government Amendment (Auditing) Act 2017|
|Auditor’s report||The Auditor General’s auditor’s report that is published in the local government’s annual report by the CEO, in accordance with section 5.55A of the LG Act. This includes the audit opinion. It may also include any instances of material non compliance that we identified.|
|Audit report||The overall report under section 7.12AD of the LG Act, formally issued to the Mayor, President or Chairperson, the CEO and the Minister for Local Government on completion of the audit, including the Auditor’s Report and the management letter(s).|
|CEO||Chief Executive Officer|
(or unqualified opinion)
|Auditor General’s opinion expressed when an annual financial audit concludes that in all material respects the financial report is presented fairly in accordance with the LG Act and, to the extent that they are not inconsistent with the Act, Australian Accounting Standards.|
|Contract audit||Audit of a local government undertaken by an appropriately qualified individual or firm, on behalf of the Auditor General, appointed under a contract.|
|DLGSC||Department of Local Government, Sport and Cultural Industries|
|Emphasis of Matter||A paragraph included in an auditor’s report that refers to a matter that is appropriately presented or disclosed in the financial report but which, in the auditor’s judgment, is of such importance that it should be emphasised in the auditor’s report.|
|Entity/entities||Western Australian local government cities, towns, shires and regional councils|
|Financial audit||Work performed to enable an opinion to be expressed regarding a financial report prepared by the party who is accountable for the financial transactions.|
|LG Act||Local Government Act 1995|
|LG Audit Regulations||Local Government (Audit) Regulations 1996|
|FM Regulations||Local Government (Financial Management) Regulations 1996|
|Management letter||A letter to management of a local government that conveys significant audit findings and results of the audit. On completion of the audit, the management letter forms part of the audit report sent to the CEO, to the Mayor, President or Chairperson, and to the Minister for Local Government.|
|OAG||Office of the Auditor General|
|Qualified opinion||Auditor General’s opinion expressed when an audit identifies aspects of the annual financial report that are likely to be misleading to users, there was material conflict with applicable financial reporting frameworks or a limitation of scope on audit work.|
1 Western Australian Auditor General’s Report, Regulation and Support of the Local Government Sector, Report 21: April 2021
2 Report 15: March 2019 – Audit Results Report – Annual 2017-18 Financial Audits of Local Government Entities
3 Report 16: March 2020 – Audit Results Report – Annual 2018-19 Financial Audits of Local Government Entities
4 Page 37 of Audit Results Report – Annual 2019-20 Financial Audits of State Government Entities, Report 7, November 2020