Financial accounting and reporting updates

NHS providers should refer to this page for the latest updates on financial accounting and reporting. We also email updates to finance teams.

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International Financial Reporting Standard (IFRS) 16 Leases

Our IFRS 16 guidance now has its own webpage. The latest updates will listed on this page.

Current form and submission issues – updated 23 January 2023

The following table lists known issues in the month 9 2022/23 PFR form:

Reference Issue Status
TAC00 / TAC Validation 1 NEW: Some providers have a 1 April transition adjustments for an existing headlease previously classified as an operating lease and an associated adjustment for an existing sublease now classified as a finance lease. Where the counterparty classification of the headlease and the sublease differ, providers will be unable to pass TAC validation 1 due to the absence of a right of use asset entry for each of the two counterparties. Where providers are affected by this issue, we will accept files with validation 1 failing but the variances on the counterparty columns MUST net to nil. In most cases, the variance is expected to equal the 1 April adjustment for the sublease receivable. If in doubt, please email the provider accounts team who will review the form prior to submission.
TAC07 Op Inc 2 (F166 to F171) The sum formulae in these cells are omitting columns P and Q FIXED in V1.22.09.1A 20 January
TAC validation 186 Populated figure for PDC cash payments (from fixer v1.22.09.1 issued 13 January) into validation 186 has different sign to the TAC input cell FIXED in V1.22.09.1A – fixer issued 20 January.
TAC29 – Losses and special payments (rows 35 and 53) Figures relating to overtime corrective payments in 2021/22 have been omitted when pre-populating comparatives into this note. FIXED in v1.22.09.1 – fixer issued 13 January. Missing comparatives added.
TAC04 – SOCIE Hidden row 16 contains a formula that duplicates row 17, double counting IFRS 16 implementation adjustments on consolidated charitable funds. FIXED in v1.22.09.1 – fixer issued 13 January.
TAC04 – SOCIE Revaluations of right of use assets are not currently pulled from TAC23 into TAC04. Existing revaluations rows pick up PPE and intangible assets only. FIXED in v1.22.09.1 – fixer issued 13 January.

An additional row for revaluations of right of use assets has been added.

Latest financial reporting updates

TAC Completion Instructions: month 9 2022/23 – 21 December 2022

Guidance on completing the Trust Accounts Consolidation (TAC) schedules for month 9 2022/23: TAC Completion Instructions M09 2022-23

Month 9 2022/23 accounts timetable – 9 December 2022

We have issued the accounts timetable for month 9:  Accounts timetable month 9 2022-23

Referencing directions in late 2021/22 accounts – 6 July 2022

The following text provides guidance on references in 2021/22 accounts finalised after 1 July 2022. In summary no changes to template disclosures are required.

NHS trusts

There are no changes to the template disclosures provided for NHS trust annual reports and accounts for 2021/22.

  • For annual reports, the change in the Health and Care Act transferring this power to NHS England commences on 1 July. However, a saving provision in regulations will mean that the changes do not apply to annual reports for the financial year 2021/22 – so the existing Secretary of State power continues to apply to those reports.
  • For accounts, DHSC has reissued its accounts direction to update a legislative reference. This will be published in the 2022/23 Group Accounting Manual (GAM) and is attached here for reference. There are no changes in substance and NHS trusts’ disclosures should continue to refer to a direction from the Secretary of State

NHS foundation trusts

There are no changes to the template disclosures provided for NHS foundation trust annual reports and accounts for 2021/22.

  • While Monitor is abolished as entity from 1 July 2022, its functions transfer to NHS England and directions issued by Monitor continue in force. As such 2021/22 annual reports and accounts finalised after 1 July 2022 should continue to refer to directions issued by Monitor.
  • New directions will be issued for the 2022/23 financial year by NHS England.

CCGs

(This guidance is included here for ease of reference for local auditors to publish in one place.)

There are no changes to the template disclosures provided for CCG annual reports and accounts for 2021/22.

  • Directions were originally issued in the legal name of the NHS Commissioning Board. It is now in force that the legal name of the entity is NHS England, but this name change does not affect the legal status of the directions, and references to the Board should now to be read as references to NHS England.
  • Transitional provisions in regulations require ICBs to finalise their predecessor CCG(s) reports and accounts for 2021/22. ICBs will also be responsible for producing CCG annual reports and accounts for the period 1/4/22 to 30/6/22. Directions for these are available separately via NHS England Sharepoint.

2021/22 year end timetable letter – 4 February 2022 (updated 24 June 2022)

The NAO has set a deadline of 30 September for local auditors to finalise their work and reporting on value for money arrangements for 2021/22.

We have updated our 2021/22 timetable letter to include:

  • A 30 September deadline for finalising annual report and accounts for 2021/22, and publishing by NHS trusts
  • Deadlines for further tranches of laying before Parliament for NHS foundation trusts, and guidance on what to do if an FT is unable to meet the 30 September date above due to delayed laying.

Timetable letter:

Accounts payable addresses for ICBs from 1 July – 15 June 2022

NHS SBS has been working closely with NHS England to ensure accounts payable processes are up and running for ICBs from 1 July. Accounts payable addresses for all ICBs from 1 July can be found here. Please use this information to update local finance systems.

A mapping document of CCGs to ICBs is also available here. Any outstanding invoices on CCG ledgers are expected to be transferred to ICB ledgers during July.

Reminder: special payments  – 10 June 2022

NHS providers are reminded that all special severance payments of any value require approval in advance of agreeing the payment. The NHSE&I team has guidance at https://www.england.nhs.uk/publication/severances/ and can be contacted at nhsi.vsmcases@nhs.net

In addition all special payments (not special severance payments) above £95k – and those of any value that may be considered novel, contentious or repercussive – require approval as explained in our letter of April 2021. The mailbox for these matters is England.assurance@nhs.net . Guidance on the definition of special payments is provided in Managing Public Money, annex 4.13: https://www.gov.uk/government/publications/managing-public-money (second file). Providers are reminded this includes retention payments to staff or a group of staff.

Please ensure special payment disclosures in 2021/22 accounts and TAC schedules are complete.

Audited accounts and annual report submission checklist – 1 June 2022

We have prepared our annual year end checklist to aid providers with preparations for submitting the audited annual report and accounts. This checklist contains no new information but is available to download if useful.

FT Annual Reporting Manual 2021/22 update – 6 May 2022

We’ve made a minor update to the FT ARM to improve the suggested format for the NHS staff survey disclosure to align with the new format of the survey.

NHS pension scheme disclosure for 2021/22 – 22 April 2022

The template disclosure on the NHS pension scheme for inclusion in 2021/22 accounts is now available.

Month 9 2021/22 TAC feedback on common errors – 8 March 2022

This document lists common errors made in Trust Accounts Consolidation (TAC) schedules at month 9 2021/22. Providers are asked to please ensure any issues impacting your Trust are addressed at month 12.

NHS foundation trusts: FT Annual Reporting Manual (FT ARM) 2021/22 – 2 March 2022

The  FT ARM 2021/22 has now been published.

To facilitate copying, a Word document of the model Annual Governance Statement (AGS) and other certificates/statements needed for the annual report and accounts is also available below.

NHS trusts: 2021/22 annual governance statement and certificates for year end accounts – 25 February 2022

The following document provides guidance to NHS trusts preparing annual governance statements (AGS) for their annual reports. It also contains the required formats for other certificates/statements for year end accounts.  A Word document is also provided to facilitate copying. This does not apply to NHS foundation trusts who should follow the formats prescribed by the FT ARM.

Injury Cost Recovery (ICR): probability percentage – 7 December 2021

The Compensation Recovery Unit (CRU) advises a percentage probability of entities not receiving ICR income. The CRU advises the percentage for 2021/22 is 23.76%. For 2020/21 the percentage was 22.43%. Updated guidance has been published here.

Impact of auditor value for money arrangements conclusions on audit certificates – 4 June 2021 (updated 27 August 2021)

NHS foundation trusts: laying of annual reports and accounts

From 2020/21, NHS local auditors will issue the ‘auditor’s annual report’, replacing the previous annual audit letter (not previously applicable to all NHS foundation trusts), which will include the auditor’s commentary on use of resources (value for money) arrangements. For NHS bodies this would usually be issued at the same time as the audit report containing the audit opinion on the accounts. For 2020/21, as part of the response to the coronavirus pandemic, the NAO has said that auditors at NHS trusts and NHS foundation trusts can issue the auditor’s annual report at a later point than the audit opinion on accounts, by 20 September.

When the auditor issues the audit report on the accounts (containing the audit opinion, and included within the annual report and accounts), this also includes a certificate that the auditor has completed their work. Where the auditor’s work on VFM arrangements is not complete at the time of issuing the opinion on the financial statements, or in some cases where the auditor is still drafting their auditor’s annual report, the audit certificate will not be issued at the same time as the audit opinion. This means that the audit report and certificate is not final, so the annual report and accounts (in which it is included) is also not final. Paragraph 1.10 of the FT ARM 2020/21 lists the required components of an FT’s annual report and accounts, and this incorporates the auditors’ report including certificate.

Therefore an NHS foundation trust cannot lay its annual report and accounts before Parliament until the auditor has issued the audit certificate. It is the Trust’s responsibility to ensure that its annual report and accounts document is complete. Paragraph 1.20 of the FT ARM explains that laying before Parliament must precede local publication.

For NHS foundation trusts able to lay their document before the summer Parliamentary recess, e-laying arrangements (i.e. no printed copies) are still in force. Arrangements for laying after the summer have not yet been communicated. We hope to set out the deadlines and arrangements for laying for FTs next week.

Guidance for NHS trusts

While NHS trusts do not lay their annual report and accounts before Parliament, NHS trusts are advised that their annual report and accounts document is not complete until the audit report (opinion) is accompanied by the audit certificate, as explained for NHS foundation trusts above.

Inclusion of the audit certificate in annual reports

Where later completion of the auditor’s use of resources work means the audit certificate is finalised at a later date than the true and fair audit opinion, we understand that the audit certificate will be issued as a separate document at that later date and both should be included within the annual report. The annual report will include the audit report (with audit opinion) at the original date, and the audit certificate signed at the later date. Please do not attempt to merge the two.

Special payments – 22 April 2021

Following this letter, organisations are reminded that proposed special payments that are either (i) above £95,000 and/or (ii) considered potentially novel, contentious or could cause repercussions elsewhere in the public sector, should be submitted for HM Treasury approval. Please contact england.assurance@nhs.net with any queries over this process.

Year end accounting guidance for 2020/21 items – updated 26 March 2021

A third version of guidance on accounting for 2020/21 items has been issued. The main update is adding the process for communicating details of testing equipment. The trusts to which this applies received a listing from Provider Accounts on 26 March. The guidance in this document remains applicable for the 2021/22 year end.

Accounting for additional employer pension contributions 2020/21 – 22 January 2021

The employer contribution rate for the NHS Pension Scheme increased from 14.38% to 20.68% from 2019/20, but NHS providers have continued to pay over at the old rate with the additional 6.3% being settled centrally on their behalf by NHS England. As was the case for 2019/20, in 2020/21, the full 20.38% needs to be reflected in local provider accounts, with notional income from NHS England being recognised for the 6.3% element.

For the purposes of accounts NHS England will again compute the full year 6.3% figure for each provider, extrapolating from data provided by NHS BSA at month 10. We will communicate this figure to providers and populate a validation in month 12 TAC schedules. Based on previous analysis, the impact of using an estimate in this way will be highly immaterial. In the rare circumstances that the estimate leads to a more significant difference for any particular provider, there is a process where entities can ask for the national figures to be updated. More details are available in the guidance document below.

IFRS 17 Insurance Contracts – 8 August 2019

IFRS 17 on insurance contracts (replacing IFRS 4) is expected to apply to the public sector from 2022. An insurance contract is defined as “a contract under which one party (the issuer) accepts significant insurance risk from another party (the policyholder) by agreeing to compensate the policyholder if a specific uncertain future event (the insured event) adversely affects the policyholder”.

IFRS 17 brings a number of changes to accounting compared to IFRS 4; a useful summary is available here. But the first step for HM Treasury and DHSC is to identify what contracts might be held that would fall under IFRS 17. It’s possible that there may be items currently considered as provisions or contingent liabilities which are in reality insurance contracts. There are a number of important parts of the definition (this list is not complete):

  • The compensation from the issuer to the policyholder could be in money or in-kind: for example fixing a broken machine
  • The future event is uncertain – which means at least one of the probability of the event occurring, when it will occur, or how much would be paid if it occurs.
  • The future event is specific to the insured party (e.g. flood damage to a building owned or used by the policyholder is specific to that party).
  • The risk around the future event existed for the policyholder before the agreement was made, and it is not financial risk such as a future change in an index.
  • Warranties provided in connection with the sale of goods and services are specifically excluded by the standard as they fall under IFRS 15. So for example we would see readmissions in the NHS as affecting IFRS 15 measurement, and not considered the provision of insurance. Employer pensions and insurance contracts where the entity is the policyholder are also excluded from IFRS 17.

We request that all NHS providers think about whether they are likely to have contracts which are likely to fall under IFRS 17, with the provider as the issuer (rather than the policyholder). If you do have, or have matters that you’re unsure about and would like to discuss further, please get in touch with us.

New accounting standards in 2018/19 – April 2019 (re-packaged December 2019)

The TAC Completion Instructions in 2018/19 contained additional annexes explaining how the disclosure requirements in IFRS 7 (upon adoption of IFRS 9) and IFRS 15 had been addressed in the TAC schedules, with additional guidance on considerations for local accounts. These are now (from December 2019) retained separately as a future reference for providers.

Central review of NHS standard contract for IFRS 15 – 29 January 2019

The Department of Health and Social Care has led on a project to provide a review of the main features of the NHS standard contract and how IFRS 15 thinking should be applied. Chapter 5 will be the most useful part of this, explaining key elements of the NHS standard contract. Please note that chapter 7 on disclosure requirements is very focused on the requirements of the standard, rather than considering materiality for the NHS. The disclosures in our TAC schedules are designed to meet the most relevant disclosure requirements of IFRS 15, as explained in the TAC Completion Instructions.

NHS England centralised inventory procurement – 26 February 2018

NHS England operates a national centralised system for purchasing high-cost medical devices and implants used in specialised services. These items are paid for by NHS England but physically held by providers until they are used. This stock is seen as being owned by NHS England and so is reflected in its Statement of Financial Position. NHS providers are reminded to ensure that they exclude this consignment stock from their inventory counts and it should not be included within providers’ balance sheets.