4. Improving collaboration in the public sector audit system in Brazil

Given the reality of decentralisation in Brazil, audit bodies of the decentralised audit systems might look for opportunities to work together, in order to deliver to the centre of government and policymakers insights into crosscutting improvements for decentralised policies. If they can work in collaboration on these common areas, not only may they be able to reduce the likelihood of unnecessary duplication of audit work and to improve the audit coverage, but also their work may lead to better audits through exchange of knowledge, ultimately resulting in better insights and a higher impact of audit work.

By improving co-ordination among external audit institutions, supreme audit institutions (SAIs) can help to address the challenges inherent in decentralisation, ultimately improving their added value (OECD, 2016[1]).

Collaboration involves multiple actors, who are in one way or another connected to the same issue in a network. By working together in that network, the audit bodies can achieve collective benefit through the pooling of expertise, access and resources while respecting the diverse views, mandates and institutional priorities of their institutions. Any collaboration in a network of external audit entities needs to be carefully designed in order to deliver the expected added value. There are three crucial design challenges that might be considered, further detailed below: the required level of collective action in the network, the required network governance, and the operational design of the network.

The terms collaboration, co-operation and co-ordination are often used interchangeably to describe the way individuals or institutions work together. However, there are differences that may help external audit entities understand and decide on what is needed and attainable given their specific context (see Box 4.1 for definitions).

The level of collective action among audit bodies in the network is not static. Collaboration, co-ordination and co-operation might coexist in the same network at the same time for different elements of the network activities, depending on the context, the goals of the audit bodies involved, the resources available, etc.

Trust among the network participants is the key driver of the level of collective action that is possible in a network. Trust keeps the network together and it can grow or diminish through further interaction among the partners. The higher the level of trust within the network, the higher will be the level of integration and collective action that can be expected from the network.

When establishing the level of collective action of the network, Brazilian audit institutions might consider the following key dimensions:

  • Trust, the basic and fundamental dimension – While co-operation does not require trust to be built on a strong basis among the network participants, collaboration does. Trust is not static; it can increase or decrease depending on the experiences of the individuals or organisations in the network over a longer period.

  • Information sharing and communication – While co-operation does not require formal and ongoing information arrangements, co-ordination does need structured information sharing and communication on the project level. Collaboration needs communication on a strategic and tactical level. The more intense and better the communication flow, the more trust can grow.

  • Sharing of goals, power and resources – The more integrated the network, the more these elements are shared among the network partners.

  • Commitment and accountability – Co-operation is possible even if the primary commitment and accountability is to the own organisation, while collaboration requires primarily commitment to the network.

  • Time frame – Co-operation can work within a short time frame, while co-ordination requires a project-based time frame and collaboration a longer term.

Combining these elements allows the description of a given network, as shown in Table 4.1.

These dimensions can be mixed and matched, and may evolve over time. For example, in Brazil, audit institutions have experienced, to a greater or more limited extent, different ways of working together. Ad hoc initiatives led mostly by TCU for carrying out specific co-ordinated audits might be seen as an example of “co-operation”, given, for example, its relatively short relational time frame and the frequency of information sharing (project-based). Participation in initiatives and projects broader in scope involving structured communication flows and information sharing – such as participation in the National Strategic Information Network for the External Control (Rede Nacional de Informações Estratégicas para o Controle Externo, the Infocontas) could be identified as co-ordinated work experience. Finally, the participation of some TCs in committees or projects with negotiated shared goals, in a relational long-term time frame where the power and resources are shared, such as the Education Committee hosted by the Rui Barbosa Institute, could be an illustration of collaboration (see Box 4.2).

Therefore, with regard to issues or subjects on which TCs have not worked together yet, they might start working on them at a co-operation level but later may express the desire to evolve towards a more integrated network over time. Collaboration might be of particular interest to address the risks of duplication or overlap. For instance, a municipal audit institution and the relevant state audit institution might decide to collaborate in areas where their joint efforts may be of value (e.g. for auditing policies involving both levels of government). In such cases, these institutions would need to implement structures to integrate and improve the frequency of information and knowledge sharing, particularly on the issues affecting both institutions (for example, by applying the methods for audit selection described in Chapter 2). Moreover, they might decide to negotiate shared goals and programmes, based on a relationship of shared power and pooled resources.

For the Brazilian network of audit institutions to be effective and efficient, TCs might think of the governance structure of the network and decide on issues concerning the allocation of responsibility, formalised structures and established processes. Overall, networks might be shaped around three governance structures: self-governed networks, a lead organisation network, and an administrative organisation network (Kenis and Provan, 2009[7]) (see Figure 4.1).

Self-governed networks are structures in which there is no formal administrative entity governing the network. The network participants manage the network activities and take all decisions collectively. If the network is large, some of the tasks may be performed by a subset of the network participants, e.g. in working groups. The model can be of value when, for example, the active involvement of all participating audit bodies is vital (e.g. when they have complementary audit mandates), and it respond to participants’ needs (see Box 4.3 for example). The risk associated with the model is its potential inefficiency, depending on the size and complexity of the network. The model is best suited to small local networks, or to networks in which all the participating audit entities are independent and autonomous and have reasons (e.g. political or institutional) not to delegate decision-making powers to a third party.

In this type of network governance, the activities and key decisions are co-ordinated by one of the participating institutions, which acts as the lead organisation. This organisation provides the administration for the network and facilitates the activities of the members in their efforts to achieve the network goals. The model might be suitable in vertical relationships, e.g. in case there is a major funder of the activities, or if one of the network participants institutionally has more decision-making power than the others (see Box 4.4 for an example). The strength of the model is in its potential efficiency and the legitimacy provided by the lead agency. The risks involved in implementation relate to the potential control over the agenda by the lead organisation, and the decrease of interest by the network partners in the network.

This type of network consists of a separate entity that is set up specifically to manage and co-ordinate the network and its activities. This might be a dedicated formal entity or association with a mandate and its own budget and structure, or an existing entity that is well positioned to take on this role. The strength of the model relates to its potential sustainability, legitimacy and its efficiency. The risks may include the costs and overcomplication of decision‐making processes. In addition, some network members may profit from the network without contributing actively to network activities (“free riders”).

To facilitate co-ordination within the external audit system in Brazil, TCs and their members (e.g. ministers and counsellors) have established a number of critical bodies, such as the Rui Barbosa Institute (IRB) and the Association of the Members of the Brazilian Courts of Accounts (ATRICON), which may be considered administrative organisation networks. Each institute has specific mandates, but also complementary activities (see Box 4.6).

Each type of network governance has its strengths and weaknesses (see Table 4.2). The most suitable network governance model depends on the purpose, needs, goals and capacity of and partners in the network at a given point in time. In reality, mixed governance structures may be applied and the appropriate model may evolve over time, depending on changes in context and in requirements. Regular monitoring and evaluation of the network may reveal the need for adaptation on a timely basis.

In Brazil, unlike the case of Spain, France and Mexico (as seen in Box 4.3, Box 4.4 and Box 4.9 respectively), to date audit institutions have no legal obligation to work in collaboration. Moreover, unlike other areas of the Brazilian public administration – and despite being object of certain bills to amend the Constitution (mainly the PEC 28/2007) – the Brazilian audit institutions do not have an institutional “national council of the external control”. Such organisation could guide, inform and co-ordinate the activities and priorities of the institutions, as well as issue rules to harmonise practices (see Box 4.7 for examples of existing councils).

One option is that the Brazilian audit institutions could advocate for the creation of a new administrative network that could take the form of a national council. The council could have the mandate to promote best practices among audit institutions, define strategic planning for the whole system, co-ordinate, disseminate and leverage individual initiatives, avoid duplication and gaps, etc.

As a first action, or until the network takes the form of an institutionalised council, the audit institutions could prioritise measures to strengthen the existing associations, mainly ATRICON and the Rui Barbosa Institute. For example, they could:

  • promote dialogue among audit institutions for the adoption of international audit standards that are reviewed and published by IRB

  • in order to avoid duplication of actions, classify each of the existing initiatives (committees, working groups, networks) and allocate them to one specific vice-presidency, which could be responsible for the continuity of each activity

  • work to assure the continuity of the activities of the associations, or think of solutions for the mitigation of risks such as the lack of future leadership

  • promote dialogue with the courts of accounts to decide on the actions for further improvement of the association.

Networks might consider how they operate. Crucial elements include understanding of the network’s purpose and essential needs and when to change earlier choices, depending on the evolution of the network (described in the previous section and Box 4.8). These questions should be addressed at the establishment of the network and readdressed at significant transitions in the network’s life (Plastrik, Taylor and Cleveland, 2014[21]).

Regardless of the form of the network in Brazil (e.g. a national council; a lead organisation; or a strengthened existing administrative network), the audit institutions must debate and decide on the key operational design in order for the collaboration to be effective.

Most importantly, TC leadership must agree on the purpose of the network and therefore, must understand and be convinced of the added value of the collaboration. For this, all prospective members of the network should be consulted, for instance through a series of (video) conferences or a survey among members of the courts of accounts, to share their ideas about the values and purpose of the network. If existing networks are used, such as IRB and ATRICON, an option is to involve representatives of each court of accounts in the development of the strategic planning (see Box 4.10 and Box 4.14 for examples).

Ways to communicate among network member institutions and auditors might be designed in a way that supports the purpose if the network. For example, if the network intends to reduce duplication and overlap of audit activities performed by the TCs, it could adopt a channel for the consolidation, analysis and classification of such activities. In this sense, the network could draw inspiration from Mexico and Argentina (Box 4.9) and work towards the integration of the audit plans of all TCs. If the network has the ambition to collaborate in selecting and planning audits, an IT system such as the one detailed in Chapter 2 could aggregate and organise the information about auditees, policies being audited, etc. The system could also consolidate the findings of the audit institutions, which could in turn facilitate following up on the audit recommendations. Moreover, the network could think of measures to preserve its legacy, for example by implementing and managing an official archive of its documents.

Through the network, the audit institutions could adopt one official external control calendar, with the official events organised by the different courts and associations (e.g. events hosted by the courts of accounts, IRB, ATRICON, the National Council of the Presidents of the Courts of Accounts, the Brazilian Association of Municipal Courts of Accounts – ABRACOM, etc.)

The network might be funded by a fixed annual fee paid by its members –like the IRB funding structure – or could take the form of a fee that might vary depending on certain criteria (e.g. size categories of members), such as the ACAG funding structure (Box 4.5). Alternatives for funding the structure might include calculating the reduction of costs for the audit institutions due to joint or co-ordinated audits, which could be allocated by the relevant courts to the network.

The network must think about its governance structure strategically, i.e. who will make decisions and how. For example, under the current structure of IRB, TCs choose the presidency every two years. Other possibilities include a governance model consisting of an assembly and a board, the former composed of one or two representatives of each TC (e.g. the president and one auditor, or the secretary-general for the external control), who could elect a board that would have some decision-making powers. The network could also establish an advisory committee that included the participation of citizens and auditees. Other independent committees could be established in order to manage and co-ordinate specific subjects, such as the committee for audit selection (further described in the next section of this chapter).

In any case, network members need to evaluate the adequacy of the governance model – including the term of the mandate, and consider if such mandate should be extended for the purpose of continuity of actions, for example. This might be part of a mechanism to assess the network’s performance and adequacy. For example, the presidency or the board might be responsible for delivering an annual report of activities around the strategic objectives of the network (see Box 4.10 for an example of interactive reporting of activities).

While working together in a network might benefit from the ability of TCs to address issues associated with the audit of decentralised policies and multi-level governance, audit networks also face specific challenges. When using the work of other auditors at state, provincial, regional, district or local level, or of public accounting firms that have completed audit work related to the audit objective, audit institutions should make arrangements to ensure that any such work was carried out in accordance with public sector auditing standards (INTOSAI, 2013[25]). Other specific challenges include:

When working together in a network, TCs might share information, analysis and conclusions obtained throughout their work. Therefore, the exchange of information must be given particular attention and the network entities must consider and observe the internal provisions of each participating institution regarding confidentiality and privacy issues. For example, it might be necessary to enter into confidentiality agreements to address the specific concerns and particularities of each TC involved. This is for instance the case in the European Union, where these restrictions apply to exchange of information between the European Court of Auditors and the SAIs of the Member States. In some cases, a “single audit” agreement might facilitate the exchange of information within the network. See Box 4.11 for an example from Belgium.

Brazilian audit institutions must exercise caution about the use of different audit standards. In that regard, adoption of the international standards translated and adapted by IRB might be of use as the common ground. Moreover, if the network decides to consolidate information from audits coming from different audit institutions, it should be aware that audit criteria, e.g. for compliance, may differ among jurisdictions. Finally, the network may also need to take into account differences in budget and audit cycle timing among participating network institutions. Some countries are implementing measures to overcome these challenges through capacity building and harmonisation of practices among audit institutions (see Box 4.12 for examples).

It is not likely that the different audit institutions will have the same capacity, given the different size of their structures and budgets. Moreover, Brazilian audit institutions have different focuses and priorities in terms of types of audit, particularly regarding performance audit (i.e. some audit institutions are not used to carrying out these audits, while others have more experience with it). Therefore, if the network requests the joint and collaborative work of the audit institutions, it is necessary to take the different capacities into account. For example, when carrying out a co-ordinated activity, one audit institution might be responsible for a more limited activity, given its more limited resources. These cases might be an opportunity for the organisations with more (experienced) staff to help build capacity among the other audit institutions. Another example could be of expertise – for instance, one audit institution that is used to audit environmental issues due to its geographical location might be able to share its expertise with other audit institutions that are less knowledgeable about these issues.

Unlike other countries, in Brazil the audit institutions do not have any institutional or legal obligation to collaborate among themselves. Therefore, unless there is a change in the legal framework, the collaboration will be voluntary, including the buy-in of all the courts at the leadership level. Any difficulties in obtaining such commitment might compromise the continuity of the network’s activities. Thus, Brazilian audit institutions must pay particular attention to this issue and engage their efforts for the involvement of management at all the institutions involved.

As seen above, a network might draw upon the audit capacity of each external audit body, individually and collectively, by sharing knowledge among the network members and working together strategically. One powerful way to generate constructive collective action within the network, with the potential for greater impact, is through strategic collaboration on the selection of audits. Chapter 2 described the approach for developing an evidence-based risk assessment for the selection of audit topics. This section provides details on how this approach can be embedded in a collaborative process of audit selection within the network of external audit entities.

TCU and TCs have made concrete efforts to co-ordinate their oversight capacities, including carrying out co-ordinated audits (see Box 4.13 for examples) and capacity building using the ATRICON and the Rui Barbosa Institute as platforms. To date, the co-ordinated audits are usually led by TCU, which selects the topics and engages the participation of TCs in the audits.

The efforts towards collaborative work were also translated into co-operation agreements among TCs, such as:

  • The Amazon Charter (2010) and the Belém Declaration (2011), both of which proposed the continuous exchange of knowledge and the execution of performance audits with an emphasis on environmental issues

  • The Campo Grande Declaration (2012), which proposed co-ordinated audits in education and health

  • The Vitória Declaration (2013), which was intended to guarantee technical and institutional support for co-ordinated audits

  • The Declaration of Fortaleza (2014), which reinforced the pact to develop co-ordinated audits to evaluate effectively and systematically the results of public policies.

Additionally, some TCs, such as the TCE-Rio Grande do Norte, and the TCU have agreements in place containing general terms of co-operation among the courts. Overall, these agreements do not intend to regulate one specific co-ordinated audit; they set forth, for example, that the courts must include in their audit programming the control activities resulting from the co-operation. The contracts might also establish that one court, notably the TCU, must inform the other court about any federal resources transferred to entities of the relevant level of government (e.g. the State of Rio Grande do Norte and its municipalities), as these transfers might be subject to oversight by both TCs.

Despite these initiatives, to date TCs have not implemented methods or a network to decide on systemic or common issues, including the common selection of co-ordinated audits. Moreover, in general, most TCs do not have any mechanism or co-ordination process in place intended to clarify or define their responsibilities and mandates, or to avoid duplication, fragmentation or overlap of activities.

In order to increase the synergy and impact of the work among the Brazilian audit institutions, they might develop procedures and mechanisms for collaborative selection and alignment of their audits. Unlike the current co-ordinated audit selection processes, mostly led by TCU, the alignment of audits of decentralised policies might involve all stakeholders. For that to be possible, TCs could benefit from the work of the network. As seen throughout this chapter, it is recommended that the Brazilian audit institutions either establish a new network or improve the existing structures. Either way, the chosen network could dedicate specific efforts to the collaborative selection of audits. These efforts could take the form of a vice-presidency or a committee, with a dedicated team to ensure the activities’ continuity.

For example, the committee could be allocated at one existing committee of IRB, or could be an extension of the Integrar Project (the OECD-TCs project leading to this publication). Building on the knowledge of Integrar Project, the project’s structure could be adapted to be the basis of the committee for collaborative audit selection. The committee, which might have decision powers related to its activities, could eventually be within the IRB (or other existing network) structure, or within the structure of a future national council or network.

The development of strategic objectives for audit networks might encourage the appropriate participation of the network members. When drafting strategic objectives, one option is to assign to a small committee primary responsibility for drafting the strategy document and granting the committee a reasonable degree of autonomy in developing the draft; the committee would be composed of representatives from (some or all) network members. Including a broad range of voices in the development process can help build a common vision and increase the legitimacy of the strategy, and hence augment support for it within each audit institution and in the wider society (OECD, 2020[34]) (see Box 4.14 for an example of a network’s strategic plan).

Among the strategic objectives of the network, there should be the collaborative selection of audit topics and alignment of audits. The strategic objective might accompany specific activities aiming to obtain the commitment from all audit institutions to participate in the network’s strategic audit programming process. This commitment could be formalised by the participation of at least one representative from each audit institution in the audit selection committee.

The audit selection committee might be responsible for the strategic audit programming process, an opportunity for the members of the committee to discuss and agree on which audits can be pursued by the audit institutions, jointly or collaboratively. This exercise would allow both the committee and each participating audit entity to consider the topics that, within their jurisdiction, may have the biggest impact, while taking account of the audit capacities available (e.g. human resources, professional skills and internal structures). During the process, the committee’s participants might apply the methods described in Chapter 2 related to evidence-based audit selection in decentralised policy areas in order to identify the major fields of action that might require joint efforts.

During the shared audit programming exercise, the committee must consider that the Brazilian audit institutions have in place their own audit practices and ways of working, including their own mechanisms for selecting audits and multi-year audit programming. However, to the extent that the committee might use the methods described in Chapter 2 for selecting collaborative audit work, the methods should not supersede the existing individual audit programming of each audit institution. Nonetheless, for alignment of audits to be possible, the committee (or the network hosting the committee) could advocate before its members that audit institutions dedicate some staff and resources of their institutions to aligned audit programming and joint audit work.

Following application of the methods for evidence-based audit selection – and once the major fields of action are defined, taking into account the objectives of the network – the process for selecting objects of audit can be more focused, leading to the scrutiny of sector information on government actions against selection criteria.

It may therefore be useful for TCs to answer a set of questions that may help prioritise the proposed audit topics in the committee’s deliberative selection process, such as:

  • Strategic considerations – Does the topic match with the strategic objectives of the network? Is the topic important to citizens and governments at the relevant levels?

  • Political and societal context – Is the topic considered urgent for all involved audit institutions, given the political and social contexts? Have the governments involved made commitments around the topic and do they have plans to meet them?

  • Multi-level context – Is working together among multi-levels of government necessary to achieve the commitments or plans around the topic?

  • Impact – Will the audit potentially make a positive difference? Will there be pressure for auditees to follow up on the recommendations?

  • Materiality – Does the audited activity or programme have potentially significant financial, economic, social or environmental management implications?

  • Auditability – Can the audit be carried out with resources that match the impact and materiality of the topic?

  • Added value to the network – Will the network leverage the impact?

To answer these questions the committee might consider not only the results of the evidence-based audit selection in decentralised policy areas, but also other information exchanged by the audit institutions in the network. For example, the committee should have access to and make use of mechanisms implemented by the network to ensure persistent knowledge sharing among audit institutions (as described in the section above).

Finally, a deliberative process with the participation of the committee members may be implemented to define shared audit programming, which could summarise all planned and announced audit activity to be undertaken jointly by the committee’s members (see Box 4.15 for example).

As shown in Chapter 3, the way in which the multi-level governance system is structured and how efficiently it works affects the design, implementation and outputs of public policies with subnational impact. It is therefore crucial to consider the multi-level governance (MLG) dimension in audits of decentralised policies. The Brazilian network of audit institutions is an adequate forum to enable this integration.

A working group or committee might be formed within the network with the specific mandate to put in practice the steps described in Chapter 3 on how to map and assess the capacities and resources at each level of government as well as co-ordination mechanisms between and across each level. Once the analytical framework has been defined, it can be used as an input to design and plan audits. The main result of this design phase of the audit process is the audit plan, which usually includes the audit’s objectives, scope, criteria, evidence collection and analysis techniques.

Understanding the topic or object to be audited is important in any type of audit, and good practice is to do this in a pre-audit study. In that respect, development of the MLG assessment framework for a specific decentralised policy area can be considered as such a pre-audit or preliminary study. Therefore, once the committee for audit selection decides on the shared audit programming, it might work in collaboration with the MLG committee to define and refine the audit planning.

After the audit planning and before the beginning of audit work, the committee’s members (or the members of the participating audit institutions might develop an evaluation process to assess whether the audit objectives, defined at the beginning of the work, have been achieved. The more clearly and precisely these objectives are defined, the clearer will be the evaluation exercise. The evaluation might also address whether and which constraints have impacted the audit work. A repertory of best practices and pitfalls can be a simple way to consolidate the lessons learned (see Box 4.16 for an example from Canada).

The evaluation might take place after the conclusion of the audit, but it might also contain intermediary assessments. Overall, it might assess, through surveys or other indicators:

  • Adequacy of the audit topic – Was the audit topic important to all citizens? How did the joint work help achieve the audit objectives (i.e. what would not have been achieved without the co-ordination between audit institutions)?

  • Commitment – Have all the audit institutions involved complied with the timelines and committed to the vision of the network?

  • Design – Was the audit programming and planning adequate for the audit objectives? What could have worked better?

  • Communication – Has the communication structure been appropriate? What could have worked better to facilitate the information and knowledge sharing?

  • Different practices and methodologies – Did the different practices and methodologies negatively affect the audit? How? What measures have been taken in order to address the challenges? What could have worked better?

The results of the assessment might be stored, publicly available and reported to the network’s leadership, as well as to all audit institutions participating in the network.


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