Report from supervision of the NAV Qualification Programme at NAV Kristiansand 2014
The Office of the County Governor of Vest-Agder (Fylkesmannen i Vest-Agder)
This report outlines the non-conformities and notes that were pointed out in the audited areas. The system audit comprised the following activities:
- whether the municipality ensures sound allocation (selection of participants) of the Qualification Programme,
- whether the municipality ensures sound implementation of the Qualification Programme.
One non-conformity was noted during the supervision:
The municipality of Kristiansand does not ensure sound implementation of the Qualification Programme.
Trond Sælør, Audit Leader
Birthe Guttormsen, Auditor
The report was drawn up following a system audit at the municipality of Kristiansand (Kristiansand kommune)/NAV Kristiansand in the period 28 August 2013 – 16 December 2013. The audit is part of the planned supervisory activities which the Office of the County Governor is carrying out this year, and forms part of a national supervision commissioned by the Norwegian Board of Health Supervision (Norwegian: Statens helsetilsyn).
Section 9 of the Act on Social Services in NAV (the Labour and Welfare Administration, Norwegian: Arbeids- og velferdsforvaltningen (NAV)) gives the Office of the County Governor the authority to supervise NAV.
The objective of the system audit is to assess whether the organisation, through its internal control activities, complies with the various legislative requirements. The audit comprised assessing:
- what measures the organisation has implemented to detect, correct and prevent any violation of the law in the areas covered by the supervision,
- whether the measures are monitored in practice and, where necessary, corrected,
- whether the measures are adequate to ensure compliance with the legislation.
A system audit is performed by reviewing documents, carrying out interviews and other forms of investigation.
The report concerns non-conformities that were identified during the audit and therefore does not provide a complete appraisal of the status quo as regards the organisation’s work within the areas covered by the supervision.
- Non-conformity is the failure to comply with requirements laid down in or in pursuance of laws or regulations.
- Notes refer to conditions that are not in conflict with requirements defined in or in pursuance of the law or regulations, but where the supervisory body wishes to point out there is room for improvement.
Kristiansand has approx. 85 000 inhabitants. NAV Kristiansand (the municipal Labour and Welfare Administration) was established in April 2011 and is the country’s largest NAV office. The office consists of seven departments, each of which has its own department head. These report to the NAV manager. The NAV manager is a Unit Head in the municipality’s Health Care and Social Services. These services in turn report to the Health Care and Social Services Director.
There are four departments that make administrative decisions pursuant to the Act on Social Services in NAV: NAV Centre Reception, NAV Young Persons, NAV Follow-up and NAV Intro.
Up to 6 May 2013 NAV Kristiansand had its own department that worked on the Qualification Programme (abbreviated as QuP, or KVP in Norwegian). Due to a cutback in funding for KVP work, the work with the Qualification Programme was re-organised. Two full-time equivalent positions were allocated to NAV Young Persons, designed for users under 25. Four persons were allocated to NAV Follow-up, which assists users above the age of 25. One of these four positions is the team co-ordinator, who has professional responsibility and co-ordinates activities in connection with the Qualification Programme. The other team members all work both with the Qualification Programme and other NAV services. At the time the supervision was performed, two of the four team members were undergoing training.
During the supervision, one person from NAV Centre Reception was interviewed, another person from NAV Young Persons, and three from NAV Follow-up. In addition, the leader of NAV Follow-up, the NAV manager and the Health and Social Services Director were interviewed.
The system audit comprised the following activities:
The notification of the audit was sent on 28 August 2013. A list of the documents the organisation has sent to the auditors in connection with the supervision is supplied in the chapter Casedocuments.
The pre-supervision meeting was held on 24 September 2013.
The opening meeting was held on 5 November 2013.
Eight people were interviewed.
A list of the documentation that was reviewed during the audit visit is provided in the chapter Casedocuments.
The closing meeting was held on 6 November 2013.
The supervision appraised whether the municipality of Kristiansand/NAV Kristiansand ensures sound allocation of the Qualification Programme and that the programme is carried out in a sound manner. As regards proper allocation, the supervision examined whether the municipality ensures that the service is accessible, has proper identification processes, provides good information about rights to the Qualification Programme and whether the municipality ensures sound processes with regard to mapping, assessment and decision-making when allocating the Qualification Programme. As regards carrying out the Qualification Programme in a sound manner, the supervision examined whether the time limits for implementation of the programme were adhered to, and whether the content and scope of services are appropriate and in accordance with laws and regulations.
The municipality of Kristiansand does not exercise adequate management to ensure sound implementation of the Qualification Programme.
Non-conformities from the following requirements of laws and regulations have been found:
Section 30 of the Act on Social Services in NAV (content of the Qualification Programme), Section 4 of the Act on Social Services in NAV (requirements regarding sound practice)
Section 5 of the Act on Social Services in NAV (internal control)
Sections 4 and 5 of the Regulations on Internal Control for the Municipality in NAV. Section 1 of the Regulations on the Qualification Programme and Associated Financial Support.
The non-conformity is based on the following:
- In 7 of 14 cases financial support in connection with the qualification programme is paid without there being a programme, either because the programme has not been drawn up or because the user has completed the programme.
- When users start the programme, administrative decisions and programmes are in place. However, although measures have been proposed, the NAV user continues on a waiting list waiting for a place on the scheme in question. In the meantime, the KVP financial support in connection with the qualification programme is payable from the date the administrative decision is made.
- Financial support is not stopped when the participants have stopped attending the programme or have been granted leave.
- In the 14 cases we reviewed we observed that participants were not aware of any fixed evaluation time (which is part of the programme).
- The programmes were fairly unspecific as regards content and type of activities. It is therefore difficult to determine whether the legal requirement that a programme should equal a weekly workload of 37.5 hours has been complied with.
- Qualification programmes had been granted in 2 out of 14 cases, despite the fact that the work capacity assessment had concluded that there was a need for “a personalised programme”.
- In 3 of the 14 cases the case processing time from the time of application to programme start-up had exceeded the six-month time limit.
- In 3 of the 3 cases in which the participant had completed the Qualification Programme, they had not been given any certificate of programme completion.
- The case notes do not include any written documentation indicating user involvement. In 11 of 14 cases there is no sign that a self-assessment form had been used.
- The interviews indicated that there was no clear distribution of responsibility for the Qualification Programme among the co-ordinator for the Qualification Programme, the Department Head for NAV Follow-up and the Deputy Head for NAV Follow-up.
- Although the QuP co-ordinator is responsible for NAV Follow-up and NAV Young Persons as regards the Qualification Programme, in practice this only works in relation to NAV Follow-up.
- There is a system for non-conformity processing, but the employees are not well-acquainted with it.
- Systems to verify the outcome of Qualification Programme completion are inadequate.
- Correct payment of financial support is based on attendance lists. The procedures relating to control of these lists are inadequate.
As of 1 January 2010 the municipalities are obliged to establish internal control mechanisms in areas that are covered by the Act on Social Services in NAV. The requirement to internal control entails that the municipal management is responsible for ensuring compliance with social services legislation through systematic management and continuous improvement.
The municipality is responsible for establishing structures to ensure sound monitoring of the Qualification Programme.
The Qualification Programme is a one-off programme involving financial support that can be given for up to two and a half years. It is therefore of particular importance that the programme contains sufficient activities to ensure that the objective of work and activity are attained. It is a requirement that NAV can offer close and co-ordinated follow-up of the participants. NAV therefore requires a system to evaluate, control and adjust the programme to ensure that the organisation has sufficient resources to safeguard the individual user’s rights in accordance with laws and regulations.
According to the regulations the organisation shall ensure that employees have sufficient knowledge and skills within the service in question. Inadequate training increases vulnerability, especially when there are re-organisation processes and the employees are given new areas of work and new work methods, and new technology.
In order to ensure sound services, systematic training and upskilling efforts are required at all levels of the organisation.
The Act on Social Services in NAV of 18 December 2009, No. 131
The Regulations on Internal Control for the Municipality in NAV
The Regulations on the Qualification Programme and Associated Financial Support
The Public Administration Act of 10 February 1967
The Regulations pertaining to the Public Administration Act of 15 December 2006 No. 1456
The organisation’s own documentation related to day-to-day operations and other matters of significance that were sent to the auditors during preparation for the audit:
Because the Office of the County Governor had a supervision of NAV Kristiansand a year ago and was familiar with the organisation and the existing agreements, the Office of the County Governor only requested a limited amount of documentation on this occasion.
- Updated organisation chart
- List of staff working on issues related to the supervision
- Procedural descriptions of Qualification Programme case flow
- Procedures related to the Qualification Programme such as mapping, needs assessment, delegation of responsibility for the programme
Documentation reviewed during the audit visit:
- On 29 and 30 October, 21 case files were reviewed at NAV Kristiansand. Following the review the Acting Department Head assisted us in reviewing these cases in the various computer systems. This was done in order to attain the best possible sense of the work that is being done with the Qualification Programme.
- Inspection at the Reception/NAV Centre.
Correspondence between the organisation and the Office of the County Governor:
- Notification of supervision, dated 28 August 2013
- The municipality’s reply regarding a contact person
- The requested documents, received 15 October 2013
9. Persons participating in the supervision
The table below lists the persons attending the opening and closing meetings, and the persons who were interviewed.
Not published here
The following individuals from the Office of the County Governor participated:
Birthe Guttormsen, Auditor
Elin Kristensen, Auditor
Trond Sælør, Audit Leader