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This report reviews the implementation by the Rural Payments
Agency and the Department for Environment, Food and Rural Affairs
of the European Union’s single payment scheme in England. The
implementation had cost £122.3 million by the end of March 2006.
The Agency encountered difficulties in processing payments due
under the scheme, totalling around £1,515 million, and failed to
meet its own target to pay 96 per cent of that sum by the end of
March 2006.
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The factors contributing to the difficulties experienced
included:
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a the Department and the Agency had not fully appreciated the
risks and complexities involved in implementing the English model
of the single payment scheme. This was, in part, due to a lack of
common understanding of the scheme requirements and likely customer
behaviours across all key teams within the Department and the
Agency;
- an absence of clear
metrics against which to assess progress on implementation led to
over optimistic upward reporting, and hence a failure to show the
true state of progress. As a consequence, the related risks of
failure became apparent at too late a stage to enable effective
alternative payment regimes to be put in place; and
- in implementing the scheme
at the same time as a wider business change programme aimed at
delivering efficiencies, the Agency lost too many of its
experienced staff and, as a consequence, the knowledge which went
with them.
- Implementation has not provided value for money because the
project has cost more than anticipated and is not fully implemented
as scoped, planned efficiency savings will not be achieved,
relationships with the Agency’s customer base have been damaged and
there is a risk of substantial disallowance of expenditure by the
European Union.
- The previous Chief Executive was therefore removed from post on
16 March 2006 and at the end of September 2006 remained on leave of
absence on full pay of almost £114,000 a year. [Footnote 1]
The new Chief Executive and senior managers at the Agency have
demonstrated a business-like approach to learning lessons from what
happened with the 2005 single payment scheme and are acting on the
recommendations we have made. The Agency is unlikely to be able to
remedy all the problems in time for the 2006 single payment, but
the management team is developing a recovery plan which they expect
to be fully implemented by April 2008.
Key Findings, Conclusions and Recommendations
- The European Unions single payment scheme replaces 11 previous
subsidies to farmers based on agricultural production with one new
single payment based on land area.[Footnote 2]
Landowners and farmers in England who kept their land in good
agricultural and environmental condition in 2005 could claim
payment from the Rural Payments Agency (the Agency accredited under
EU Regulations to administer the single payment scheme in
England).[Footnote 3] Under EU Regulations 96.14 per cent of the
Agencys single payment scheme funds of the estimated 1,515 million
had to be paid by the end of June 2006 in order to be sure of
avoiding late payment penalties.
- The Department for Environment, Food and Rural Affairs
(the Department) regards the model of the single payment scheme in
England as more forward looking than those in most other European
countries. EU Regulations offered some discretion to
Member States over how to implement the single payment scheme and,
as Appendix 1 shows, England and Germany were the only countries to
adopt the dynamic hybrid model for 2005.[Footnote 4/Footnote 5] Ministers considered that this model was the
most suited to giving farmers in England greater freedom to respond
to market demands for agricultural products, and to reward
environmentally friendly farming practices.[Footnote 6]
The Department recognised that their approach had a high risk of
not being delivered on schedule.[Footnote 7]
- The Agency spent 122.3 million on implementing the
single payment scheme as part of a wider business change
programme. The Agency deals with a range of EU subsidies
and other activities, such as cattle tracing. From its inception in
2001 the Agency had embarked on a business change programme to
improve efficiency but had to revise its approach in November 2003
to include the development of the single payment scheme, which then
became the key element of business change. The way the scheme was
implemented was designed to achieve efficiency savings by enabling
staff in different offices to work on any tasks relating to any
claim, rather than for the same individual or small team to process
a whole claim from end to end. The Agency anticipated that this
task based approach would enable faster processing and improve
staffing flexibility.
- The Agency encountered difficulties in processing
payments under the single payment scheme, and failed to meet its
own target to pay 96 per cent of the money due to farmers by the
end of March 2006. As at 31 March 2006 the Agency had paid
225 million (representing 15 per cent of the 1,515 million single
payment scheme funds) to 31,040 farmers (27 per cent of the 116,474
claimants). The Agency made payments of 515 million by the end of
April 2006 by streamlining processes for authorising payment once
claims had been validated. Taking into account the risk that the
remaining payments could otherwise have been deferred beyond the
end of June 2006, the Agency made partial payments of 730 million
in May 2006 with the agreement of the Department and
Ministers.[Footnote 8] The Agency paid out 1,438 million (95 per cent)
against an EU deadline of 96.14 per cent by the end of June 2006,
and 96 per cent of sums due by the end of July. By the end of June
most farmers had been paid, except for 8,586 farmers (seven per
cent) who had not received any money, and 16,168 (14 per cent) who
had received partial payments amounting to 80 per cent of their
claim. The delays, in particular the Agencys failure to meet its
target for payments in March, led to the removal from post of the
Chief Executive and increased Parliamentary interest in the
performance of the Agency. This report examines the impact of the
difficulties experienced by the Agency, the events that led to the
delay in paying farmers, and what lessons can be learned and
applied in future.
Overall conclusions
- The single payment scheme is not a large grant scheme compared
to some government programmes, but the complexity of the EU
Regulations, the complex way in which the Department planned to
implement them in England, combined with the deadlines required to
implement the scheme for 2005, made it a high risk project. By
choosing to integrate the scheme into a wider business change
programme, the Agency added to its already considerable challenges.
Many of the Agencys difficulties arose, however, from:
- underestimating the scale of the work needed to implement the
scheme;
- over optimistic progress reporting; and
- governance structures which, in practice, proved overly
complex, and the absence of clear metrics, arising from the lack of
appropriate management information that would have allowed the
oversight boards to measure progress objectively.
By the end of March 2006 implementation of the single payment
scheme had cost 46.5 million more than the Agency had anticipated
in its November 2003 business case. The implementation of the
single payment scheme and the wider business change programme had
cost 258.3 million, will not achieve the level of savings forecast,
and there is risk of substantial costs for disallowance by the
European Commission. The farming industry has also incurred
additional costs, 20 per cent of farmers have experienced stress
and anxiety as a result, and five per cent of respondents to our
survey said they have considered leaving farming.
- The Agency has begun processing the 2006 single payment scheme
claims ahead of the European Commissions payment window from
December 2006 to June 2007. In view of the large number of changes
required, the Agency has confirmed that it is unlikely to be able
to remedy all the issues highlighted in our report in time for the
2006 single payment scheme. As a consequence, our recommendations
include actions that the Agency should take to improve performance
in the longer term as well as in 2006. We have also identified a
number of recommendations with broader application to reduce the
likelihood of other projects encountering similar problems in the
future.
The impact of the difficulties experienced by the Agency
- The difficulties in making payments have caused
distress to a significant minority of farmers. Twenty per
cent of the farmers surveyed by Ipsos MORI on our behalf said that
the delays had caused distress and anxiety for them and their
family. For some, such as many hill farmers, the single payment
scheme is a significant proportion of their family income. We
estimate that the delays have cost farmers between 18 million and
22.5 million in interest and arrangement fees on additional bank
borrowing. The wider knock-on effects on the farming sector are
difficult to quantify, but some farmers claim to have postponed
purchases, sold crops and livestock early or delayed payments to
their suppliers. The Secretary of State for Environment, Food and
Rural Affairs announced on 22 June 2006 that, calculated from 1
July 2006, the Agency would pay interest to farmers in respect of
delayed payments at one per cent above the London Interbank Offered
Rate.[Footnote 9]
- We identified a number of errors and procedural
weaknesses by the Agency in making payments to farmers in
2006. The Agencys systems were designed to make most
payments by automated bank transfer and in a number of cases the
Agency used other systems to speed up farmers receipt of funds,
especially where hardship was involved or regulatory deadlines were
approaching. The Agency found that one batch of payable orders
(amounting to 14.6 million) had not taken account of partial
payments which had already been made. The Agency took immediate
action in response to the review and stopped all the payable orders
before farmers could cash the money. However, the Agency has yet to
recover a further 5.4 million of overpayments that were made as a
result of an error introduced in the computer system. In addition,
as at 15 September 2006 we had identified 34 overpayments and 79
underpayments in our sample of 363 cases which, if replicated
across the whole population, are most likely to result in errors of
6.5 million and 17.4 million respectively.[Footnote 10] Many of the mistakes arose from errors in inputting
data onto the computer system. In 105 of the 113 cases, the error
related to the flat rate per hectare element, which represented
only 10 per cent of the value of claims in 2005.
- Errors and procedural mistakes in administering the
scheme in England have created a risk that the European Commission
will impose a financial correction, for which the Department has
recognised provisions and contingent liabilities totalling some 131
million in its 2005-06 accounts. The European Commission
can disallow expenditure if the Agency has not wholly complied with
its regulations, leaving the Department to bear the cost. The
figure of 131 million represents the Departments prudent estimate
based on the guidance available, at this stage, of what the
financial corrections could be. Any disallowed amount is subject to
clarification and negotiation with the European Commission. The
Agency and the Department confirmed that, on occasion, the European
Commission had subsequently revised down its initial assessment of
potential disallowance. In advance of discussions between the
Department and the European Commission it is not certain, however,
what disallowance might be incurred on the 2005 single payment
scheme.
- There appears to be little prospect that the Department
and the Agency will achieve much of the 16 million efficiency
savings they had forecast between 2005-06 and 2008-09. The
Agency is hopeful that savings could be made in future, but it has
yet to develop a revised business case specifying how this can be
achieved. The Agency had anticipated that its new task based system
could reduce the number of staff employed by 1,800 posts from a
baseline of 3,950 posts. The Agency met its target to reduce its
headcount of permanent staff by 1,000 posts by the end of March
2006, at a cost of 38.9 million. At this date, however, there were
2,140 permanent staff, plus 838 casual staff and 1,351 contract
staff to deal with outstanding claims for the 2005 single payment
scheme. Since then, the Agency has abandoned its task based
approach to processing the single payment scheme and, although the
volume of work associated with the 2005 scheme may subside,
reverting to a client based approach, which is aimed to speed up
payments, will not necessarily generate significant savings. Corven
Consulting, commissioned by the Department to review the single
payment scheme, reported in June 2006 that they have identified
potential savings of 7.5 million achievable by March 2009.
- The project to implement the single payment scheme has
cost 6.5 million more than anticipated, and further cost increases
are likely. According to the Agencys financial data, the
outturn cost at March 2006 of 122.3 million (compared to an
original budget in November 2003 of 75.8 million) does not take
account of the deferral of some key elements of the system, such as
the software required to extract management information. The Agency
are also considering plans to commission further development work
to improve the performance of the computer system. By March 2006
the implementation of the single payment scheme and costs relating
to the wider business change programme totalled 258.3
million.
- The former Chief Executive was removed from post in
March 2006 and at the end of September 2006 remained on leave of
absence on full pay. The Department has yet to determine
the terms of his departure.[Footnote 11]
The events that led to the delay in paying farmers
- The timetable for the implementation of the single
payment scheme became very tight following required changes to the
original specification of the computer system. The Agency
had anticipated that the development of the core IT infrastructure
would be complete by December 2004. By this date, however, the
Agency had identified 23 changes to the computer systems under
development, largely to incorporate changes to EU Regulations and
legal clarifications of those Regulations, Ministerial decisions
and other changes identified.[Footnote 12] The Agency considered that failure to implement these
changes would have exposed the Department to a significant risk of
disallowance by the European Commission. In accordance with EU
Regulations the Department had already notified the Commission of
the United Kingdoms decisions on implementation of the single
payment scheme by 1 August 2004 and did not consider that deferral
to 2006 was an option. The revised timetable anticipated completion
by September 2005 and deferred the date of the first payments from
December 2005 to February 2006.
- To keep to the timetable, the Agency implemented key
aspects of the IT system without adequate assurance that every
component was fully compatible with the rest of the system and
supporting business processes. The Agency did not have
time to test the system as a whole before it began making payments.
Each key element of the system was tested before introduction, but
problems arose afterwards as the testing of each system in
isolation could not fully simulate the real world environment. The
claim validation and inspection system, for example, had issues
outstanding when it was implemented (such as computer screens
freezing), and the Agency reported that the system had subsequently
proved unstable. Accenture and the Agency confirmed to us, however,
that the problems experienced in July and August 2005 have now been
overcome and that the system is now stable.
- The Agency underestimated the work involved.
The Agency did not adequately pilot test the process of registering
farmers, accurately mapping their land and confirming eligibility.
It had expected to record 1.7 million parcels of land, but had to
deal with 2.1 million parcels. Some of the land related to new
claimants, of whom some had very small landholdings, but 36 per
cent of the increase arose when existing farmers registered
additional land. The Agency consider that most of this additional
land should have been registered in previous years under the EU
Regulations governing the subsidy schemes that the single payment
scheme replaced.
- The Agency did not have adequate management information
to monitor progress and forecast future work effectively.
The Agency had deferred the development of software to draw out key
information on the progress of each claim in order to focus
resources on parts of the system it considered would increase the
chances of meeting the tight deadline. As a consequence, the Agency
found it difficult to determine how much work remained outstanding
on claims each week and how much time it would take to complete
them.
- The Agency had to rely on temporary and agency staff to
process claims, but many lacked experience in dealing with such
work. The Agency confirmed that it had an induction
programme for everyone brought in to work on claims, but our
interviews indicate that the training team struggled to deal with
the volume of work and some temporary staff had to rely on advice
from colleagues and experts in each office on how to deal with
claims. The Agency spent 14.3 million on agency staff in 2005-06 to
process 2005 single payment scheme claims.
- Despite limited confidence that the system would be
ready on time, development work on the computer system continued
and no contingency plan was invoked. In June 2005, the
Department informed the Secretary of State and the Minister of
Farming that an OGC Gateway review had assessed the programme as
red, meaning that the Chief Executive of the Agency was recommended
to take urgent remedial action to address the issues which had been
identified. The Department also advised that there was only a 40
per cent confidence that payments would in fact commence, as
planned, in February 2006. The same OGC Gateway review, Gate 4b,
recommended that action was taken to identify and analyse fallback
options to safeguard payment deadlines. However, the Department and
the Agency assessed that continuing development of the existing
computer system provided a greater possibility of meeting the
payment target than relying on the contingency system under
development by Sungard and Xansa. The Department did not therefore
recommend invoking a contingency system or, because it did not
believe it was an available option, delay use of the new computer
system until 2006.
The lessons to be learned
- It may have been expensive to develop and maintain
suitable contingency arrangements, but the high risks of the new
system being developed, and of the potential consequent
disallowance by the European Commission of the payments made, might
have warranted such costs. The Agency initially developed
an alternative, costing 8.4 million, which adapted its legacy IT
systems to make 2005 payments. As the contingency relied on the
same data as the new system being developed it was mothballed once
claims started to be processed using the new system. Continued
development work to run the contingency in parallel would have
absorbed further resources and spread more thinly the limited
number of staff with the required knowledge of the scheme and
development skills. Furthermore, many of the difficulties with data
accuracy would have arisen with the contingency system and the
Agency considered that its ability to process them was understood
less than the main system that had been the focus of attention.
Nevertheless, as the contingency system would have processed
payments on a claim by claim basis, rather than task by task, the
Agency may have found it easier to resolve outstanding data
queries. After mothballing that contingency system and the adoption
of an EU Regulation in October 2005 which permitted partial
payments, the Agency decided to develop as a fallback a new system
to make partial payments which was available from the end of
January 2006. This fallback was not invoked because of the
perceived progress to enable full payments. A decision to implement
an alternative partial payments system based on 80 per cent of
claim values was taken in April 2006. Our consultants, RAND Europe,
confirmed that in Germany the Federal Ministry of Food, Agriculture
and Consumer Protection used its contingency scheme to make advance
payments in December 2005, and final payments in April to June
2006. Until the relevant auditors report in January 2007, however,
it will not be clear whether this payment scheme complied with the
European Commissions requirements.
- The Office of Government Commerce undertook four OGC
Gateway reviews between May 200 and February 2006, three of which
assessed the programme as red. The reports focused on the
leadership of the project and Ministerial involvement, IT issues
and relations with the contractor. There was some consideration of
wider issues that would impact on the success of the scheme but
more attention could have been paid to issues such as staff morale
and training, or the Agencys relationship with farmers. The Office
of Government Commerce is carrying out its own case study review of
the Agencys business change programme, as part of which it is
reviewing the role of the OGC Gateway process and whether there is
scope for possible improvements, including the scope for carrying
out more Gate 0 reviews during a project, which are designed to
take a more holistic view.
- The Department and the Agency put in place appropriate
arrangements to oversee progress, but as the deadline got closer,
the two key oversight boards took greater control of
implementation. We reviewed the structures for overseeing
the project early in 2005 and confirmed to the Agency that, in
principle, they provided a sound basis on which to manage the
project risks. In practice, however, as the programme entered its
final, critical, phase the distinction between the two oversight
boards became less clear and the conclusions of one board (the CAP
Reform Implementation Board) were typically referred to the other
(the Executive Review Group) for approval.[Footnote 13] The OGC Gateway Review recommended in June 2005 that
one individual should be given responsibility for managing the
decision making process. This recommendation was not adopted for
the 2005 scheme, but the Executive Review Group agreed that this
lesson should be learned for the 2006 scheme.
- The Executive Review Group became embroiled in
progressing the project rather than exercise an obvious challenge
function. Nearly all the members of the Review Group were
senior officials within the Agency and Department with policy or
operational responsibilities for the single payment scheme, and
there was only one non-executive member appointed. Our interviews
with senior officials confirmed that the papers submitted by the
Agency for each meeting were difficult to understand. Nonetheless,
those officials believe that they were still able to exercise an
appropriate challenge function, although this was not always clear
from our review of the minutes. The former Chief Executive
confirmed to us his belief that the CAP Reform Implementation Board
came to supercede his role as senior responsible owner of the
delivery of the single payment scheme, its decisions subsequently
being ratified by the Executive Review Group.
- Clearly defined metrics for the Executive Review Group
would allow a more objective measure of performance. The
former Chief Executives progress reports to Ministers were unduly
optimistic and the progress reports and other papers prepared by
the Agency were overly complex, and did not spell out overall
performance clearly enough. In the absence of adequate management
information systems, robust and objective data were not readily
available meaning that clearer output measures (such as the
cumulative number of maps registered or the progress of claims
through the validation process) which might have triggered
corrective actions earlier, could not be set.
- The Department allowed the Agency too much discretion
and independence in implementing the single payment scheme given
the potential liability it faced and the consequent risks to its
reputation. Senior departmental officials confirmed that
they had concerns in late 2005 about whether the Agencys management
team could deliver the single payment scheme on time, but felt that
making changes at that time would have been more disruptive and
raised the risk profile of the project even higher.
- As the pressure built, day to day communications with
farmers proved difficult and a lack of information on the progress
of their claims led to stress and frustration amongst the Agencys
primary customers. The Agency relies on farmers
cooperation to administer the payments scheme effectively. The
absence of key information on the progress of each claim hampered
the ability of staff in the customer contact centre to resolve
farmers queries.
- We recommend that the Agency:
- Undertakes a cost benefit
review by the end of March 2007 of the processes and systems it has
developed for administering the single payment scheme to determine
whether each component is, and is likely to remain, adequate for
business needs.
- Reviews the high risk and
high value claims paid in 2005 to confirm their accuracy, before it
commences the associated 2006 payments.
- Finalise and test plans
for a partial payment system for 2006 claims before the payment
window commences in December 2006 in case such arrangements prove
necessary.
- Contact those farmers who
are known to have been overpaid for the 2005 single payment scheme
before the end of October 2006 to agree arrangements to recover the
money.
- Draw to the attention of
farmers the payments calculator available on the Agencys website so
that they can check the reasonableness of their 2005 payment before
the start of the 2006 payment window. This tool could help identify
those farmers who received less than they were entitled to in 2005,
and enable any underpayments to be remedied.
- Develop adequate
management information systems by Summer 2007 to enable the Agency
to track the progress of claims.
- We recommend that the Department:
- Review the Agencys plans
for partial payments for the 2006 single payment scheme to
determine whether they are cost-effective and likely to comply with
EU regulatory requirements.
- Drawing upon the results
of the Agencys review of 2005 high risk and high value claims,
develop a robust case by the end of 2006 that could be used in
negotiations with the European Commission to minimise the extent of
disallowance likely to be imposed.
- Simplify reporting
arrangements between the Agency and the Department so that in any
future projects there are clear lines of accountability between
them.
- Develop a clear set of
metrics for this project and any similar projects in future that
can be used by senior officials and members of project oversight
boards to measure progress objectively. These metrics should
include quantifiable, objective measures of outputs. In the context
of the single payment scheme it should be possible to relate these
measures directly to progress processing farmers claims, such as
the number of maps registered each week compared to target.
- Agree arrangements with
delivery bodies at the outset of a project that, if the performance
metrics dictate, the Department would instigate a review of
progress to determine whether changes are required. Such reviews
could be undertaken by internal audit, the Office of Government
Commerce or, if appropriate, by inviting the National Audit Office
to examine progress.
- Resolve the former Chief
Executives employment status as soon as possible.
- We recommend that the Office of Government
Commerce:
- For the key mission critical projects (where OGC has a direct
intervention role), use the Gateway Report, together with the wider
evidence, to specify the circumstances in which it would be
appropriate for the senior responsible owner to notify the
Permanent Secretary and Ministers that a project should either be
stopped or fundamentally reviewed. For projects in general, OGC
should make use of capability reviews of departments’ programme and
project management Centres of Excellence (as being piloted by OGC)
to ensure that departments’ processes give them access to the full
body of knowledge on projects so they can take appropriate
decisions on whether a project should be stopped or fundamentally
reviewed.
- Review, before the end of
2006, how red reviews, and in particular, multiple red reviews, are
dealt with in future in terms of guidance to the senior responsible
owner and bringing them to the attention of the Permanent
Secretary.
- Examine whether existing
OGC Gateway review procedures pay sufficient attention to the
softer aspects of a project, such as staff training and skills, and
customer expectations.
-
- [back from footnote 1] This is less than he
was paid in 2005-06 as his pay in that year included a bonus for
performance in 2004-05 and a housing allowance. The terms of his
departure will be reported publicly when they are settled.
- [back from footnote 2] Arable Area Payments
Scheme, Beef Special Premium, Extensification Payment Scheme, Sheep
Annual Premium Scheme, Suckler Cow Premium Scheme, Slaughter
Premium Scheme, Veal Calf Slaughter Premium Scheme, Dairy Premium,
Dairy Additional Payments, Hops Income Aid, and the Seed Production
Aid.
- [back from footnote 3] Regulations define a
farmer as any person or organisation whose holding is situated
within Community territory and who exercises an agricultural
activity or maintains their land in good agricultural and
environmental condition. Similarly, in this report we have used the
term farmer to include all people with land eligible for payments,
whether or not they farm the land commercially.
- [back from footnote 4] Under the dynamic
hybrid model chosen in England, the value of payment entitlements
is based partly on claimants average subsidy receipts, if any,
between 2000 and 2002, and partly on a flat rate per hectare.
Ninety per cent of the English financial ceiling was used to fund
the historic element of entitlement values and 10 per cent to fund
the flat rate element in year one of the scheme, and the weighting
transfers to the flat rate in incremental steps of five per cent to
15 per cent each year (see Appendix 1).
- [back from footnote 5] Whereas, according to
our consultants, RAND Europe, the German government set a 100 euro
de minimis claim limit, the Department did not adopt such an
approach because all four UK Departments (the decision having
legally to be made at Member State level) concluded that it was the
calculation of the entitlement values that absorbed the processing
effort and that having done that work it was simpler to make the
payment. In addition, the Department introduced three separate
categories of land in England, each of which attracted a different
flat rate of grant. Set against that in Germany there was a
different flat rate in each of the German Lander and different
payment rates were set for grassland and arable land. This was an
option considered in England but not adopted.
- [back from footnote 6] Secretary of State for
Environment, Food and Rural Affairs statement on CAP reform:
implementation of the Single Farm Payment Scheme in England,
Hansard 12 February 2004, volume 417 Session 2003-04, columns
1585-1587.
- [back from footnote 7] Partial Regulatory
Impact Assessment on Options for the Implementation of the Reform
of the Common Agricultural Policy: Allocation of the single payment
entitlements, July 2004 (published at http://www.defra.gov.uk/farm/capreform/background/pdf/RIAv1.pdf).
- [back from footnote 8] The partial payments
represented 80 per cent of what the Agency estimated would be the
total amount of each claim. The payments were made to those farmers
who had not already received a payment and who had a claim of over
1,000.
- [back from footnote 9] House of Commons, Oral
Answers to Questions, 22 June 2006, column 1478.
- [back from footnote 10] The overpayments and
underpayments represent our estimate of the most likely error based
on our sample testing as at 15 September 2006. We can be 95 per
cent sure that the maximum overpayment would not exceed 20.2
million and the understatements would not be more than 37.1
million. The Agency are still investigating our queries on a
further 33 cases from our sample of 363 cases. In these cases,
however, the Agency has not yet processed the final payments and
any errors found can be rectified beforehand.
- [back from footnote 11] The terms of his
departure will be reported publicly when they are settled.
- [back from footnote 12] An example of the
other changes was amendment to the layout of the application
form.
- [back from footnote 13] The CAP Reform
Implementation Board was responsible for technical programme
management. It was chaired alternately by the Chief Executive of
the Agency (who was senior responsible owner of the Rural Payments
Agency change programme) and the Director General for Sustainable
Farming, Food and Fisheries at the Department (who was senior
responsible owner of CAP reform). The Executive Review Group was
chaired by the Permanent Secretary, and its role was to provide a
critical challenge function.