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Mental Health Investment Standard independent assurance report

This is an independent assurance report from Grant Thornton LLP in connection with the 2018 to 2019 Mental Health Investment Standard (MHIS) compliance statement to our Governing Body for the year ended 31 March 2020.

Mental Health Investment Standard compliance statement

NHS England and NHS Improvement (NHSEI) has committed to invest in mental health, with increased funds provided for mental health services every year since 2010. Since 2018 to 2019 NHSEI, have set all clinical commissioning groups (CCGs) a key measure, the MHIS, to monitor the achievement of their increased investment. In 2018 to 2019 NHSEI developed a MHIS compliance statement. The MHIS compliance statement is a statement to the public from NHS commissioners of healthcare (CCGs) stating whether the CCG has met the MHIS. NHSEI have slightly changed the required format of this compliance statement for 2019 to 2020. The 2019 to 2020 statement includes the CCG’s actual MHIS spend and their target MHIS spend (as notified by NHSEI).

NHSEI requires CCG’s to obtain independent assurance on their 2019 to 2020 compliance statement by local CCG auditors by the end of February 2021. CCGs are required to publish their compliance statement, which states whether the CCG has, or has not, met the MHIS, in a prominent position on their website alongside an independent reporting accountant’s assurance report on this compliance statement. This assurance report does not relieve management or those charged with governance of their responsibilities for the preparation of the compliance statement.

Purpose of this report

This report summarises the results of our independent reporting accountant’s assurance engagement on your 2019 to 2020 MHIS compliance statement, in line with the terms of our engagement set out in our engagement letter dated 4 January 2021. It is issued in conjunction with our signed reasonable assurance report, which should be published on your website alongside your MHIS compliance statement. This enables the Governing Body to demonstrate that they have discharged their governance responsibilities by commissioning an independent, appropriately qualitied reporting accountant to carry out a ‘reasonable assurance review’.

In performing this work, we followed the assurance engagement of the MHIS 2019 to 2020 briefing for CCGs (the guidance) issued by NHSEI.

The output from our work is a conclusion that states whether the CCG’s 2019 to 2020 MHIS compliance statement is properly prepared, in all material respects, in line with the criteria set out in the guidance.

Our approach to materiality

The concept of materiality is fundamental to the reasonable assurance process and our consideration of the monetary misstatements in the expenditure figures on which the CCG’s MHIS compliance statement is based. We have set out in the table below our determination of materiality for this engagement.

Subject £
Materiality 2,306
Trivial matters 115

Qualitative factors considered

We have considered the impact of non trivial errors on the CCG’s MHIS compliance statement.

Conclusion

The CCG’s draft compliance statement stated:

NHS Kernow considers that it has complied with the requirements of the mental health investment standard for 2019 to 2020.

Our work on your MHIS compliance statement is complete. We have issued an unmodified opinion on your 2019 to 2020 MHIS compliance statement on 12 March 2021.

We will provide a separate copy of the reasonable assurance report along with this report.

Key messages

In all material respects, your MHIS compliance statement for 2019 to 2020 has been properly prepared, in accordance with the criteria set out in line with the requirements of the guidance. However, we identified a few non-trivial errors in the CCG’s expenditure summary on which the compliance Statement was based. These are set out below.

Acknowledgements

We would like to thank the CCG staff for their co-operation in completing this engagement.

Compliance with the criteria

We applied audit procedures to confirm that the MHIS compliance statement (the statement) had been properly prepared in all material respects in line with the criteria set out in the guidance.

Work performed

We have undertaken the following procedures:

  • ascertained the method of compilation of the statement
  • considered the internal controls applied by CCG over the preparation of the statement and the actual and target MHIS spend figures included therein, and evaluated the design of those controls relevant to the engagement to determine whether they had been implemented
  • identified and assessed the risks of material misstatement in the statement as a basis for designing and performing procedures to respond to the assessed risks
  • verified the target spend included in the statement to figures issued by NHSEI
  • agreed the actual spend to the CCG’s expenditure summary and supporting records
  • carried out testing, on a sample basis, on the actual spend to check whether it met the definition of mental health spend properly incurred, as set out in the relevant group accounting manual and the guidance
  • verified the factual accuracy of the compliance statement and whether the total spend is equal to or above the target spend based on the results of the procedures set out above

The scope of our testing was the MHIS performance and mental health expenditure included in the statement only and did not cover the reporting of spend against individual service lines or the degree of provider triangulation.

Conclusion

Based on the results of our procedures, we confirm that for the year ended 31 March 2020, NHS Kernow’s MHIS compliance statement has been properly prepared in all material respects in line with the criteria set out in the guidance.

The target spend disclosed in the compliance statement of £88,550k was higher than the target spend notified to us by NHSEI of £87,443k. However, the actual spend of £88,709k exceeded both of these target figures.

Two non-trivial errors were identified by our audit, however they did not significantly impact on the actual spend, and would not result in the actual spend being lower than the target spend, so the compliance statement was not amended by the CCG.

A list of the non-trivial errors we identified from our work are set out in below.

Fees for our work on the MHIS compliance statement

We confirm below our final fees charged for this work.

Assurance on your MHIS compliance statement Proposed fee Final fee
Total fee (excluding VAT) £10,000 £10,000

We have complied with the independence and other ethical requirements of the Financial Reporting Council’s Revised Ethical Standard 2019 which is founded on fundamental principles of integrity, objectivity, professional competence and due care, confidentiality and professional behaviour.

Misstatements in expenditure

The assurance engagement of the MHIS 2019 to 2020 briefing for CCGs issued by NHSEI states that “each CCG must continue to increase investment in mental health services, in line with the MHIS. For 2019 to 2020, the standard requires CCGs to spend at least their target spend, defined as their 2018 to 2019 outturn, increased in line with overall programme allocation growth, plus an additional 0.7% to reflect the additional mental health funding included in CCG allocations for 2019 to 2020, plus any shortfall from 2018 to 2019 (incorporating any adjustments from the independent review of the 2018 to 2019 MHIS achievement).”

All non-trivial misstatements in the compliance statement which we identified during our testing are set out below, together with the overall impact on the CCG’s MHIS expenditure and in CCG allocations for 2019 to 2020.

As these errors did not significantly impact on the actual spend, and would not result in the actual spend being lower than the target spend, the compliance statement was not amended by the CCG.

Detail 2019/20 actual spend £’000 2019/20 target spend £’000
Prescribing costs 147,000 0
CHC expenditure (147,437) 0
Overall impact (0.437) 0

Prescribing costs were under stated by £147k. Dementia costs had been removed from this expenditure, however these costs were permitted by the guidance for this expenditure line.

We were unable to obtain sufficient evidence for one of the CHC expenditure sampled items that the expenditure related to mental health. In order to demonstrate this, the CCG would have had to review various confidential patient records. The error was for £1,368. We have extrapolated the error based on the full sample tested to obtain a projected error or £147,437k. That is, expenditure is over stated by £143,437k.

Grant Thornton UK LLP
12 March 2021

About Grant Thornton UK LLP

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Registered office 30 Finsbury Square, London, EC2A 1AG.

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