Thursday, November 3, 2011

3. GOAL : INTEGRATING AUDIT EFFORTS




                       CHAPTER 3.    

GOAL  1 : INTEGRATING  AUDIT  EFFORTS

This strategy is about:

1A. Re‐structuring the organizational structure for audit of Government of India entities
on the basis of the Ministry/ Department, rather than on the type of the entity
(Government office, PSU, Autonomous Body etc). In this way, a Central Ministry as
well as the PSUs and Autonomous Bodies under it will be audited together by a single
office (or group of offices), and audit of several Ministries/ Departments (grouped
sector‐wise) will be under a single DAI. The existing boundaries of Civil, Defence,  Railway, Commercial and Autonomous Bodies Audit will be done away with.

1B.         Regional ADAIs for State Reports, with arrangements for co‐ordination and ensuring  consistency in a country‐wide approach.

3.1 Background

Our audit arrangements in respect of entities under the Government of India (GoI) are organized primarily based on the nature of the entity, rather than on a sect oral perspective. For example,

·      While Ministries and Departments of Government of India are audited by the respective Principal Audit Offices (DGACE, PDAESM and PDASD on the Civil Side; DGADS, PDAFN, PDAOF on the Defense Side, the Railway Audit Offices etc.), the commercial undertakings under the administrative control of these Ministries/ Departments are audited by the MABs reporting to DAI(C).

·      Units of Ministries/ Departments located outside Delhi are audited by the concerned State PAGs/ AGs, except in Mumbai and Kolkata, where they are audited by DGA(C)/ PDA(C), whose primary reporting relationship is, however, to DAI(RA).

·      The autonomous bodies functioning under these Ministries/ Departments are audited by the respective Principal Audit Offices as well as State PAGs/ AGs, but are processed by a separate wing in Hqrs under ADAI(C&AB).

Problems with Existing Audit Organisation

 ·      Each audit office, and functional wing in Headquarters, is concerned primarily with audit of
the units under its audit jurisdiction. There is lack of overall perspective for the Ministry/ Department as well as the sector.




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 ·      Currently, integration of audit perspectives across audit offices and functional wings takes
place on an ad hoc/ case to case basis, and effective integration depends to a large extent
on the persons involved in such an exercise. While there are many successful instances of
integrated audit across functional boundaries4, in the absence of an institutional

mechanism for integration, there are often cases of lack of adequate ownership for an  integrated audit exercise.

 ·      The current organizational structure does not facilitate creation of domain knowledge on a
sectoral basis; such knowledge is restricted to individual pockets in different offices and that too to a limited extent.

This organization of audit offices may be contrasted with the organization of the auditee entities under GoI, where the administrative control of PSUs, autonomous bodies, as well as attached/ subordinate offices (located in Delhi and elsewhere) rests with the Ministry/ Department.

3.2 Re­Organising Audit of GoI according to Ministry

 In the light of the need for institutional mechanisms for integrated audit, the audit of entitites  under the GoI should be completely re‐organized on the basis of the Ministry/ Department,  rather than on the nature of the auditee entity.

The existing boundaries/ divisions such as Civil/ Defense/ Railway Audit, Commercial Audit, Autonomous Bodies Audit should be done away with. This will provide a far better platform for integration, than the current structure.

Two issues are likely to be thrown up in the context of such a radical re‐organisation:

·      Currently, commercial audit staff form a separate pool and are deployed for commercial audit of Central and State PSUs (with ad hoc deployment for certification audit of Central/ State Autonomous Bodies). Under the proposed re‐organisation, these entities will no longer fall within a limited set of audit offices. In such a situation, the cadre of commercial audit staff will be deployed for all Audit Offices which require their services, particularly for certification audit and also for specialized sect oral knowledge (e.g. oil and gas); this should not be a major handicap.

·      The audit reports of the reorganized audit offices will be referred either to PAC or COPU (depending on the subject matter of the report). This is also not a major problem, as the auditee Ministries/ Departments deal with several Committees of Parliament (PAC, COPU as well as the Departmental Standing Committees) as part of their normal operational activities. The paragraphs/ chapters dealing with PSUs can be referred to the COPU (as in
 


4   E.g. co‐ordination between the Commercial and RC wings on performance audits of Hydrocarbon Production Sharing Contracts and NACIL.




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the case of Commercial Chapters in combined State Audit Reports in the North Eastern States). Further, the proposed Parliamentary Relations Unit will also handle co‐ordination issues, if any.

3.3 Current Audit Organisation

Currently, thereare 43 audit offices dealing with audit of GoI entities, as summarized below:

·       13 Commercial Audit Offices (12 MABs plus DGA P&T);

·       4 Defence Audit Offices;

·      6 Civil/ Central Revenue Audit Offices (DGACE, PDAESM, PDASD, DGA (C) Mumbai, PDA (C) Kolkata, and DGACR);

·       17 Railway Audit Offices; and

·       3 Overseas Audit Offices.

These audit offices are currently reporting to four DAIs – DAI(RC), DAI(C), DAI(LB & A),and DAI(RA), and one ADAI (ADAI (C&AB)).

3.4 Proposed Audit Organisation

We now propose that the audit of GoI be reorganised under 53 audit offices – 43 existing offices plus 10 new offices5, as summarized below:

Function
No. of Audit




Offices



DAI (Economic and
7 DGs/ PDs for
·
DG/ PD – Petroleum (Upstream)

Infrastructural Ministries)
Economic
·
DG/ PD – Petroleum (Downstream)


Ministries


·
DG/ PD – Steel






·
DG/ PD – Coal



·  DG/PD – Heavy Industries & Micro, Small and Medium




Enterprises (MSME)



·  DG/PD – Commerce, Corporate Affairs, Textiles and




Tourism



·  DG/ PD – Mines, Chemicals and Fertilisers


5 DGs/ PDs for
·
DG/ PD – Power (Thermal)


Infrastructure
·
DG/ PD – Power (Hydropower and Power




5 Or alternatively by diversion of existing DG/ PD level posts in other areas (e.g. PD – RTIs, PDA Railways for some of the smaller, newly created zones), as deemed appropriate by senior management.




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Function
No. of Audit




Offices






Transmission)



·  DG/ PD – Shipping, Road Transport and Highways



·  DG/ PD – Civil Aviation, Urban Development, Housing




and Urban Poverty Alleviation



·
DGA P&T

DAI (Socialand General
3 DGs / PDs for
·
DG/ PD – Agriculture, Food Processing Industries, and

Services Sector)
Social Sector

Consumer Affairs and Food & Public Distribution



·  DG/ PD – Human Resources Development, Panchayati




Raj, Water Resources, Labour & Employment, Social




Justice & Empowerment, Minority Affairs, Tribal




Affairs, and North Eastern Region



·  DG/PD – Health and Family Welfare, Women & Child




Development, and Rural Development


3 DGs/ PDs for
·
DG/ PD – Atomic Energy and Space


Scientific
·
DG/PD – Science and Technology, Agricultural


Departments



Research and Education, Earth Sciences, Information








Technology, and Medical Research



·  DG/ PD – Environment & Forests, and New and




Renewable Energy


3 External
·
PDA London


Audit Offices
·
PDA Washington






·
PDA Kuala Lumpur


2 DGs/ PDs for
·
DG/PD – Home Affairs, UT, External Affairs, Overseas


General

Indian Affairs, Law and Justice,and Parliamentary


Services

Affairs



·  DG/ PD – I&B, Culture, Personnel, Youth Affairs and




Sports, Planning Commission, Statistics and




Programme Implementation

DAI (Finance and Revenue
4 Revenue
·
DGACR, New Delhi

Audit)
Audit Offices
·
DGA CR, Mumbai






·
DGA CR, Kolkata



·  DGA CR, Southern Region (Bengaluru/ Hyderabad/




Chennai)







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Function                                            No. of Audit

Offices

2 Financial

Audit Offices




DAI (Defence and Railway           7 DGs/ PDs for

Audit)                                                Defence










17 Railway

Audit Offices










·       DG/ PD – Finance (overall responsibility for certification of GoI accounts, and audit of Ministry of Finance)

·       DG/ PD – Finance & Insurance PSUs

·       DGADS, New Delhi

·       PDA – Northern and Central Commands, Chandigarh

·       PDA – Southern Command and DRDO, Pune

·       DG/ PD – Air Force

·       DG/ PD – Navy

·       DG/ PD – Ordnance Factories

·       DG/ PD – Defence PSUs

·       Re‐structuring/reduction of Railway Audit Offices may be considered, after considering the workload (especially in the newly created Railway Zones) and also in view of the current and future availability of IAAS Officers at AG level

·       Audit of Railway PSUs (KRCL, DMRC, CONCOR, RITES, IRCON etc.) should be with the Railway Audit Wing



Ideally, a separate post of DAI (Accounts) would be required, so as to focus full attention on this important function and also for appropriate direction for standard setting (including GASAB). Till such time as a separate post is not available, this function can be handled by one of the DAIs –DAI (Finance and Revenue Audit) or perhaps DAI (Hqrs) or DAI (Defence and Railway Audit), depending on an assessment of their relative workload

Details ofthe proposed re‐organisation of audit offices in respect of GoIare indicated in Annexe‐ 4.

 The proposed re‐organisation is a complex one, involving major restructuring on a scale not
seen in the IAAD since 1984 (when the State AG Offices were bifurcated into Audit and A&E

 Offices). Hence, a gradual and long‐term approach will be required for its implementation,  even in phases.

Further, audit of all central units (expenditure/ receipts/ ABs) – whether located in New Delhi or elsewhere ‐ would be done only by the Central Audit Offices. State PAGs/ AGs will be responsible only for conduct of All India Reviews of Central Sector/ Centrally Sponsored Schemes within their State audit jurisdictions.







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 While the proposed re‐organisation would ensure integrated audit for Ministries/
Departments and other units of GoI in most cases, All India reviews (in particular those in the
 social sector) will need active involvement and co‐operation of the State PAGs/ AGs, without
which effective integrated audit cannot be achieved. There would, thus, need to be extensive

 co‐ordination between DAI (Social and General Services Sector) and the ADAI (Reports  States), primarily in audit of Centrally Sponsored/ Central Sector Schemes.

3.5 Staff Implications of Re­organisation of GoI Audits

 Considering the sensitivity of such re‐organisation on IAAD staff, we propose that no  transfers of IAAD officials on account of this re‐organisation outside their current station of  posting would be made, without their consent.

Officials who consent to move to other locations could be appropriately posted, while officials who do not agree to move to other locations may either be adjusted in other audit offices at the same locations with vacancies, or adjusted againstposts personal to them (which will lapse with their transfer/ retirement).

Such re‐organisation is not expected to be a major problem in terms of staff implications, since there are not only huge vacancies(especially on the Central Civil side) but there is need for increasing the sanctioned staff strength in many areas which have seen a huge increase in expenditure in the past (without corresponding increase in staff strength). Such increases in staff strength should be only at the supervisory grades.

3.6 Re­organisation of Audit of States

Recent proposals for re‐organisation of audit of States have centred around creating posts of Regional ADAIs; this would have the advantage of a uniform command structure and single reporting relationship for field PAGs/ AGs. Considering the advantages and disadvantages, we broadly agree with the approach of creating Regional ADAIs (either four or five, depending on whether a separate ADAI(North East States) is to be created. In addition, the Regional ADAI organization would also facilitate co‐ordination amongst the different State PAGs/ AGs to ensure a commonality of audit approach, and minimizing chances of important audit areas not being audited dueto lack of co‐ordination.

With Regional ADAIs, there would also be no need for the concept of a single PAG, with a co‐ ordinating responsibility in respect of other AGs in the State. Such an approach of a “co‐ordinating” PAG would add an additional layer in the organizational hierarchy, without any commensurate benefits to the organization, since he/ she will not be held accountable for the Audit Reports produced by the other offices.








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However, two key issues with the Regional ADAI structure need to be addressed:

·      There is a danger of All India Reviews of Central Schemes being “orphaned”, with one DAI having to deal with five zonal ADAIs; this could seriously compromise the objective of “integrating” audit efforts. To minimize this problem, in respect of Centrally Sponsored Schemes/ Central Sector Schemes involving transfer and utilization of funds at the State and lower levels, the concerned DAI (primarily DAI ‐ Social and General Services Sector) will have to be assigned a formal co‐ordinating role in this regard.

·       Even in other areas, the opportunity for a uniform country‐wide approach (particularly for

Commercial and State Receipts) should be retained. This could be achieved through designation of nodal DAIs/ ADAIs for a specific topic6. The responsibilities of the nodal DAIs/ ADAIs would include providing overall guidance and, as far as possible, uniformity on an All‐ India basis, and also resource support in cases of shortage of resources with the requisite competencies. This concept of nodal DAI/ ADAI would also tie in neatly with the concept of knowledge centres and resource persons proposed in the next chapter.
 




































6    This need not necessarily be the DAI dealing with Central Audit. While DAI (Economic and Infrastructural Ministries) could be the nodal officer for roads and highways, the Regional ADAIs could be the nodal officers for areas like public works, irrigation projects, power distribution etc.




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