A report for the committee’s ongoing oversight of:
· Scheme, Regulatory, Legal and Fund Update
· Risk Register
· Business & KPI Improvement Plan update
· Administration KPI update – 1 March 2024 to 30 June 2024
· Annual Low Volume Performance summary
· Audit
a) SWAP Audit KC Report 2024/25
b) Payroll Migration – Phase 3
c) CSE & PASA accreditations
· Training plan 2024/25
Minutes:
Jennifer Devine, Head of Wiltshire Pension Fund, supported by other officers, presented the Headlines and Monitoring report. The report included, but was not limited to, that there had been positive developments from the Investment and Accounting team who had recruited two apprentices as well as an accounting officer who would be able to assist with training and the completion of additional tasks. Additionally, the Fund had hired an Investment Analyst who had started on 4 July and had come from an investment background. It was also noted that work had taken place on the salaries supplement, which had been taken to the Wiltshire Corporate Leadership Team and was now pending an update.
Detail was provided that the Fund was working towards an accreditation in Customer Service Excellence. An update was also provided on the low volume performance reporting and complaints activity, which covered the past year and also included Freedom of Information requests.
Information was provided regarding the Risk Register, which covered the period from January to April. It was noted that there had been improvements in relation to Compliance and Data Management, as well as Projects which had seen a number of projects closed off. The only area which had had an upturn in risk which was Fund Governance, which had been down to the procurements taking place and which had since been resolved.
Detail was provided regarding the SWAP key controls audit, where the Fund had been offered an improved assurance rating of “Reasonable”, which was an increase from the previous “Limited” rating in January 2023. This reflected the hard work of officers. Reference was also made to the Members training plan, which had been recommended by the Board after review.
The Committee discussed the report with it questioned whether the risks experienced by the Fund were being flagged sufficiently and strongly in the governance structure of the Council, it was suggested that the reputational risk of the Fund had a wider implication for the Council. It was suggested that the Chairman could attend the Audit and Governance Committee with a specific agenda item to enable greater visibility for the Fund within the wider Council, with reputational risk cited as an important matter that Councillors should understand. The Chairman agreed to give this further thought and that he would discuss the notion with Officers before further updating the Committee on his stance.
It was questioned whether the risk rating change for Data Management from amber to green was appropriate, to which Officers clarified that the report presented a snapshot in time and that the change in rating followed on from the completion of the end of the last scheme year on the old SAP system. The Officer noted that it was expected that the risk would increase again within the next report. It was also questioned regarding the Risk Register, why Fund Governance had been rated as a high risk which could be perceived as too high given the work of Officers, to which it was clarified that this had been a temporary high risk due to the key procurements which had been undertaken.
The Chairman congratulated Officers for their work regarding the improvement of the SWAP key controls audit, to which it was noted that there was still work to do concerning quality assurance issues and that the Fund was looking to recruit a Quality Assurance Officer to further manage the recommendations set by SWAP. It was also agreed that the Chairman would be given sight of the draft action plan which was being produced to complete the recommendations.
Regarding the service delivery of KPIs, a discussion took place regarding the use of the word “tolerable”, with clarity provided that in this instance the word “tolerable” represented the minimum expected performance and that in the future this would be changed.
Further detail was provided from Officers on the situation involving iConnect onboarding and how data for contributions and submissions had not matched in some cases. Assurance was provided that the Fund team was ready to onboard, pending clean data at the year end.
A discussion took place on the charging of interest for late contributions, with it noted that the Fund would have to consult on the minimum amount charged and that currently this amount did not seem to be acting as a deterrent for employers. The importance of wording was stated by Officers, and that within regulations it would not be possible to charge employers penalties and that the relationships in place might cause difficulty in enforcement. The Officer updated that currently the charging process was being discussed and would need to go through a full consultation process. It was agreed that a paper would be produced including recommendations and all possible options for the Fund relating to charging.
James Franklin, Pension Administration Lead, provided a presentation on the KPI improvement plan checkpoint update for the first 6 months. The presentation included, but was not limited to the following points:
· An overview of the backlog in December 2023 was provided with it noted that positive progress had been made by outsourcing the aggregation backlog.
· A road map was provided on where the Fund would expect to be if the proposed actions were taken.
· A status update after 6 months was provided, which included administration recruitment, the Evolve Payroll migration, training plans, the administration strategy and KPI and backlog update.
· It was also advised that the Fund had only been reporting Medium and High priority cases which has meant the backlog had been underreported. Going forward all cases will be included in the reports to Committee.
· Targets for the next 6 months were outlined, which included for the total backlog to be less than 100, remaining vacancies to be filled, death and retirement KPIs to be greater than 90% and for the Oracle to Altair migration to take place.
The Committee discussed the presentation, with it suggested that the target of less than 100 backlog cases was ambitious to which assurance was provided that this was achievable based on the training and performance of the team members in place. Clarity was also provided that the backlog had taken long to clear as the handling of deaths and retirements cases required greater attention due to reputational risk issues.
The notion of performance was discussed and how this might impact on the team over the next 6 months and that once this had passed, the team would be strong with the potential to bring in strong individuals to replace any which might be lost. Regarding the targets, it was outlined that should there be any risk of missing what had been set, the Committee would be informed and approached regarding readjustment.
At the conclusion of debate, it was,
Resolved:
The Committee agreed to:
· Approve the risk register recommendations made by the Board and the officer assessment of risk as presented in the April version of the risk register:
· Note the SWAP Key Controls audit report and instruct the officers create a log to complete the recommendations stated in the report:
· Approve the members training plan 2024/25.
· To produce an administration charging paper for consideration by members.
Supporting documents: