Accounts deadline pushed back in response to Covid-19 pressure on NHS

Usually, at this time of year, this piece would set out the key issues when preparing the annual report and accounts and most of these would be known in advance. This year is different and the mechanics of preparing the annual report and accounts has become a key consideration.

NHS England and NHS Improvement have issued an amended timetable for the submission and audit of the accounts and have signposted where more guidance is being prepared.

All provider and clinical commissioning group draft accounts are now due for submission on 27 April, two weeks later than usual, but this can be extended to 11 May by providers if they wish. This recognises that some NHS bodies are keen to get on with the process, but others are going to struggle where they have fewer staff available and where home working is less easy.

Those providers that elect to use the later deadline will still need to provide agreement of balances information on 27 April. Equally, those providers submitting their draft accounts on the earlier date will have to provide updated agreement of balances on 11 May.

Therefore, providers will need to decide the deadlines they will work to.

For everyone, the audited accounts are now due to be submitted to NHS England or NHS Improvement on 25 June.

The annual accounts will have to be IFRS-compliant, so will need to include all of the necessary disclosures. This may feel like overkill in the current circumstances, but most of the information in the notes will be needed to prepare the primary statements.

For example, it would be impossible to determine a closing balance for provisions without understanding the movements in-year in terms of the provisions that have been discharged, new liabilities and changes due to discounting. Having said that, NHS bodies should consider materiality at all stages in the preparation of the accounts and may decide to exclude detail in notes that are usually completed as a matter of course.

These might include the financial instruments notes, details of all related party transactions, intangible assets and pooled budgets. But each NHS body will need to make this decision based on its own circumstances.

Early discussions with auditors in relation to materiality would be helpful. This is perhaps particularly the case in relation to the perennial problem of whether the fact that the submission schedules must be consistent with the accounts actually means that they should be the same.

In terms of the annual report, including the remuneration report, the guidance is still being developed. Again, the focus will need to be on what is important. It is hard to remember that there was a time before Covid-19. However, annual reports will have to cover the full financial year, focusing on what is really important in terms of strategic or critical decisions and performance issues.

Most of this information should be available in the board papers and board discussions. A good place to start is probably the annual governance statement, then moving on to the performance statement.

The preparation of the quality accounts by providers is a statutory requirement, so it is difficult to amend. However, NHS England and NHS Improvement have announced that there will be no audit work required on quality accounts. Foundation trusts are encouraged to include the additional quality report information in their quality accounts. It is not expected that the statutory deadline of 30 June will be strictly enforced.

Debbie Paterson is HFMA policy and technical manager