It is now six years since the Treasury announced that ‘Accounting Officers should [in future] personally approve, in advance, all significant initiatives, policies, programmes and projects … A Ministerial policy decision cannot be sufficient justification alone for proceeding.’
This seemed to be a significant constitutional development, but its impact apears to have been limited. My own rather downbeat current assessment is below, and might be of interest to those unfamiliar with AO Assessments. But I am drawing attention to it mainly because I know that my writing is often accessed by journalists and students, and I want to make sure that it is accurate.
Please therefore do contact me, by commenting below or by email, if you have any up-to-date information or would like to suggest changes of tone or other improvements and corrections.
The below text is part of a longer chapter in Civil Servants, Ministers and Parliament which may be read here. I hope to publish the whole text, as a book, in the New Year.
6.7 Â Accounting Officer Assessments
As from 2017, and following a Public Accounts Committee recommendation, the Treasury announced that ‘Accounting Officers should personally approve, in advance, all significant initiatives, policies, programmes and projects’ and so be able to provide assurance to Parliament that those activities provide value for money and are feasible etc.  The guidance went on to say (emphasis added):
The analysis should consider the issue in the round. A Ministerial policy decision cannot be sufficient justification alone for proceeding. The accounting officer’s job is to try to reconcile Ministers’ policy objectives with the standards for use of public funds.
The full accounting officer assessment should provide a frank examination of the key issues including any sensitive issues. It should address the essence of the policy which is being delivered, its purposes and its prospect of successful delivery or implementation. It is therefore not usually published in full, but is shared with the Treasury.  A summary of the key points from an accounting officer assessment of a major project should however be prepared and published.Â
Officials are not obliged to prepare an AO Assessment immediately a Minister indulges in some blue sky thinking. And the Treasury’s guidance allows a bit of wriggle room later on:
Often, big intricate decisions have long lead times. In such cases, it is good practice to make the accounting officer assessment in principle at an early point, firming it up at suitable strategic points as the policy or proposal is developed. This makes for orderly evaluation of the key features of the policy, with no surprises at the final decision point. Apart from providing time to redesign a policy or proposal, early assessment may flag up how the proposal can be better designed to meet both Ministers’ and parliament’s requirements, or whether there is a for a Ministerial (or board) direction, particularly when proposed spending is imminent or an existing spending stream no longer complies with the four accounting officer standards.
It is useful to distinguish policy assessments from major projects assessments. Â
The Treasury allows summaries of major projects assessments to be shared with MPs. Here is their guidance:
Parliament has been given a role in monitoring ‘major projects’:Â
Accounting officers who have considered an assessment for a project in the Government’s Major Projects Portfolio (GMPP), in line with this guidance, and approved it, should provide to Parliament a summary of the key points from the assessment which informed their judgement.
But policy AO Assessments (for plans that fall outside the GMPP) do not need to be shared with Parliament. Here is the Treasury again:
Accounting officers may choose to publish similar information from assessments made in other circumstances at their discretion, but there is no requirement to do so.
It is of course very unlikely that Accounting Officers will choose to publish the more controversial Assessments. So MPs will not be able to assure themselves that sensible policy decisions are being made ... unless – perhaps supported by the National Audit Office and the media – Select Committees start insisting on seeing individual AO Assessments. If this were to happen, we might begin to see a significant improvement in the way this country is governed. But Parliament has seemed relatively weak since 2016, and possibly well before then, so this author, for one, is not optimistic.Â
My pessimism was not dissipated by an exchange in a Public Accounts Committee hearing in September 2020 when the PAC asked to see the Accounting Officer Assessment of the approach taken by Ministers in deciding which 'struggling' towns (and hence constituencies) were to benefit from the £3.6 billion Towns Fund. There were fears that too much politics had intruded into decision making but the relevant Permanent Secretary politely refused to publish his assessment of the program. "My understanding is that they are not normally published".
The Committee asked whether the Accounting Officer might nevertheless 'be willing for the Committee to have a private look at the papers? We have done this a number of times with other documents from Departments.' Next month, however, the Committee reported that (emphasis added):
The £3.6 billion Towns Fund was introduced at pace by the Ministry of Housing, Communities and Local Government (the Department) in summer 2019. It relied upon Ministers selecting which towns would receive funding from a ranked list prepared by officials. The Department claims it had good reasons for this approach, but we are not convinced by the rationales for selecting some towns and not others. The justification offered by ministers for selecting individual towns are vague and based on sweeping assumptions. In some cases, towns were chosen by ministers despite being identified by officials as the very lowest priority (for example, one town selected ranked 535th out of 541 towns).
The Department has also not been open about the process it followed and it did not disclose the reasoning for selecting or excluding towns. This lack of transparency has fuelled accusations of political bias in the selection process, and has risked the Civil Service’s reputation for integrity and impartiality. We are therefore disappointed that, although the Department’s Permanent Secretary confirmed he was satisfied the selection process met the requirements of propriety and regularity, a summary of his Accounting Officer assessment remains unpublished.
It is still far from clear what impact the Department expects from the Towns Fund, when it expects to see the benefits, and how it will measure success both at the town level and across the whole programme. The Department says that it wished to give money to towns which it deemed unlikely to have the expertise to succeed at bidding for funding through an open competition; which also raises concerns about whether those towns will have the capacity to spend the money well.
A July 2022 National Audit Office report about AO Assessments revealed that they could not tell how many AO assessments had been carried out. The NAO concluded that Accounting Officers were not consistently publishing and sharing their assessments in line with Treasury guidance. Many of the summaries that were published were published far too late to permit proper transparency and scrutiny. And those assessments that had been published did not always make clear that issues had been considered by AOs when making their judgements.
All in all, therefore, it does not appear that AO assessments are as yet achieving the objectives that were envisaged when they were introduced.
Martin Stanley - Editor - Understanding the Civil Service