Thirty-Eighth Report - COVID-19 cost tracker update

We are concerned that HM Treasury does not intend to adequately monitor and update the ongoing cost of COVID-19 to the taxpayer. Monitoring the forecast costs and actual spend related to COVID-19 is crucial for Parliamentary scrutiny and for holding departments to account for their use of taxpayers’ money. The cost-tracker has enabled Parliament and the public to have full visibility over what government has spent and committed to spend in response to the pandemic and the financial risks to the public purse. Government estimates that it will lose £21 billion as a result of loans that it does not expect will be repaid. HM Treasury will know more about how much will be lost in connection to these loan schemes over time as more repayment data is received. HM Treasury has committed to conduct a routine review of material changes to the estimated costs, including updating the costs associated with the COVID-19 loan schemes and some public services measures, where these can be reliably attributed to COVID-19. However, it has not specified which elements of government’s response to the pandemic will be included in these updates, what will constitute material changes to estimated costs, or how the costs of those elements which are excluded will continue to be monitored and Departments held to account for spending taxpayers’ money. From 2022–23 onwards, funding to tackle issues arising from COVID-19 will not be ring-fenced. Some of the costs currently included in the cost tracker will form part of departments’ ongoing activities. 6 COVID-19 cost tracker update Recommendation: As part of its Treasury Minute response, HM Treasury should explain how, when, and which subsets of the data captured by the NAO in the COVID-19 cost tracker it will continue to update. This should also address how loan book commitments, including those made under the Culture Recovery Fund, and any associated liabilities, such as estimated write-off costs under the Bounce Back Loans Scheme, will be moni

HM Treasury does not yet know how much money has been lost to fraud and error across government’s response to COVID-19. Our previous work on government’s response to COVID-19 has revealed that the risk of fraud and error to public finances has risen substantially during the pandemic. As a result, government is likely to be exposed to significant financial risk. Some of the larger COVID-19 measures are likely to lose large sums of taxpayers’ money to fraud and error. For example, the Coronavirus Job Retention Scheme is estimated to lose £5.3 billion to fraud and error – equating to 8.7% of the funding distributed through the scheme. HM Treasury asserts that it has increased its investment in the detection and recovery of fraud and expects this to have a significant return. However, HM Treasury is not able to put a figure to the expected return on investment or the amount of fraud and error across the breadth of government’s response to COVID-19. Given that the increased risk of fraud and error could cost the taxpayer billions of pounds, it is crucial that HM Treasury can identify, estimate the volume of, and attempt to recover, funding that was distributed in error or through fraudulent claims. Recommendation: HM Treasury should write to the committee by the end of the financial year with its estimate of: • how much taxpayers’ money has been lost to fraud and error within schemes introduced in response to the pandemic; and • how much it expects will be recovered for each pound it spends doing so.

HM Treasury has not set out what lessons it has learnt from the government’s response to COVID-19 and how it will apply these in future. The pandemic required government to respond rapidly to emerging issues across all areas of society. It is essential that government learns from its response to the pandemic and identifies what it should do to ensure that those lessons are applied, both to improve its ability to respond to emergencies, and to improve its business-as-usual service delivery. Departments cannot wait until the public inquiry, which may take some years to complete, to learn the lessons from government’s handling of the pandemic. HM Treasury agreed that it is now an appropriate time to undertake a lessons learned exercise covering the whole of government’s initial response to the pandemic. The sooner this exercise takes place, the quicker departments can embed the lessons they have learned in their practices and guidance. Recommendation: HM Treasury should write to the committee by the end of the financial year setting out: • what it has learned from the government’s response to the COVID-19 pandemic; and • what action it is taking to identify and collate learning from across government departments. COVID-19 cost tracker update 7 1 The cost of the pandemic to the taxpayer

Based on the fourth iteration of the COVID-19 cost tracker (the cost tracker) published by the Comptroller and Auditor General in September 2021, we took evidence from HM Treasury about the costs of government’s response to the COVID-19 pandemic.1 In May 2021, we took evidence from HM Treasury on the third iteration of the cost tracker (published by the Comptroller and Auditor General in May 2021) as part of our series of inquiries into the pandemic.2

In our evidence session on 17th November 2021, we observed that the cost tracker had supported Parliamentary scrutiny of departments and enabled us to hold government to account.9 We have found the model used in the cost tracker very useful, and it has helped in the ongoing exercise of monitoring COVID-19 spending.10 We asked HM Treasury whether it planned to use a similar model to the cost tracker in future to track other areas of spending. HM Treasury told us that it was still looking at whether it would 5 The COVID-19 cost tracker, available at: COVID-19 cost tracker - National Audit Office (NAO) 6 Committee of Public Accounts, COVID-19 Cost Tracker Update, Twelfth Report of Session 2021–22, HC173, 19 July 2021 7 HM Treasury, Government response to the Committee of Public Accounts on the Twelfth and Seventeenth to the Twenty-First Reports from Session 2021–22, CP 583, 9 December 2021 8 Letter from Tom Scholar, Permanent Secretary, HM Treasury, to Dame Meg Hillier MP, Monitoring the cost of cross-government programmes, 23 December 2021 9 Q 13 10 Qq 1, 56–58 COVID-19 cost tracker update 9 use a model similar to the cost tracker to monitor other areas of thematic spend, such as the transition towards a net zero economy. HM Treasury said that the nature of the COVID-19 pandemic and its impact on the economy and public finances, meant that it was easier to identify the public spending implications of it than would be the case in other situations. For example, it told us that the banking crisis some 12 years ago was “also an enormous shock” and that it was difficult to attribute particular fiscal pressures to the banking crisis because it required disentangling lost tax revenue and additional public spending. It told us that most net zero related spending will also be designed to achieve other objectives, so it would be difficult to determine what is being spent on one objective or another. HM Treasury recognised, however, that it needed to work out the best way to ens

We noted that the public inquiry into government’s handling of COVID-19 was due to start in the spring or summer of 2022, and that understanding how money was being spent was likely to be an important part of this inquiry. We therefore asked HM Treasury how it would ensure that this information was kept in good shape to allow for proper scrutiny and oversight about how government had handled the pandemic. HM Treasury explained that there were three elements to identifying the cost of COVID-19. The first is the direct public expenditure during the pandemic, which was captured by the cost tracker. Secondly, there would be ongoing costs to public services in the future which would not have happened were it not for the pandemic, which it told us was “easy to measure today … [but] gets harder to measure as time goes by”. It explained that the third element is the indirect cost due to the effect on the economy, jobs and businesses, and the effect of this on tax revenue, which it told us was much more difficult to answer.12

HM Treasury told us that, during the pandemic, it had made some very significant sums of money available at short notice in conditions of great uncertainty. This funding was ring-fenced so that, if it was not needed for the intended purpose, it would not be spent on other things.13 HM Treasury told us that there will not be separate ring-fenced COVID-19 expenditure for 2022–23 onwards. It suggested that bringing the tracker to a close at the end of 2021–22 was “probably the right thing to do” given the difficulties in distinguishing expenditure from this point.14 We therefore asked what its approach would be to programmes such as NHS Test and Trace and the vaccines programme, which would still be in place after 202122 and were clearly COVID-19-related costs. HM Treasury told us that while some ongoing costs, such as NHS Test and Trace and the vaccines programme, could reasonably be separately identified, it was increasingly difficult to distinguish costs due to COVID-19 from routine business costs.15 It gave the example of the backlog of cases within the criminal courts where HM Treasury asserted that the source of the backlog did not matter, what mattered was dealing with the backlog and that it had not ring-fenced any money specifically for COVID-19-related backlogs. It 11 Qq 56–58 12 Q 19 13 Q 18 14 Q 9 15 Qq 8, 10 10 COVID-19 cost tracker update told us that this approach would provide departments with greater flexibility to deal with the circumstances they faced.16 HM Treasury said that it would keep the departmental allocations under review and respond to changes in the pandemic.17

HM Treasury told us that one element of the cost tracker it would definitely continue to monitor and report on was the cost of the various loan and grant schemes where the true cost will only be known over time.18 Government has guaranteed or issued loans worth a total of £129 billion during the pandemic. This comprises of loans issued through business support schemes such as the Coronavirus Business Interruption Loan Scheme, the Coronavirus Large Business Interruption Loan Scheme, the Bounce Back Loan Scheme, the Future Fund and the Covid Corporate Financing Facility.19 The September 2021 cost tracker reported that the government expected to lose £21 billion as a result of some loans issued or guaranteed by government not being repaid (write-offs).20 The Office for Budget Responsibility (OBR) produces estimates of write-offs that the government will be required to fund if loans it issued or guaranteed are not repaid. In October 2021, the OBR revised its estimate of the cost of write-offs for the 2020–21 financial year down to £21 billion from £26 billion in March 2021. This is partly because the economy is recovering better than expected but also due to some early repayment data.21 Estimated total Volume of Expected volume of loans loans reported cost of write- Scheme expected to guaranteed offs be guaranteed or issued by (£ millions) or issued by government (£ government (£ million) millions) Bounce Back Loan Scheme 47,360 47,360 18,373 Coronavirus Business 26,390 26,390 2,198 Interruption Loan Scheme Coronavirus Large Business 5,560 5,560 357 Interruption Loan Scheme Future Fund 1,137 1,137 75 Recovery Loan Scheme 1,600 428 164 Total 82,047 80,875 21,167

Across government’s response to COVID-19, there are also other substantial loan books that have no estimated write-offs as at the September 2021 update to the cost tracker, but which government will have to manage until the loans are repaid. For example, as at the September 2021 update to the cost tracker, Arts Council England was responsible for £252 million of loans issued through the Culture Recovery Fund.22 We examined the Culture Recovery Fund in June 2021 and concluded that, as the largest ever single investment in the arts and culture sector, and with a typical 20-year term, these will require skilled oversight and careful management for years to come. We were concerned about the Department’s and Arts Council England’s ability to manage the significant 16 Q 18 17 Q 11 18 Qq 19, 21; Letter from Tom Scholar, Permanent Secretary, HM Treasury, to Dame Meg Hillier MP, Monitoring the cost of cross-government programmes, 23 December 2021 19 The COVID-19 cost tracker, available at: COVID-19 cost tracker - National Audit Office (NAO) 20 Q 37 21 Office for Budget Responsibility, Economic and fiscal outlook – October 2021 22 The COVID-19 cost tracker, available at: COVID-19 cost tracker - National Audit Office (NAO) COVID-19 cost tracker update 11 and ongoing loan book commitments created by the Fund and recommended that the Department made sure it had the resources in place to take on the new responsibility for managing the loans.23

In its letter to us after our evidence session, HM Treasury recognised the helpful role that the NAO cost tracker has played in improving transparency on the cost of COVID-19, as well as its role as the definitive source of information on the public expenditure costs of the pandemic. It told us that it would conduct “a routine review of material changes to the estimated costs of these measures and provide public updates”. It confirmed that this would include updates to the estimated lifetime costs of loans and updated costs for some public services measures “where these can be reliably attributed to COVID-19”. It did not comment, however, on which measures this would include, what would constitute material changes to estimated costs, or what approach it would take to monitoring the costs of those measures that were not included in the updates.24 23 Committee of Public Accounts, COVID 19: Culture Recovery Fund, Eighth Report of Session 2021–22, HC340, 23 June 2021 24 Letter from Tom Scholar, Permanent Secretary, HM Treasury, to Dame Meg Hillier MP, Monitoring the cost of cross-government programmes, 23 December 2021 12 COVID-19 cost tracker update 2 Fraud and error within pandemic spending

We examined fraud and error across government in 2021. We found that government had introduced many vital support schemes in response to the pandemic, but that these had substantially increased the risk of fraud and error to public finances and the taxpayer was expected to lose billions of pounds as a result. Between April 2020 and March 2021, fraud within Universal Credit rose to an all-time high of 14.5%. At the time of our previous evidence session, BEIS estimated that between 35% and 60% of loans issued through the Bounce Back Loan Scheme may not be repaid.25 HM Revenue & Customs (HMRC), the Department for Work & Pensions (DWP), and the Department for Business, Energy & Industrial Strategy (BEIS) are responsible for some of the schemes we identified as having the highest risk of fraud and error. Since our report in June 2021, all three departments have published their annual report and accounts for 2020–21, which provide an updated position on the estimated fraud against some of the largest COVID-19 measures. These show that at the end of March 2021, these three departments expected to lose £15.7 billion as a result of fraud and error within COVID-19 support schemes, with their estimated total losses ranging between £12.4 billion and £20.1 billion.26 Department and scheme Estimated loss from COVID-19 support schemes Lower estimate Central estimate Upper estimate (£ millions) (£ millions) (£ millions) Department for Work & 3,850 Pensions & Universal Credit HM Revenue & Customs & 4,065 5,279 7,281 Coronavirus Job Retention Scheme HM Revenue & Customs & 355 493 631 Self-Employment Income Support Scheme HM Revenue & Customs & 43 71 99 Eat Out to Help Out Business, Energy & Industrial 3,615 4,944 6,725 Strategy & Bounce Back Loan Scheme Business, Energy & Industrial 514 1,038 1,562 Strategy & Local Authority Grant Scheme (figures do not include all local authority grant schemes) Total 12,442 15,675 20,148

We asked HM Treasury what its current assessment of fraud and error across government was, given the availability of the new data. HM Treasury told us that its upfront estimates on losses due to fraud and error were broadly in line with HMRC’s most 25 Committee of Public Accounts, Fraud and Error, Ninth Report of Session 2021–22, HC253, 24 June 2021 26 HM Revenue & Customs, Annual Report & Accounts 2020–21, 4 November 2021 HMRC Annual Report and Accounts 2020 to 2021 (Web) (publishing.service.gov.uk); Department for Work & Pensions, Annual Report & Accounts 2020–21, 15 July 2021 HC 422 – Department for Work and Pensions – Annual Report and Accounts 2020–21 (publishing.service.gov.uk); Department for Business, Energy & Industrial Strategy, Annual Report & Accounts 2020–21, 25 November 2021 BEIS Annual report and accounts 2020–21 (publishing.service.gov.uk) COVID-19 cost tracker update 13 likely scenario in its annual report and accounts for three of its measures: the Coronavirus Job Retention Scheme (CJRS), the Self-Employment Income Support Scheme (SEISS) and Eat Out to Help Out (EOHO). It explained that this had helped HM Treasury validate its methodology for estimating fraud. For example, it had initially estimated that fraud within CJRS and EOHO would be between 5% and 10%. It told us that the most likely estimated of fraud within the schemes were 8.7% and 8.5% respectively. It similarly told us that this had allowed it to target funding in a more effective way when investing in counter-fraud activities.27

In our report in June 2021, we recommended that HM Treasury and the Cabinet Office set out how they would ensure that departments implemented a zero-tolerance approach to fraud and error following the pandemic and ensure taxpayers’ money was recovered.28 We therefore asked HM Treasury what it was doing to recover money which had been paid due to fraud or error. HM Treasury told us that it had “put a lot more of [its] investment in the detection and recovery side of [its] fraud activities”.29 It explained that as a result of recent investment, HM Revenue & Customs had over 1,200 people dedicated to collecting this money. It explained that it expected this investment to have a “significant return” but admitted that, although it was monitoring this regularly, it did not yet have a good enough sense of “what that would actually mean in pounds and pence”.30 It confirmed, however, that it would not write-off this money until it had “pursued every single opportunity to recover it”.31 27 Q 30 28 Committee of Public Accounts, Fraud and Error, Ninth Report of Session 2021–22, HC253, 24 June 2021 29 Q 31 30 Q 31 31 Q 32 14 COVID-19 cost tracker update 3 Learning lessons from government’s response to COVID-19

The COVID-19 pandemic placed increased pressure on government departments to respond to a crisis while continuing to provide their business-as-usual services. The Comptroller and Auditor General told us that the NAO had now, for the most part, completed its examination of the initial schemes that were implemented at pace in response to the acute phase of the pandemic. He explained that in relation to the pandemic, the NAO was now examining longer-term issues such as the impact of backlogs in many public services and the recovery of fraudulent payments. He noted, however, that lessons can be drawn from these initial schemes, particularly regarding the trade-off between the need to act at speed, and control of public money and value for money.32

As part of our previous examination of the cost tracker in May 2021, we concluded that government’s ability to achieve value for money was compromised during the pandemic by poor quality impact assessments and Accounting Officer assessments.33 To address this, we recommended that HM Treasury should review major COVID-related spending decisions to identify cases where decisions made had resulted in poor value for money. We recommended that it should report its findings to us by the end of 2021, and use the lessons learnt to produce guidance to minimise the risk of this happening in future.34 HM Treasury shared a copy of its response to our recommendations with us ahead of our evidence session. In its response, HM Treasury disagreed with our recommendation. While HM Treasury agreed that lessons learnt from the pandemic should inform its future approach to similar situations, it asserted that maintaining a proper distinction of roles between Accounting Officers, HM Treasury and the NAO was the best way to do this.35

We therefore asked HM Treasury what it was doing to identify and address some of the issues raised by our and the NAO’s work examining the response to the pandemic, for example around the trade-offs between acting at speed and ensuring value-for- money.36 HM Treasury said that, although it had disagreed with our recommendation, it agreed that it should review major COVID-related spending decisions and “consider very carefully value for money”.37 It told us that it did not intend to carry out a full formal audit of all COVIDrelated expenditure and then reach a value-for-money judgement on all programmes. However, when we asked whether there was a process for assessing previous spending decisions and learning from them, it told us that ahead of new funding decisions, for example on NHS Test and Trace and the vaccines programme, it reviewed and learned lessons from departments’ previous spending.38

We examined the initial lessons that can be learned from government’s response to the pandemic in June 2021 based on 20 evidence sessions on various aspects of the government’s response. In our report, we set out our views on what government can 32 Q 5 33 Committee of Public Accounts, Fraud and Error, Ninth Report of Session 2021–22, HC253, 24 June 2021 34 Committee of Public Accounts, Twelfth Report of Session 2021–22, COVID-19 Cost Tracker Update, HC173, 19 July 2021 35 Q 2; HM Treasury, Government response to the Committee of Public Accounts on the Twelfth and Seventeenth to the Twenty-First Reports from Session 2021–22, CP 583, 9 December 2021 36 Q 2 37 Q 2 38 Q 40 COVID-19 cost tracker update 15 learn from its response to the pandemic, what it should do to ensure that those lessons are applied, and what it should do to improve both its ability to respond to emergencies and its business-as-usual service delivery. We noted that the future public inquiry into the government’s handling of the pandemic could take some years to complete, and that government could not wait for the review before learning important lessons.39

HM Treasury informed us that it had conducted a lessons learned exercise with Accounting Officers and it planned to update Managing Public Money in December

We asked HM Treasury what it was doing to ensure that, if emergency support such as business support schemes or loans were needed in future, those responsible would have the information they needed to act quickly, informed by lessons from the COVID-19 pandemic. HM Treasury explained that it was able to draw on lessons learned from the financial crisis of 2007–2009 when designing some of the COVID-19 schemes. In particular, HM Treasury said that it was useful to be able to draw on the design of measures used to address the effects of the financial crisis when it was designing the Covid Corporate Financing Facility, the Coronavirus Business Interruption Loan Scheme and the Coronavirus Large Business Interruption Loan Scheme. In contrast, it explained that there was no relevant precedent that HM Treasury could use to help design the Bounce Back Loan Scheme. As a result, HM Treasury recognised that there was a huge amount that could be learned from that scheme. We stressed that these lessons should be recorded in such a way that their usefulness does not depend on current HM Treasury staff being available when the lessons need to be drawn upon.44 39 Committee of Public Accounts, Initial lessons from the government’s response to the COVID-19 pandemic, Thirteenth Report of Session 2021–22, HC 175, 25 July 2021 40 Q 5 41 Q 49 42 Qq 52, 54 43 Qq 2, 5 44 Q 42 16 COVID-19 cost tracker update