4. Improving collaboration in the public sector audit system in Brazil
This chapter discusses how co-operation, co-ordination and collaboration among national and subnational audit bodies can lead to coherent, strategic auditing of decentralised policies. It begins by noting the key dimensions of collective action, and goes on to list three types of network governance structure, citing examples as well as the strengths and weaknesses of each. Key operational requirements for the audit network are explored next, with the emphasis on the need for collective understanding of, and agreement on, the network’s purpose. Challenges faced by these networks are then outlined, including information sharing versus confidentiality and privacy and differing audit standards and capacities. The chapter concludes by providing details on how an evidence-based risk assessment can be embedded in a collaborative process of audit selection within a network of external audit entities.
Given the reality of decentralisation in Brazil, audit bodies of the decentralised audit systems might look for opportunities to work together, in order to deliver to the centre of government and policymakers insights into crosscutting improvements for decentralised policies. If they can work in collaboration on these common areas, not only may they be able to reduce the likelihood of unnecessary duplication of audit work and to improve the audit coverage, but also their work may lead to better audits through exchange of knowledge, ultimately resulting in better insights and a higher impact of audit work.
By improving co-ordination among external audit institutions, supreme audit institutions (SAIs) can help to address the challenges inherent in decentralisation, ultimately improving their added value (OECD, 2016[1]).
Collaboration involves multiple actors, who are in one way or another connected to the same issue in a network. By working together in that network, the audit bodies can achieve collective benefit through the pooling of expertise, access and resources while respecting the diverse views, mandates and institutional priorities of their institutions. Any collaboration in a network of external audit entities needs to be carefully designed in order to deliver the expected added value. There are three crucial design challenges that might be considered, further detailed below: the required level of collective action in the network, the required network governance, and the operational design of the network.
Levels of collective action
The terms collaboration, co-operation and co-ordination are often used interchangeably to describe the way individuals or institutions work together. However, there are differences that may help external audit entities understand and decide on what is needed and attainable given their specific context (see Box 4.1 for definitions).
Collaboration describes the process of facilitating and operating in multi-organisational arrangements to solve problems that cannot be solved or solved easily by single organisations. Together, collaborating organisations produce outcomes or products, and thereby serve their society or clients. For collaboration to work, there must be a high level of trust and engagement and a close relationship among the collaborating organisations, normally including the establishment of shared goals, shared resources, and defined relationships and communications.
Co-ordination consists of organisations working in a concerted manner to achieve a particular goal, providing shared rewards in the long term. It involves some formal and long-term interaction, and facilitates mutual learning, but it does not require, for example, shared resources. Co-ordination requires a medium level of trust and engagement among the partners.
Co-operation is the least formal of the three concepts, and may be established for example on a short-term basis in order to achieve a specific goal. It involves incidental sharing of information and exchanges of resources, without necessarily having mutual goals. It can be ad hoc and requires only a low level of trust and engagement.
Source: OECD elaboration based on (Agranoff and McGuire, 2003[2]) (Thomson and Perry, 2006[3]).
The level of collective action among audit bodies in the network is not static. Collaboration, co-ordination and co-operation might coexist in the same network at the same time for different elements of the network activities, depending on the context, the goals of the audit bodies involved, the resources available, etc.
Trust among the network participants is the key driver of the level of collective action that is possible in a network. Trust keeps the network together and it can grow or diminish through further interaction among the partners. The higher the level of trust within the network, the higher will be the level of integration and collective action that can be expected from the network.
When establishing the level of collective action of the network, Brazilian audit institutions might consider the following key dimensions:
Trust, the basic and fundamental dimension – While co-operation does not require trust to be built on a strong basis among the network participants, collaboration does. Trust is not static; it can increase or decrease depending on the experiences of the individuals or organisations in the network over a longer period.
Information sharing and communication – While co-operation does not require formal and ongoing information arrangements, co-ordination does need structured information sharing and communication on the project level. Collaboration needs communication on a strategic and tactical level. The more intense and better the communication flow, the more trust can grow.
Sharing of goals, power and resources – The more integrated the network, the more these elements are shared among the network partners.
Commitment and accountability – Co-operation is possible even if the primary commitment and accountability is to the own organisation, while collaboration requires primarily commitment to the network.
Time frame – Co-operation can work within a short time frame, while co-ordination requires a project-based time frame and collaboration a longer term.
Combining these elements allows the description of a given network, as shown in Table 4.1.
These dimensions can be mixed and matched, and may evolve over time. For example, in Brazil, audit institutions have experienced, to a greater or more limited extent, different ways of working together. Ad hoc initiatives led mostly by TCU for carrying out specific co-ordinated audits might be seen as an example of “co-operation”, given, for example, its relatively short relational time frame and the frequency of information sharing (project-based). Participation in initiatives and projects broader in scope involving structured communication flows and information sharing – such as participation in the National Strategic Information Network for the External Control (Rede Nacional de Informações Estratégicas para o Controle Externo, the Infocontas) could be identified as co-ordinated work experience. Finally, the participation of some TCs in committees or projects with negotiated shared goals, in a relational long-term time frame where the power and resources are shared, such as the Education Committee hosted by the Rui Barbosa Institute, could be an illustration of collaboration (see Box 4.2).
Therefore, with regard to issues or subjects on which TCs have not worked together yet, they might start working on them at a co-operation level but later may express the desire to evolve towards a more integrated network over time. Collaboration might be of particular interest to address the risks of duplication or overlap. For instance, a municipal audit institution and the relevant state audit institution might decide to collaborate in areas where their joint efforts may be of value (e.g. for auditing policies involving both levels of government). In such cases, these institutions would need to implement structures to integrate and improve the frequency of information and knowledge sharing, particularly on the issues affecting both institutions (for example, by applying the methods for audit selection described in Chapter 2). Moreover, they might decide to negotiate shared goals and programmes, based on a relationship of shared power and pooled resources.
Over half of the TCs have established conditions for collaboration, either in their organic laws, in internal rules, or in both instruments. In general, these legal provisions enable the audit institutions to enter into co-operation agreements with the TCU or other audit institutions in order to exchange information, improve the control system and train personnel, as well as to develop joint actions involving, for example, a transferring entity or receiving entity of public resources. Approximately 12 TCs establish specific conditions for signing co-operation agreements, approved by the plenary and/or by the president.
Most TCs have already been involved in initiatives to exchange information between institutions. These initiatives include, for example:
The aforementioned Infocontas
Public Expenditure Watch (Observatório da Despesa Pública)
The National Network of Public Indicators (Rede Nacional de Indicadores Públicos – INDICON).
Education Committee of the Rui Barbosa Institute
The Technical Education Committee of the Rui Barbosa Institute, formed in 2018, has developed several initiatives aiming to induce action to improve public education in Brazil. The Committee is also responsible, for instance, for co-ordinating actions to monitor the goals of the country’s National Plan of Education through the platform “TC Educa”. The platform presents the Plan’s strategic goals and compares the situation in Brazil, the states, the federal district and selected municipalities. The platform also makes this information available to public sector managers.
The Education Committee is headed by one president, counsellors from eight courts of accounts and the Secretary for the External Control of Education from the country’s SAI. The technical body is composed of more than twenty auditors from the ten participating courts of accounts.
Source: (Instituto Rui Barbosa, 2020[5]); (Instituto Rui Barbosa, 2020[6]), TCs’ Internal Rules and Organic Laws, as consulted in August 2017.
Network governance structure
For the Brazilian network of audit institutions to be effective and efficient, TCs might think of the governance structure of the network and decide on issues concerning the allocation of responsibility, formalised structures and established processes. Overall, networks might be shaped around three governance structures: self-governed networks, a lead organisation network, and an administrative organisation network (Kenis and Provan, 2009[7]) (see Figure 4.1).
The self-governed network
Self-governed networks are structures in which there is no formal administrative entity governing the network. The network participants manage the network activities and take all decisions collectively. If the network is large, some of the tasks may be performed by a subset of the network participants, e.g. in working groups. The model can be of value when, for example, the active involvement of all participating audit bodies is vital (e.g. when they have complementary audit mandates), and it respond to participants’ needs (see Box 4.3 for example). The risk associated with the model is its potential inefficiency, depending on the size and complexity of the network. The model is best suited to small local networks, or to networks in which all the participating audit entities are independent and autonomous and have reasons (e.g. political or institutional) not to delegate decision-making powers to a third party.
The Spanish Court of Audit (Tribunal de Cuentas) and the External Control Bodies of the Autonomous Communities (Órganos de Control Externo de las Comunidades Autónomas, the OCEXs) have a legal duty to work in co-ordination, both to avoid duplication in audit actions and to ensure the best impact from the audit work, with the least use of resources.
For this reason, the Court of Audit and the OCEXs systematically maintain co-ordination and co-operation relationships with the purpose of exchanging audit programmes, planning joint actions and establishing common audit criteria and techniques; all the while, each institution safeguards its independence,
For example, the OCEXs will communicate to the Court of Audit issues they detect in their audits that could lead to further audit work by the Court. The collaboration also takes place when the Court of Audit, aiming at greater efficiency, delegates to the OCEXs certain investigative actions in the course of an audit. The collaboration arises from and is generally organised by the members of the audit system.
Source: (Tribunal de Cuentas, 2014[8]) (Tribunal de Cuentas, 2020[9]).
The lead organisation network
In this type of network governance, the activities and key decisions are co-ordinated by one of the participating institutions, which acts as the lead organisation. This organisation provides the administration for the network and facilitates the activities of the members in their efforts to achieve the network goals. The model might be suitable in vertical relationships, e.g. in case there is a major funder of the activities, or if one of the network participants institutionally has more decision-making power than the others (see Box 4.4 for an example). The strength of the model is in its potential efficiency and the legitimacy provided by the lead agency. The risks involved in implementation relate to the potential control over the agenda by the lead organisation, and the decrease of interest by the network partners in the network.
The regional and territorial chambers of accounts (Chambres Régionales et Territoriales des Comptes, CRTCs) were created during the French decentralisation movement in 1982, in light of the financial autonomy granted to the subnational levels in France. In addition to the French Supreme Audit Institution, there are thirteen territorial and regional courts in mainland France and ten courts overseas spread over four locations.
While maintaining their autonomy, the CRTCs work in close co-operation with the SAI through the Higher Council of Regional Courts of Accounts (Conseil supérieur des chambres régionales des comptes). For instance, in addition to compliance and financial audits, the CRTCs also participate in the evaluation of public policies implemented locally, for example by carrying out surveys, in close collaboration with the SAI. The management and operation of the Council is led by the SAI, which is also responsible for the financial management of the council, and for assigning the leadership (magistrates) to the CRTCs.
Source: (Cour des Comptes, 2020[10]).
The administrative organisation network
This type of network consists of a separate entity that is set up specifically to manage and co-ordinate the network and its activities. This might be a dedicated formal entity or association with a mandate and its own budget and structure, or an existing entity that is well positioned to take on this role. The strength of the model relates to its potential sustainability, legitimacy and its efficiency. The risks may include the costs and overcomplication of decision‐making processes. In addition, some network members may profit from the network without contributing actively to network activities (“free riders”).
The Australasian Council of Auditors-General (ACAG) is an association established in 1993 for the sharing of information, experiences and intelligence. Membership of ACAG is open on a voluntary basis to the auditors-general of all audit jurisdictions within Australia, New Zealand, Fiji and Papua New Guinea.
The Council is the supreme authority of ACAG, and consists of all ACAG Members. The Council meets face-to-face at least twice each year. It seeks consensus in its decisions; where this is not the case however, reasons for differing points of view will be clearly documented.
The Council may from time to time, establish specialist subgroups for the purpose of discussing matters of common interest. With respect to such subgroups, the Council may:
specify in writing the terms of reference and function of the subgroup
appoint such persons as the Council considers appropriate, including as chair of the sub-group
determine the frequency and medium for meetings
receive minutes from the subgroup from each meeting held
terminate the subgroup at any time.
The Secretariat is the Council’s operational and administrative organ. The executive director is the chief executive officer of the secretariat and is responsible to the executive. The executive director performs assigned duties and responsibilities as directed by Council and the executive committee, and their performance is reviewed annually against a series of agreed key performance indicators. Responsibilities include:
delivering Council and committee secretariat support services
stakeholder engagement and relationship management
developing and maintaining business support systems and records, including the ACAG intranet
developing, overseeing and monitoring the strategic plan and annual business plans, including operational and project budgets.
ACAG funds consist mainly of membership subscriptions and other financial contributions paid by members. These contributions vary and are proportionally split among members depending on certain criteria (e.g. the size of the organisation).
Source: (ACAG, 2019[11]) (ACAG, 2017[12]).
To facilitate co-ordination within the external audit system in Brazil, TCs and their members (e.g. ministers and counsellors) have established a number of critical bodies, such as the Rui Barbosa Institute (IRB) and the Association of the Members of the Brazilian Courts of Accounts (ATRICON), which may be considered administrative organisation networks. Each institute has specific mandates, but also complementary activities (see Box 4.6).
Rui Barbosa Institute (IRB)
The IRB is a civil association created in 1973 with the goal of improving the activities carried out by TCs. The IRB is considered the “academic arm” of the external audit system in Brazil, due to the events, seminars, congresses and publications for which it is responsible.
To achieve its statutory purposes, since 2015 the IRB is administratively structured into five directorates (vice-presidências):
Institutional Relations, which aims to establish national and international partnerships to develop projects or actions.
Institutional Development, which aims to develop co-operative and network actions for various areas of work of the courts of accounts, such as ombudsman, internal affairs, libraries, secretaries of external control, communication advisory, IT management for the courts, etc.
Auditing, which is responsible for translating into Portuguese the international auditing standards, publishing the Brazilian Public Sector Auditing Standards, and assisting the courts in implementing these standards.
Public Policies, which aims to provide support to improve the audit of public policies, including by indicators, with emphasis on the municipal management efficiency index - IEGM and the state management efficiency index - IEGE.
Capacity Building and Research, which develops training activities to disseminate and share knowledge and capacity.
In addition to the directorates, the Institute organises and co-ordinates different thematic committees, such as the committees on auditing standards, capacity building, human resources, TC governance, education, public policy evaluation and information technology.
Finally, IRB co-ordinates other networks, groups and projects that might be headed by one of its committees or directorates. One example is the Programme for the Modernisation of the External Control System (Programa de Modernização do Sistema de Controle Externo, PROMOEX).
The membership to the Institute is voluntary, and to date most TCs are members. The members finance the association’s activities by means of an annual contribution. The main objective established in the IRB Strategic Plan for 2018-22 is to promote integration of the audit work of TCs in order to strengthen them institutionally.
The Institute is thus responsible, for example, for translating and adapting INTOSAI audit guides and standard rules into Portuguese and to the Brazilian context. Such efforts aim to promote the harmonisation of the audit practices adopted by the Brazilian audit institutions. The Institute also intends to consolidate the different capacity-building initiatives launched by the TCs, particularly the e-learning courses. To date, over 400 initiatives have been consolidated and shared on the Institute’s website. Moreover, the Institute is currently developing a “talent pool”, which will aim to facilitate the connection of auditors from different TCs to participate in trainings and secondments.
The TCs choose the IRB presidency through elections that take place every two years. The Institute does not employ any personnel directly; therefore, the elected presidency is responsible for allocating staff for the directorates, committees and relevant activities.
Association of the Members of the Brazilian Courts of Accounts (ATRICON)
ATRICON was created in 1992 with the aim of promoting the improvement and integration of the Brazilian courts of accounts and their members (ministers, counsellors, substitute ministers and substitute councillors). For that, the entity promotes and encourages the exchange of information and experiences among members of TCs, while supporting the development of strategies and tools to improve the effectiveness of the public administration's control systems
Elected every two years, the ATRICON board selects strategic goals and actions, establishes partnerships with other institutions, and organises debates and national events. One of the association’s projects is the Quality Assessment of Courts of Accounts, which aims to measure the quality and agility of the Brazilian courts. Through the project, 28 out of the 33 courts of accounts were assessed in 2013 by means of peer reviews. The performance measurement was based on parameters set in ATRICON external control guidelines and in ISSAIs. The final report does not address or provide individual recommendations to the courts of accounts, but offers a high-level overview of the Brazilian external control system.
The association also supports IRB activities, and both institutions have the power to leverage and scale up the individual initiatives of TCs. For that to be possible, one of the ATRICON goals set in its strategic plan of 2018-23 is to ensure, until December 2023, the support of ATRICON in 100% of the activities involving production and dissemination of technical expertise held by the IRB.
Similarly to the Rui Barbosa Institute, the ATRICON board is elected by its members every two years. The board is responsible for allocating staff to perform the association’s activities, as it does not employ any staff directly.
Source: (Instituto Rui Barbosa, 2018[13]) (ATRICON, 2018[14]) (ATRICON, 2020[15]) (Instituto Rui Barbosa, 2020[16]).
Each type of network governance has its strengths and weaknesses (see Table 4.2). The most suitable network governance model depends on the purpose, needs, goals and capacity of and partners in the network at a given point in time. In reality, mixed governance structures may be applied and the appropriate model may evolve over time, depending on changes in context and in requirements. Regular monitoring and evaluation of the network may reveal the need for adaptation on a timely basis.
In Brazil, unlike the case of Spain, France and Mexico (as seen in Box 4.3, Box 4.4 and Box 4.9 respectively), to date audit institutions have no legal obligation to work in collaboration. Moreover, unlike other areas of the Brazilian public administration – and despite being object of certain bills to amend the Constitution (mainly the PEC 28/2007) – the Brazilian audit institutions do not have an institutional “national council of the external control”. Such organisation could guide, inform and co-ordinate the activities and priorities of the institutions, as well as issue rules to harmonise practices (see Box 4.7 for examples of existing councils).
National Council of Justice
The National Council of Justice (Conselho Nacional da Justiça, CNJ) was created by Constitutional Amendment No. 45 of 2004 and installed on 14 June 2005, under the terms of art. 103-B of the Federal Constitution. The Council is a body of the judiciary, headquartered in Brasília, and is composed of fifteen members, each with a term of two years. Its members include the president of the Supreme Federal Court, members of public prosecutor’s offices, lawyers and citizens.
The CNJ issues normative acts and recommendations for its members, and approves the judiciary’s strategic planning, taking into account its objectives, goals and institutional evaluation programmes. It also aims at promoting efficiency, by disseminating best practices and carrying out analysis, statistical reports and indicators relevant to jurisdictional activity in the country. Finally, the Council receives and decides on complaints against the members or bodies of the judiciary.
National Council of Public Prosecutors
Similar to the CNJ, the National Council of the Public Prosecutors (Conselho Nacional do Ministério Público, CNMP) was created in 2004 by Constitutional Amendment No. 45. The Council was installed in 2005 and is headquartered in Brasilia. The body is formed of 14 members of different public prosecutors offices, at the federal and state levels of government, in addition to citizen representatives and representatives of other sectors of society. Overall the CNMP is responsible for holding public prosecutors accountable for their acts, but it also aims at establishing a national strategy for the Brazilian public prosecutors offices.
National Council of Internal Control
Unlike the CNJ or the CNMP, the National Council of Internal Control (Conselho Nacional de Controle Interno, CONACI) was not created through a constitutional amendment or law. It was created in 2007 to promote and strengthen public sector internal control in Brazil, through representation, integration and institutional advice, and by increasing transparency, strengthening social control and providing effective public service.
A forum, a presidency, an executive secretariat and working groups form the Council, among others. The forum is the highest body of the Council, having deliberative and normative powers, and is composed of members of the internal control bodies at all levels of government. It has the mandate to formulate the general policy of the Council, set the guidelines and priorities, decide on the work plans and respective budgets, and elect the presidency.
Source: (CNJ, 2020[17]) (CNJ, 2020[18]) (CNMP, 2020[19]) (CONACI, 2015[20]).
One option is that the Brazilian audit institutions could advocate for the creation of a new administrative network that could take the form of a national council. The council could have the mandate to promote best practices among audit institutions, define strategic planning for the whole system, co-ordinate, disseminate and leverage individual initiatives, avoid duplication and gaps, etc.
As a first action, or until the network takes the form of an institutionalised council, the audit institutions could prioritise measures to strengthen the existing associations, mainly ATRICON and the Rui Barbosa Institute. For example, they could:
promote dialogue among audit institutions for the adoption of international audit standards that are reviewed and published by IRB
in order to avoid duplication of actions, classify each of the existing initiatives (committees, working groups, networks) and allocate them to one specific vice-presidency, which could be responsible for the continuity of each activity
work to assure the continuity of the activities of the associations, or think of solutions for the mitigation of risks such as the lack of future leadership
promote dialogue with the courts of accounts to decide on the actions for further improvement of the association.
The networks’ operational design
Networks might consider how they operate. Crucial elements include understanding of the network’s purpose and essential needs and when to change earlier choices, depending on the evolution of the network (described in the previous section and Box 4.8). These questions should be addressed at the establishment of the network and readdressed at significant transitions in the network’s life (Plastrik, Taylor and Cleveland, 2014[21]).
Answering the questions below will help establish a shared vision among the network members and the networks’ value propositions, i.e. the specific benefits that network members will realise by participating in the network. The questions are also intended to make clear what resources are needed and where they are to come from; to define the lines of decision making and responsibility; and to establish a monitoring structure that will allow the members to make decisions on the network’s strategic direction.
1. Purpose – What is the network’s reason for being? Why do members allocate time and resources to the network?
2. Membership – Who is eligible to become a member? What are the membership requirements? How many members will there be?
3. Value propositions – What will be the benefits of membership— for individuals and collectively?
4. Co-ordination, facilitation, and communication – How will network members link up and work with each other? What procedures and methods will the network use to co-ordinate and facilitate the members’ work? Three main co-ordinating tasks need to be taken into account in the responses:
a. Logistics: setting up meetings, conference calls and other ways members can engage with each other; creating and distributing essential information such as a directory of members and contact information.
b. Operations: external communications; facilitating meetings and group processes of members; managing an archive of network documents; controlling the network’s finances; managing or bringing on board new members of the network.
c. Strategic management: a higher level of responsibility focused on helping the network members, especially those with governance duties, to make and implement decisions about the network’s development. Managing relationships with outside partners and funders, supporting members who are undertaking initiatives for the network, and creating and modifying network plans.
5. Resources – What budget does the network need in order to achieve its goals? What is the network’s funding model?
6. Governance – Who decides what the network will do, and how do they decide?
7. Assessment – How will the network monitor its condition and performance?
Source: OECD elaboration based on (Plastrik, Taylor and Cleveland, 2014[21]).
Regardless of the form of the network in Brazil (e.g. a national council; a lead organisation; or a strengthened existing administrative network), the audit institutions must debate and decide on the key operational design in order for the collaboration to be effective.
Most importantly, TC leadership must agree on the purpose of the network and therefore, must understand and be convinced of the added value of the collaboration. For this, all prospective members of the network should be consulted, for instance through a series of (video) conferences or a survey among members of the courts of accounts, to share their ideas about the values and purpose of the network. If existing networks are used, such as IRB and ATRICON, an option is to involve representatives of each court of accounts in the development of the strategic planning (see Box 4.10 and Box 4.14 for examples).
Ways to communicate among network member institutions and auditors might be designed in a way that supports the purpose if the network. For example, if the network intends to reduce duplication and overlap of audit activities performed by the TCs, it could adopt a channel for the consolidation, analysis and classification of such activities. In this sense, the network could draw inspiration from Mexico and Argentina (Box 4.9) and work towards the integration of the audit plans of all TCs. If the network has the ambition to collaborate in selecting and planning audits, an IT system such as the one detailed in Chapter 2 could aggregate and organise the information about auditees, policies being audited, etc. The system could also consolidate the findings of the audit institutions, which could in turn facilitate following up on the audit recommendations. Moreover, the network could think of measures to preserve its legacy, for example by implementing and managing an official archive of its documents.
Mexico
The General Act of the National Anti-corruption System (LGSNA) from 2016 created the National Auditing System in Mexico (Sistema Nacional de Fiscalización, the SNF), chaired by the Supreme Audit Institution (SAI) of Mexico (Auditoría Superior de la Federación, the ASF) and the Ministry of Public Administration (Secretaría de la Función Pública, the SFP). The system establishes the co-ordination mechanisms among the bodies responsible for governmental auditing tasks in the different levels of government, with the objective of maximising auditing coverage and impact throughout the country.
The LGSNA mandates the development of an electronic system (Plataforma Digital Nacional) intended among other objectives to extend the coverage and impact of the auditing of federal and local resources. In order to meet the legal requirement, a working group was created in 2018 within the SNF, for the implementation of a virtual platform. The platform is still under development; it will consolidate the annual programmes of the audit bodies at the three levels of government and enable the sharing of databases among SNF members.
Argentina
The Federal Network of Public Control (Red Federal de Control Público) was created in 2002, when an agreement was signed between certain government internal and external control bodies and the main internal audit body in Argentina, the Comptroller General of the Nation (Sindicatura General de la Nación, SIGEN).
SIGEN shares with the network financial information about federal investments and transfers made to the municipalities and provinces participating in the network, which would not otherwise be disclosed or easily accessible. Additionally, based on a risk matrix prepared by SIGEN, members of the network select issues and programmes that they could potentially audit. These issues are then shared with other members.
SIGEN also collects reports issued by subnational audit bodies and consolidates all the findings. These findings are subsequently presented by SIGEN to the centre of government in biannual meetings.
Source: (Cámara de Diputados del H. Congreso de la Unión, 2016[22]) (SIGEN, 2020[23]).
Through the network, the audit institutions could adopt one official external control calendar, with the official events organised by the different courts and associations (e.g. events hosted by the courts of accounts, IRB, ATRICON, the National Council of the Presidents of the Courts of Accounts, the Brazilian Association of Municipal Courts of Accounts – ABRACOM, etc.)
The network might be funded by a fixed annual fee paid by its members –like the IRB funding structure – or could take the form of a fee that might vary depending on certain criteria (e.g. size categories of members), such as the ACAG funding structure (Box 4.5). Alternatives for funding the structure might include calculating the reduction of costs for the audit institutions due to joint or co-ordinated audits, which could be allocated by the relevant courts to the network.
The network must think about its governance structure strategically, i.e. who will make decisions and how. For example, under the current structure of IRB, TCs choose the presidency every two years. Other possibilities include a governance model consisting of an assembly and a board, the former composed of one or two representatives of each TC (e.g. the president and one auditor, or the secretary-general for the external control), who could elect a board that would have some decision-making powers. The network could also establish an advisory committee that included the participation of citizens and auditees. Other independent committees could be established in order to manage and co-ordinate specific subjects, such as the committee for audit selection (further described in the next section of this chapter).
In any case, network members need to evaluate the adequacy of the governance model – including the term of the mandate, and consider if such mandate should be extended for the purpose of continuity of actions, for example. This might be part of a mechanism to assess the network’s performance and adequacy. For example, the presidency or the board might be responsible for delivering an annual report of activities around the strategic objectives of the network (see Box 4.10 for an example of interactive reporting of activities).
The National Council of Internal Control has approved its strategic planning for the years 2019-21, consisting of seven strategic objectives and thirty specific actions. Specific goals and the relevant indicators for measuring each goal accompany each objective.
For example, Objective 1 consists of “Contribut[ing[ to the good governance of the Public Administration, promoting the fight against corruption, integrity, transparency, efficient management of public resources and social control”.
In order for the goals to be achieved, the Council has decided on specific actions for each objective – for example, four actions have been assigned to Objective 1. Each action is led by a manager and is performed by certain individuals among the different Council members. The manager’s contact information as well as information about the participating individuals, including their photos and emails, is publicly available on the strategic planning website. The interactive website also displays the indicators, the progress of each goal and objective, and the activities of the managers and other individuals working to achieve the goals.
Source: (CONACI, 2019[24]).
Challenges for audit networks
While working together in a network might benefit from the ability of TCs to address issues associated with the audit of decentralised policies and multi-level governance, audit networks also face specific challenges. When using the work of other auditors at state, provincial, regional, district or local level, or of public accounting firms that have completed audit work related to the audit objective, audit institutions should make arrangements to ensure that any such work was carried out in accordance with public sector auditing standards (INTOSAI, 2013[25]). Other specific challenges include:
Confidentiality and information sharing
When working together in a network, TCs might share information, analysis and conclusions obtained throughout their work. Therefore, the exchange of information must be given particular attention and the network entities must consider and observe the internal provisions of each participating institution regarding confidentiality and privacy issues. For example, it might be necessary to enter into confidentiality agreements to address the specific concerns and particularities of each TC involved. This is for instance the case in the European Union, where these restrictions apply to exchange of information between the European Court of Auditors and the SAIs of the Member States. In some cases, a “single audit” agreement might facilitate the exchange of information within the network. See Box 4.11 for an example from Belgium.
The Belgian Court of Audit is mandated to audit the Federal State, the Communities and Regions and the provinces. The SAI is not entitled to audit municipalities; at that level, the Audit Vlaanderen is the external audit body for the Flemish municipalities and the Centre Régional d’Aide aux Communes for the Walloon municipalities.
At the Flemish (regional) level, in order to reduce the burden for the auditee and to improve the quality of the audits, the SAI, Audit Vlaanderen and certain internal audit bodies have reached agreements for adoption of the “Single Audit Principle”. The principle consists of promoting a single audit model for the Flemish authority, where each level of control and audit builds on the previous one, aiming to reduce the burden on auditees and avoid overlaps.
The participating entities share their risk assessments of the auditees and co-ordinate their audit planning. They also meet periodically in a steering committee for single audit. The entities have also entered into the Annual Agreement Memorandum for auditing the annual accounts, which provides mechanisms for sharing information. The memorandum, signed by the Flemish Minister of Finance, the Belgian Institute of Registered Auditors, and the SAI, establishes the minimum requirements to be respected by the auditors. For example, it exempt the audit institutions from the secrecy obligation of the statutory auditor if:
the information is exchanged on audit strategy and planning, on risk monitoring and analysis, on control and reporting and on control methods concerning entities of the Flemish authority under their common area of control
the transmission of information from the work documents of the statutory auditor concerning entities of the Flemish authority is subject to the single audit principle.
Source: (Belgian Court of Audit, 2015[26]) (Belgian Court of Audit, 2009[27]) (Accountancy Europe, 2019[28]).
Different audit standards
Brazilian audit institutions must exercise caution about the use of different audit standards. In that regard, adoption of the international standards translated and adapted by IRB might be of use as the common ground. Moreover, if the network decides to consolidate information from audits coming from different audit institutions, it should be aware that audit criteria, e.g. for compliance, may differ among jurisdictions. Finally, the network may also need to take into account differences in budget and audit cycle timing among participating network institutions. Some countries are implementing measures to overcome these challenges through capacity building and harmonisation of practices among audit institutions (see Box 4.12 for examples).
Lithuania
In Lithuania, local auditors need to apply the audit methodology that is prepared and used by the National Audit Office. Additionally, the SAI annually assesses the quality control system developed by the local auditors and the quality of the audits. The results of the assessment and suggested recommendations are submitted to the local audit institutions. Common audits carried out together with local audit institutions are also considered as an element of the capacity building system.
Mexico
In Mexico, the National Auditing System (Sistema Nacional de Fiscalización, the SNF), chaired by the Supreme Audit Institution (SAI) of Mexico (Auditoría Superior de la Federación, ASF) and the Ministry of Public Administration (Secretaría de la Función Pública, SFP), has been working to advance capacity building and harmonisation of audit standards.
The General Act of the National Anti-corruption System (LGSNA), from 2016, states that procedures, techniques, criteria, strategies and professional standards in Mexico’s public sector audit field shall be harmonised. This work is facilitated by ASF at the federal, state and municipal level.
Source: (EUROSAI, 2018[29]) (Sistema Nacional de Fiscalización, 2020[30]).
Different capacity
It is not likely that the different audit institutions will have the same capacity, given the different size of their structures and budgets. Moreover, Brazilian audit institutions have different focuses and priorities in terms of types of audit, particularly regarding performance audit (i.e. some audit institutions are not used to carrying out these audits, while others have more experience with it). Therefore, if the network requests the joint and collaborative work of the audit institutions, it is necessary to take the different capacities into account. For example, when carrying out a co-ordinated activity, one audit institution might be responsible for a more limited activity, given its more limited resources. These cases might be an opportunity for the organisations with more (experienced) staff to help build capacity among the other audit institutions. Another example could be of expertise – for instance, one audit institution that is used to audit environmental issues due to its geographical location might be able to share its expertise with other audit institutions that are less knowledgeable about these issues.
Lack of institutional commitment
Unlike other countries, in Brazil the audit institutions do not have any institutional or legal obligation to collaborate among themselves. Therefore, unless there is a change in the legal framework, the collaboration will be voluntary, including the buy-in of all the courts at the leadership level. Any difficulties in obtaining such commitment might compromise the continuity of the network’s activities. Thus, Brazilian audit institutions must pay particular attention to this issue and engage their efforts for the involvement of management at all the institutions involved.
As seen above, a network might draw upon the audit capacity of each external audit body, individually and collectively, by sharing knowledge among the network members and working together strategically. One powerful way to generate constructive collective action within the network, with the potential for greater impact, is through strategic collaboration on the selection of audits. Chapter 2 described the approach for developing an evidence-based risk assessment for the selection of audit topics. This section provides details on how this approach can be embedded in a collaborative process of audit selection within the network of external audit entities.
TCU and TCs have made concrete efforts to co-ordinate their oversight capacities, including carrying out co-ordinated audits (see Box 4.13 for examples) and capacity building using the ATRICON and the Rui Barbosa Institute as platforms. To date, the co-ordinated audits are usually led by TCU, which selects the topics and engages the participation of TCs in the audits.
The efforts towards collaborative work were also translated into co-operation agreements among TCs, such as:
The Amazon Charter (2010) and the Belém Declaration (2011), both of which proposed the continuous exchange of knowledge and the execution of performance audits with an emphasis on environmental issues
The Campo Grande Declaration (2012), which proposed co-ordinated audits in education and health
The Vitória Declaration (2013), which was intended to guarantee technical and institutional support for co-ordinated audits
The Declaration of Fortaleza (2014), which reinforced the pact to develop co-ordinated audits to evaluate effectively and systematically the results of public policies.
Additionally, some TCs, such as the TCE-Rio Grande do Norte, and the TCU have agreements in place containing general terms of co-operation among the courts. Overall, these agreements do not intend to regulate one specific co-ordinated audit; they set forth, for example, that the courts must include in their audit programming the control activities resulting from the co-operation. The contracts might also establish that one court, notably the TCU, must inform the other court about any federal resources transferred to entities of the relevant level of government (e.g. the State of Rio Grande do Norte and its municipalities), as these transfers might be subject to oversight by both TCs.
Despite these initiatives, to date TCs have not implemented methods or a network to decide on systemic or common issues, including the common selection of co-ordinated audits. Moreover, in general, most TCs do not have any mechanism or co-ordination process in place intended to clarify or define their responsibilities and mandates, or to avoid duplication, fragmentation or overlap of activities.
Co-ordinated audit to assess management of primary healthcare
In 2014, 30 Brazilian courts of accounts carried out a co-ordinated audit to assess the quality of the management of primary healthcare at the federal, state and municipal levels. Among other reasons, primary care had been chosen, to be the core of the country’s health system. The work was performed by 119 auditors from all participating courts of accounts, who visited 317 municipal health secretariats and 23 state health secretariats across the country.
The audit reports issued by the courts of accounts resulted in recommendations and action plans that have been discussed with public managers. The action plans were then used by the courts of accounts to carry out follow-up audits.
Co-ordinated audit for the assessment of public schools’ infrastructure
The TCU and nineteen courts of accounts of states and municipalities have visited 679 public schools in the different regions of the country and have conducted a co-ordinated audit to assess the quality and availability of the infrastructure of these schools.
The assessment of schools resulted in the index “Average Score of the School Infrastructure”, which classifies the schools’ infrastructure as good, acceptable, bad or precarious, taking into account both the availability and the conservation of the facilities. With the results of the audit, the participating audit institutions could conclude, for example, that the majority of the schools classified as precarious and bad were located in the same regions: the north and northeast of the country.
Based on this work, TCU has decided to recommend that the Ministry of Education improve policies relating to support for the infrastructure and the provision of equipment for basic education, with particular attention to the country’s regional disparities. TCU has also recommended that the Anísio Teixeira National Institute of Educational Studies and Research – INEP – improve the data collection process of the School Census.
Co-ordinated audits with other supreme audit institutions
In 2016, under the co-ordination of the TCU Education Secretariat (SecexEducação), TCU and ten other supreme audit institutions (from Chile, Colombia, Costa Rica, Cuba, Ecuador, Guatemala, Honduras, Mexico, Panama and the Dominican Republic) carried out a co-ordinated audit that aimed to evaluate:
the adoption of international good practices by administrative units responsible for generating educational statistics
the capacity of governments to produce statistics to monitor the education systems in each country; the delivery of data and indicators to international organisations
the progress of countries regarding Goal 2 of the Millennium Development Goals and the targets of the UNESCO Dakar Framework of Action on Education for All.
The criteria applied were based on the Code of Good Practices and Regulation 223/2009 of the Statistical Office of the European Union (Eurostat), considered as a practical tool to ensure consistency, comparability and quality of educational statistics produced by the countries.
Source: (OLACEFS, 2016[31]) (TCU, 2015[32]) (TCU, 2016[33]).
In order to increase the synergy and impact of the work among the Brazilian audit institutions, they might develop procedures and mechanisms for collaborative selection and alignment of their audits. Unlike the current co-ordinated audit selection processes, mostly led by TCU, the alignment of audits of decentralised policies might involve all stakeholders. For that to be possible, TCs could benefit from the work of the network. As seen throughout this chapter, it is recommended that the Brazilian audit institutions either establish a new network or improve the existing structures. Either way, the chosen network could dedicate specific efforts to the collaborative selection of audits. These efforts could take the form of a vice-presidency or a committee, with a dedicated team to ensure the activities’ continuity.
For example, the committee could be allocated at one existing committee of IRB, or could be an extension of the Integrar Project (the OECD-TCs project leading to this publication). Building on the knowledge of Integrar Project, the project’s structure could be adapted to be the basis of the committee for collaborative audit selection. The committee, which might have decision powers related to its activities, could eventually be within the IRB (or other existing network) structure, or within the structure of a future national council or network.
Define the collaborative selection of audit as a strategic objective of the network
The development of strategic objectives for audit networks might encourage the appropriate participation of the network members. When drafting strategic objectives, one option is to assign to a small committee primary responsibility for drafting the strategy document and granting the committee a reasonable degree of autonomy in developing the draft; the committee would be composed of representatives from (some or all) network members. Including a broad range of voices in the development process can help build a common vision and increase the legitimacy of the strategy, and hence augment support for it within each audit institution and in the wider society (OECD, 2020[34]) (see Box 4.14 for an example of a network’s strategic plan).
The audit institutions comprising the Australasian Council of Auditors-General have agreed on a set of strategic objectives to be achieved by the network from 2019 until 2022. The strategic plan is based on four key objectives:
1. Knowledge sharing and collaboration – Encourage co-operation and collaboration through knowledge development, sharing and services
2. Collective voice – Identify and collectively respond to emerging issues on a national and international level
3. Capability development – Support ACAG members in developing the capacity to maximise their value and benefits
4. Maximise the value of ACAG as an organisation – Organise and govern ACAG in a way that promotes economical, efficient and effective working practices, timely decision making, and effective governance practices, while maintaining due regard for jurisdictional independence.
Each objective is composed of two or three strategies, followed by specific actions and deadlines for achievement. For example, one strategy for achieving the “collective voice” objective is “to provide a trusted and collective voice on areas of public sector auditing”. Such a strategy will be achieved by actions that include exploring the feasibility of undertaking a collaborative (co-operative) audit. Other actions provided for in the plan include:
facilitating exchange programmes among audit office staff to maximise secondment and other resourcing opportunities
sharing audit methodologies and toolsets while recognising the independence of each jurisdiction to adopt their own methodology
ensuring partnerships and twinning arrangements are developed and implemented
supporting and promoting peer-to-peer co-operation among ACAG members in support of organisational capacity development (for example, peer and quality reviews)
undertaking a review of agreed measures to inform benchmarking among ACAG members
ensuring that each network sub-group produces an annual work plan and reports biannually to ACAG on progress in relation to the plan.
Source: (ACAG, 2019[11]).
Among the strategic objectives of the network, there should be the collaborative selection of audit topics and alignment of audits. The strategic objective might accompany specific activities aiming to obtain the commitment from all audit institutions to participate in the network’s strategic audit programming process. This commitment could be formalised by the participation of at least one representative from each audit institution in the audit selection committee.
Develop a shared approach for prioritisation of audits
The audit selection committee might be responsible for the strategic audit programming process, an opportunity for the members of the committee to discuss and agree on which audits can be pursued by the audit institutions, jointly or collaboratively. This exercise would allow both the committee and each participating audit entity to consider the topics that, within their jurisdiction, may have the biggest impact, while taking account of the audit capacities available (e.g. human resources, professional skills and internal structures). During the process, the committee’s participants might apply the methods described in Chapter 2 related to evidence-based audit selection in decentralised policy areas in order to identify the major fields of action that might require joint efforts.
During the shared audit programming exercise, the committee must consider that the Brazilian audit institutions have in place their own audit practices and ways of working, including their own mechanisms for selecting audits and multi-year audit programming. However, to the extent that the committee might use the methods described in Chapter 2 for selecting collaborative audit work, the methods should not supersede the existing individual audit programming of each audit institution. Nonetheless, for alignment of audits to be possible, the committee (or the network hosting the committee) could advocate before its members that audit institutions dedicate some staff and resources of their institutions to aligned audit programming and joint audit work.
Following application of the methods for evidence-based audit selection – and once the major fields of action are defined, taking into account the objectives of the network – the process for selecting objects of audit can be more focused, leading to the scrutiny of sector information on government actions against selection criteria.
It may therefore be useful for TCs to answer a set of questions that may help prioritise the proposed audit topics in the committee’s deliberative selection process, such as:
Strategic considerations – Does the topic match with the strategic objectives of the network? Is the topic important to citizens and governments at the relevant levels?
Political and societal context – Is the topic considered urgent for all involved audit institutions, given the political and social contexts? Have the governments involved made commitments around the topic and do they have plans to meet them?
Multi-level context – Is working together among multi-levels of government necessary to achieve the commitments or plans around the topic?
Impact – Will the audit potentially make a positive difference? Will there be pressure for auditees to follow up on the recommendations?
Materiality – Does the audited activity or programme have potentially significant financial, economic, social or environmental management implications?
Auditability – Can the audit be carried out with resources that match the impact and materiality of the topic?
Added value to the network – Will the network leverage the impact?
To answer these questions the committee might consider not only the results of the evidence-based audit selection in decentralised policy areas, but also other information exchanged by the audit institutions in the network. For example, the committee should have access to and make use of mechanisms implemented by the network to ensure persistent knowledge sharing among audit institutions (as described in the section above).
Finally, a deliberative process with the participation of the committee members may be implemented to define shared audit programming, which could summarise all planned and announced audit activity to be undertaken jointly by the committee’s members (see Box 4.15 for example).
Audit Scotland works with other scrutiny bodies in that country through the Strategic Scrutiny Group (SSG), to make sure the scrutiny of public sector bodies is well co-ordinated, targeted and proportionate in relation to identified risks. The SSG is convened and chaired by the Accounts Commission and is supported by the Operational Scrutiny Group, whose purpose is to develop and support delivery of a co-ordinated scrutiny plan and opportunities for collaborative scrutiny.
The SSG work is underpinned by the obligations of the Public Service Reform (Scotland) Act 2010 and by the five principles of scrutiny:
public focus
independence
proportionality
transparency
accountability.
In 2008, the SSG established a shared risk assessment process as the vehicle for scrutiny bodies to exchange intelligence and agree scrutiny risks in each of the 32 councils in Scotland. The process has been successful in providing a focus for scrutiny bodies to work more closely together and for more co-ordinated engagement between councils and scrutiny bodies. The process is based on the following principles:
An open and trusting culture – Scrutiny bodies shall share information about risks and planned work with other scrutiny bodies. There should also be an open and transparent relationship with councils wherever possible.
A focus on best value and best use of resources – Scrutiny bodies must work to avoid duplication and should be aware of the impact of the group’s work on the public, the services they receive, local authorities, and other scrutiny bodies.
Better planning – Scrutiny bodies shall be mindful of planning time frames so that they can meaningfully share plans with other scrutiny bodies and with local authorities.
Embedding – There should be a collaborative assessment of scrutiny risks within existing systems, processes, and bureaucracy. This includes engagement with local authorities. This principle also means that the process should be ongoing rather than starting and stopping at one point in the year.
The output of the shared risk assessment process is the National Scrutiny Plan. The latest plan summarises all planned and announced strategic scrutiny activity to be undertaken by the SSG members from September 2019, in each of the country’s councils. The plan highlights the range and nature of scrutiny to be carried out during the year. Given the focus on a risk-based and proportionate approach, scrutiny activity can also change during the year, particularly in response to any significant risks or events that require immediate investigation. Therefore, to ensure that the National Scrutiny Plan keeps abreast of developments and is comprehensive, the SSG updates it on a six-monthly basis in response to any significant changes in scrutiny activity.
Source: (Scotland Strategic Scrutiny Group, 2019[35]) (Scotland Strategic Scrutiny Group, 2019[36]).
Integrate the multi-level governance dimension
As shown in Chapter 3, the way in which the multi-level governance system is structured and how efficiently it works affects the design, implementation and outputs of public policies with subnational impact. It is therefore crucial to consider the multi-level governance (MLG) dimension in audits of decentralised policies. The Brazilian network of audit institutions is an adequate forum to enable this integration.
A working group or committee might be formed within the network with the specific mandate to put in practice the steps described in Chapter 3 on how to map and assess the capacities and resources at each level of government as well as co-ordination mechanisms between and across each level. Once the analytical framework has been defined, it can be used as an input to design and plan audits. The main result of this design phase of the audit process is the audit plan, which usually includes the audit’s objectives, scope, criteria, evidence collection and analysis techniques.
Understanding the topic or object to be audited is important in any type of audit, and good practice is to do this in a pre-audit study. In that respect, development of the MLG assessment framework for a specific decentralised policy area can be considered as such a pre-audit or preliminary study. Therefore, once the committee for audit selection decides on the shared audit programming, it might work in collaboration with the MLG committee to define and refine the audit planning.
Consider establishing a learning cycle
After the audit planning and before the beginning of audit work, the committee’s members (or the members of the participating audit institutions might develop an evaluation process to assess whether the audit objectives, defined at the beginning of the work, have been achieved. The more clearly and precisely these objectives are defined, the clearer will be the evaluation exercise. The evaluation might also address whether and which constraints have impacted the audit work. A repertory of best practices and pitfalls can be a simple way to consolidate the lessons learned (see Box 4.16 for an example from Canada).
In November 2015, a project working group consisting of external auditors from most of the offices in Canada decided to undertake audit work on the progress their governments have made on climate change action. From 2015 to 2018, the provincial auditors-general collaborated with the federal Commissioner of the Environment and Sustainable Development, through the Office of the Auditor-General of Canada, to conduct the audit. The summary report, presented to the Canadian Parliament in March 2018, provided an independent review of government progress on climate change commitments across the country.
Lessons learned
The project team has written and published a final report to document the process and to assist the planning of similar work in the future. The 10 top lessons, according to the team:
Choose an audit topic that is important to all citizens, one where all governments involved have made strong commitments and have plans and strategies to meet them, and where working together among jurisdictions to achieve them is necessary.
Obtain buy-in and commitment from the highest levels in all audit offices before proceeding. In addition to getting approval in principle, it is critical to create a project charter that commits to a vision, resources and timelines, and to have the charter approved.
Begin the project early. The project started two years before the planned presentation month of December 2017, and even then it was not presented until 2018 because several jurisdictions had to move their meeting dates for a variety of reasons.
Designate clear leadership, both at a working level and at other levels. With so many participating legislative audit offices, credible leadership, vision and commitment of resources and expertise were needed.
Ensure regular and structured communication throughout the project. The project working group communicated by phone throughout the project. Minutes were taken and distributed by email for those who could not attend every meeting. A secure and user-friendly method for sharing information and report drafts is important.
Pay attention to early planning decisions for what the audits will include, especially considering the number of participating audit offices, in order to have coherent messages. Draft an outline of the summary report early so that all can work toward it.
Engage experts in the subject matter. The OAG has hired experts to advise participating audit offices on specific matters. They have also convened advisory committees to acquire input to help guide the project. Engagement with experts enhanced credibility.
Understand differences in practices and methodology. Not all legislative audit offices do the same things in the same way. Knowing these differences and finding ways to work with them early is important. For example, the project working group consulted with legal counsel during the examination and reporting phases to help them decide what kind of information could be shared and when. Different audit offices have different practices on this matter, as well as others.
Present the individual audits as close together as possible in order to maximise their impact.
Embrace innovation and adaptability. Thinking outside the box and learning along the way have proved critical to success.
Source: (Office of the Auditor General of Canada, 2018[37]).
The evaluation might take place after the conclusion of the audit, but it might also contain intermediary assessments. Overall, it might assess, through surveys or other indicators:
Adequacy of the audit topic – Was the audit topic important to all citizens? How did the joint work help achieve the audit objectives (i.e. what would not have been achieved without the co-ordination between audit institutions)?
Commitment – Have all the audit institutions involved complied with the timelines and committed to the vision of the network?
Design – Was the audit programming and planning adequate for the audit objectives? What could have worked better?
Communication – Has the communication structure been appropriate? What could have worked better to facilitate the information and knowledge sharing?
Different practices and methodologies – Did the different practices and methodologies negatively affect the audit? How? What measures have been taken in order to address the challenges? What could have worked better?
The results of the assessment might be stored, publicly available and reported to the network’s leadership, as well as to all audit institutions participating in the network.
Building on the measures TCU has already taken towards collaboration in the audit system in Brazil, including the several co-ordinated audits that it has led, TCU and TCs could improve the existing actions by establishing a collaborative network, which might take the form of a national council – or, by strengthening the existing administrative organisation networks.
In order to address the challenges for audit networks, TCs might think carefully about the network governance structure and its operational design. Such a structure might be the basis for developing the mechanisms for collaborative selection and alignment of audits among TCs.
To that end, TCs might define the collaborative selection of audits as a strategic objective of the network; develop a shared approach for the prioritisation of audits; and integrate the multi-level governance dimension as part of a pre-audit study or preliminary audit phase.
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