Consultation outcome

Changes to DHSC group accounting manual 2024 to 2025: consultation response

Updated 7 August 2024

All bodies within the Department of Health and Social Care (DHSC) accounting boundary (DHSC group bodies) must publish annual reports and accounts. Clear and transparent reporting helps the entity, as well as the users of the entity’s annual report and accounts, understand and scrutinise activities and outcomes.

DHSC and NHS England have powers to direct the:

• form in which the annual report and accounts should be prepared
• information that should be included
• methods and principles that should be followed in their preparation

In determining the form and content of the accounts, we must, by statute, aim to ensure the accounts present a true and fair view.

In order to achieve this, DHSC issues a group-wide manual every year, the group accounting manual (GAM), containing the requirements DHSC group bodies need to follow when preparing their annual reports and accounts.

The NHS foundation trust annual reporting manual (FT ARM) establishes the annual reporting requirements for NHS foundation trusts. The FT ARM contains the formal accounts direction, but foundation trusts will follow the GAM for accounts requirements.

The GAM requires DHSC group bodies to follow the requirements of international financial reporting standards (IFRS), as adopted by the United Kingdom, interpreted and adapted by HM Treasury’s financial reporting manual (FReM). 

Therefore, the GAM only includes detailed accounting guidance where DHSC group bodies are one of the following:

• required to depart from IFRS or the FReM
• required to make specific disclosures in addition to IFRS and the FReM
• faced with particular circumstances that IFRS or the FReM do not address

Updates to the GAM follow the same principle and, on that basis, are required where IFRS or the FReM have changed, or when DHSC group bodies are required to make specific extra disclosures.

Some content for the 2024 to 2025 GAM is not yet available, such as HM Treasury discount rates. The GAM indicates where this is the case, and the manual will be revised later in the year once this content is known. An additional guidance document published alongside subsequent updates of the 2024 to 2025 GAM will signpost the changes made within the manual.

Background to this consultation

This consultation related to the draft GAM for the 2024 to 2025 financial year. The consultation ran from 9 February 2024 to 9 March 2024. Following the consultation period, the revised GAM has been subject to further assessment by the financial reporting advisory board (FRAB) to clear the final draft for publication.

Feedback has been received from the user and audit community as well as technical experts, which has helped inform and enhance the development of the 2024 to 2025 GAM. The following sections of this document summarise the technical question posed, responses received and DHSC’s decisions.

Following this consultation and after consideration by FRAB, the 2024 to 2025 GAM was published in August 2024.

Details of consultation questions and responses

Applying the Task Force on Climate-related Financial Disclosure (TCFD) recommendations in the GAM

The December 2023 update to the 2023 to 2024 FReM contained annual report disclosure requirements stemming from the publication of the TCFD-aligned disclosure application guidance. The TCFD recommendations are being incorporated into the FReM on a phased basis over 3 years from the 2023 to 2024 financial year. DHSC is looking to reflect this approach in the GAM, with appropriate contextualisation of its applicability to the health sector.

As a consultation relating to the 2024 to 2025 GAM, we sought the views of respondents regarding the GAM’s proposed guidance relating to both phases 1 and 2 of HM Treasury’s TCFD application guidance. Phase 1 carries the annual reporting requirements for the 2023 to 2024 financial year and phase 2 the additional reporting requirements for the 2024 to 2025 financial year.

The guidance drafted for the GAM is not only subject to change based on responses to this consultation, but also subject to any material revisions made to HM Treasury’s guidance for phase 2, which was initially published in March 2024.

Phase 1 of HM Treasury’s TCFD-aligned disclosure application guidance:

• addresses the scope and nature of the requirements in applying the TCFD application guidance
• introduces the recommended disclosures under the governance pillar
• references the optional inclusion of emissions reporting (scope 1, 2 and 3 emissions) where currently collated as part of current departmental reporting based on sustainability reporting guidance requirements
• introduces a compliance statement to enable the entity to detail the extent to which the guidance has been complied with in its annual report

Phase 2 of the application guidance:

• provides some additional detail around the concepts and principles contained within chapter 1, which establishes the scope and nature of the TCFD requirements for public sector entities
• introduces the recommended disclosures under the metrics and targets, and risk management pillars

In developing its approach to incorporation of the TCFD-aligned disclosure application guidance within the GAM, DHSC has reflected on the fact that the HM Treasury application guidance does not automatically apply to NHS bodies. Consequently, DHSC has revised requirements around certain aspects of the HM Treasury application guidance to better reflect the context of the health sector. In particular:

• the GAM does not require NHS bodies to disclose or develop processes to disclose scope 1, 2 and 3 emissions reporting under the metrics and targets pillar. As emissions estimates for the NHS in England will be provided by NHS England, it is considered that undue costs and effort would be involved in each local body establishing a duplicative process for the purpose of this disclosure
• the GAM does not require a compliance statement, but provides suggested introductory text in making the disclosures while maintaining the Companies Act approach of requiring the entity to explain why the specific disclosures are not provided
• where other external reports provide relevant detail for compiling the TCFD recommended disclosures in annual reports and accounts, the information should not be duplicated in annual reports, but cross-referenced to, giving appropriate links to access the external report

Otherwise, DHSC maintains the approach taken within the HM Treasury application guidance by:

• maintaining the comply or explain basis to the provision of each recommended disclosure - notwithstanding the removal of the requirement, under the metrics and targets pillar, relating to the emissions reporting disclosure described above
• maintaining the requirement of the organisation to comply or explain against the phased TCFD disclosures, where the organisation has more than 500 full-time equivalent employees averaged across the reporting period, or has total operating income or is in receipt of funding exceeding £500 million
• welcoming voluntary adoption of the phased TCFD disclosure requirements for entities not meeting the employee or operating income thresholds
• referencing the need to consider the wider Implementing the Recommendations of the TCFD guidance alongside the HM Treasury TCFD application guidance content summarised in the GAM

The GAM has incorporated summarised detail relating to the TCFD recommended disclosures and supporting guidance provided in HM Treasury’s TCFD application guidance. This expands the section of the GAM covering minimum reporting requirements as part of a performance analysis, as introduced under paragraph 3.38 and detailed in a new annex to the GAM - chapter 3: annex 5.

The phase 1 detail was incorporated into the 2023 to 2024 GAM in April 2024 .

Consultation questions on applying the TCFD recommendations in the GAM

Do you have any comments on the move to incorporate TCFD recommended disclosures into the GAM to align with the FRAB endorsed approach HM Treasury are taking elsewhere in central government?

Summary of responses

Respondents supported the incorporation of TCFD recommendations in the GAM. One respondent recommended that the additional content regarding summary of progress against green plans, bulleted under paragraph 3.38, is duplicated in chapter 3: annex 5 to reinforce the joining up of reporting requirements.

A risk was noted that the approach of cross-referencing, rather than duplicating, climate-related content currently published elsewhere may detract from meaningful disclosure. Guidance around how to avoid repetitive and circular reporting was also recommended.

DHSC decision

We welcome the positive response to incorporation of the TCFD recommendations into the 2023 to 2024 GAM and 2024 to 2025 GAM. The guidance in the respective manuals has been published on this basis, with minor alteration reflecting enhancements consistent with the phase 2 TCFD guidance HM Treasury has published and the content of the 2023 to 2024 FT ARM.

There are a number of instances in which the GAM asks preparers to cross-reference to other published information for existing disclosures in chapter 3 of the GAM. We are confident that continuing this approach in relation to TCFD maintains an approach that preparers can employ and that hasn’t historically led to omissions or obfuscation of required disclosures. While acknowledging that the FReM carries a chapter covering the best practice in narrative reporting, the GAM is not considered the appropriate vehicle to hold such guidance for DHSC group bodies.     

Do you have any comments on the guidance provided in the GAM relating to the scope of application surrounding the TCFD disclosure requirements?

Summary of responses

One respondent confirmed that focusing on operating income would create scope criteria that ignores commissioning entities that receive funding and generate expenditure in delivering priorities, rather than generating operating income. A respondent requested an example of applying scope criteria within the GAM. Another respondent suggested that a minimum disclosure for all entities would be preferable.

DHSC decision

DHSC has revised the scoping criteria to incorporate references to both funding and grant in aid, as well as operating income, to ensure that the TCFD scope criteria is equally relevant to all types of DHSC group bodies. With the additional clarity in the scoping criteria provided, we do not feel an example of applying the criteria would assist entities significantly. With the ability to voluntarily adopt TCFD disclosures, combined with other continuing sustainability disclosures requirements, which now include green plan requirements for all NHS bodies, we consider that the GAM requires a robust set of sustainability and climate-related disclosures to be prepared by all entities. Consequently, we do not feel that minimum mandatory TCFD disclosures are required in the GAM.

Do you have any comments on the guidance provided in the GAM relating to the recommended disclosures under the governance pillar?

Summary of responses

A respondent recommended greater clarity that TCFD disclosures are made on a comply or explain basis. It was also noted that NHS boards may have delegated responsibility to other committees and, if this is the case, it needs to be reported.

DHSC decision

We are content that the introduction to chapter 3: annex 5 makes clear all TCFD disclosures are compiled on a comply or explain basis. We consider there is sufficient direction regarding the governance disclosures to ensure that an entity would have to disclose why their board has delegated sustainability matters. Consequently, the guidance regarding the governance pillar has been adopted in the GAM without further modification.

Do you have any comments on the guidance provided in the GAM relating to the recommended disclosures under the metrics and targets pillar?

Summary of responses

A respondent recommended entities develop processes to disclose scope 1, 2 and 3 emissions as part of this pillar, considering these key metrics in managing climate-related activity.

A respondent considered that detail in the HM Treasury application guidance regarding primary users and materiality should be replicated in the GAM, noting the importance for entities in considering the materiality of climate-related issues.

A respondent recommended public sector contextualisation of the TCFD guidance relating to the undertaking of significant activities, alongside welcoming the principles-based approach to the disclosures adopted in the GAM and FReM, and supporting the attempts to minimise duplication in the annual report and accounts.   

DHSC decision

DHSC agrees that assessment of scope 1, 2 and 3 emissions are key metrics but, as estimates are already developed by NHS England, there are cost- benefit considerations to be made in each individual entity developing processes to disclose this separately. Accordingly, DHSC is maintaining the proposed approach of not requiring entities to disclose this detail per the TCFD requirements in the GAM.

In regard to the supplemental guidance for significantly impacted industries, we leave open to the entity the choice to compile disclosures in line with the wider TCFD guidance. We also consider that, for the pillars under consideration in this consultation, there isn’t a material difference between the guidance for all sectors and the supplemental guidance. We will revisit this matter via a specific question as part of the consultation process on the 2025 to 2026 GAM.   

Do you have any comments on the guidance provided in the GAM relating to the recommended disclosures under the risk management pillar?

Summary of responses

No comments were made on this element of the guidance.

DHSC decision

The guidance has been adopted without further modification.

Do you have any other comments regarding the TCFD guidance in the GAM?

Summary of responses

A number of suggestions were made by respondents who recommended:

• further explanation of the disclosure pillars by incorporation of the overview of the TCFD framework figure from the HM Treasury guidance
• refinements to the proposed introductory text to remove assumed understanding of the TCFD framework and enhance simplicity
• specific reference to the message regarding the disbanding of the TCFD from October 2023 on the TCFD website
• inclusion of a sector overlay, on top of the generic guidance, identifying potential useful environmental metrics for the NHS
• additional guidance on the skills and resources required to undertake TCFD analysis to help NHS bodies assess these requirements, and the inclusion of a forward look to assist NHS bodies prepare for future years
• the provision of additional guidance to support bodies in making climate change reporting a practical tool for decision making, rather than risk it being a tick box exercise
• correction of typos

DHSC decision

DHSC welcomes the suggested refinements to its proposed guidance. We are content that the GAM guidance as proposed provides an appropriate balance of context and detail regarding the disclosure requirements. We do not consider the overview of the TCFD framework as a significant addition to the proposed content of the GAM, though it has been used as a key visual aid in TCFD implementation webinars DHSC has led. Some minor revisions have been made to the suggested introductory text to enhance understandability and the typos indicated have been rectified.

DHSC has not added a bespoke sector overlay to the guidance provided. We consider that users of accounts will receive the most informative and understandable disclosures where entities detail how they organise themselves to assess, address and monitor performance against targets relating to climate-related issues. We consider these requirements are established by the generic guidance incorporated into the GAM. Equally, no reference to the TCFD disbanding has been made, as the appropriate guidance remains accessible via the TCFD website linked to in the proposed text to the GAM. If this position changes, DHSC will consider updating this aspect of the guidance in the manner considered by the respondent.

The recommendations for additional guidance to support entities in undertaking TCFD analyses, ensuring climate-related reporting is integral to decision making and developing a forward look to inform preparations, are all recommendations that will enhance the implementation of TCFD recommended disclosures and activities around climate-related issues, but these are not matters for inclusion in the GAM. The GAM, for instance, sets out the minimum content of an annual report and accounts. Where implementation guidance has been provided historically, this has been published by NHS England, rather than housed in the GAM. A similar approach would be taken here. We will share the relevant comments with the appropriate colleagues in NHS England to inform any considerations around planning and implementation guidance for TCFD and climate-related issues more broadly.            

Measurement of public private partnership (PPP) and private finance initiative (PFI) liabilities using IFRS 16

The FRAB previously concluded that, with the implementation of IFRS 16 across the public sector, the approach to measuring PFI liabilities as detailed in chapter 10 of the FReM was required to transition from an approach reflecting the previous leasing standard, IAS 17, to one reflecting the principles of IFRS 16. It remains the case that the accounting for PFI liabilities will be based on the guidance in the FReM (which is in turn based on the lease accounting standard principles) rather than a direct application of the standard itself.

During the 2023 to 2024 financial year, DHSC and HM Treasury have both updated their respective manuals and issued additional application guidance, and DHSC has provided revised model solutions for entities to employ, as part of their transition to measuring PFI liabilities on an IFRS 16 basis. It is therefore expected that no further updates are required to the GAM for this matter in either the 2023 to 2024 GAM or 2024 to 2025 GAM, except to remove the transitional provisions from the GAM that are no longer relevant for the 2024 to 2025 GAM.

Consultation questions on the use of IFRS 16 to measure PFI liabilities

Do you have any further comments regarding the guidance provided in the GAM relating to the measurement of PFI liabilities on an IFRS 16 basis?

Summary of responses

The only substantive response noted a need to update disclosure requirements to make these clearer following discussions with NHS bodies and recommended that the guidance is revisited following the first year of implementation.

DHSC decision

Additional clarity has been provided in the necessary disclosures of PFI liabilities in chapter 5 of both the 2023 to 2024 and 2024 to 2025 iterations of the GAM. DHSC is happy to revisit the guidance based on reflections from the 2023 to 2024 audit process.

Other changes to the GAM

There are no other planned material updates to the 2024 to 2025 GAM.

There are no standards updates effective for the 2024 to 2025 financial year that require further contextualisation in the GAM.

Minor changes made to the 2024 to 2025 GAM include:

• requiring an entity, which must have a green plan in place, to provide a summary of progress against delivery of its green plan, as part of the performance analysis. This is included in the sustainability reporting bullet point beneath paragraph 3.38 of the GAM
• reflecting the public dividend capital policy, finalised for 2022 to 2023, in the 2024 to 2025 GAM. As is referenced in the GAM, entities should note that any changes to the cash regime and dividend policy will be communicated as a quarter 4 update to the GAM in the additional guidance document

Note that, while the GAM has been rolled over to present 2024 to 2025 dates and content where available, certain elements of guidance, such as HM Treasury discount rates, will be provided later in 2024 and 2025. These matters will be finalised as part of the additional guidance updates to the 2024 to 2025 GAM.

Prior to publication of 2024 to 2025 GAM, the presentation of certain elements of the GAM was revised to enhance the general accessibility of the manual.

Consultation questions on other changes made to the GAM

Do you have any other general comments on draft group accounting manual?

A summary of the comments received in response to this question and the DHSC decisions taken follows.

Comment and DHSC decision

Foundation trusts have a specific duty to disclose activities to tackle health inequalities but NHS England’s statement on health inequalities references ‘NHS bodies’.

As a result of implementation of the Health and Care Act 2022, additional content was included in the 2023 to 2024 GAM that detailed requirements for NHS bodies around health inequalities. Content was added to paragraph 3.27 for NHS trusts and 3.28 for integrated care boards (ICBs).

Comment and DHSC decision

A link to the IFRS standards would be useful to preparers of the accounts.

This has been included in paragraph 1.3 in both the 2023 to 2024 and 2024 to 2025 GAMs.

Comment and DHSC decision

The legislative framework section gives particular focus to foundation trusts over other NHS bodies.

That is because the GAM needs to reference the FT ARM, whereas further detail regarding the legislative basis of NHS bodies is sufficiently referenced in chapter 1 and chapter 2: annexes 3 and 4.

Comment and DHSC decision

Chapter 2: annex 4 details the NHS trusts’ accounts direction. Other accounts directions should be linked to in the GAM.

The GAM was considered the most efficient vehicle for sharing the NHS trusts’ directions, and other directions are determined and distributed per the detail covered in chapter 2: annex 3. No further update is proposed.

Comment and DHSC decision

Reference should be made to foundation trusts in chapter 2: annex 6.

Given the FT ARM details the annual reporting requirements for foundation trusts, this omission is deliberate.

Comment and DHSC decision

The GAM still references the financial reporting council’s 2018 publication of the guidance on the strategic report which was updated in 2022.

Paragraph 3.9 of the GAM contains factual content as the FReM does make specific references to the 2018 publication rather than the updated 2022 guidance. No further update is proposed.

Comment and DHSC decision

In regard to paragraph 3.15, it would be helpful to refer to the Code of governance for NHS provider trusts and cross-reference to the relevant paragraph that deals with disclosure requirements under the code.

The content of paragraph 3.15 is factually accurate and the reference to the NHS provider code is made appropriately further down in chapter 3. We are content with the approach in the GAM.

Comment and DHSC decision

Paragraph 3.28 refers to general duties that an ICB must report on. Is it possible to list these for the readers?

The wording of the GAM mirrors the language used in section 14Z58(2) of the Health and Care Act 2022. We are content that the GAM therefore presents appropriate detail and contains relevant cross references for users of the GAM to work through the requirements of the legislation.

Comment and DHSC decision

It would be helpful if further clarity was provided regarding the requirement for additional disclosures where unit costs are central to decision-making or accountability functions.

The historic inclusion in the GAM reflected the introduction of the content to the FReM. We are content that the requirement and supporting information enables preparers to compile a suitable disclosure where relevant. We are open to revisiting if a number of GAM users identify this requirement as difficult to employ as currently described.

Comment and DHSC decision

The FT ARM provides guidance on disclosures required by the code of governance for NHS providers. The GAM and ARM should align on presentation of these.

Schedule A of the code of governance provides adequate coverage of the disclosures required by providers, so replication of this is considered duplicative and would also add significant length to the GAM.

We are mindful of the benefits in limiting the length of the GAM in ensuring users can more easily identify all requirements of the guidance. This is in line with the stated objectives of the GAM: to not repeat requirements where they require no interpretation or adaptation.

Comment and DHSC decision

Where there is a joint appointment, the GAM is clear only the remuneration relevant to the reporting body is included in the single total figure table. Should the same principle be applied to pension-related disclosures?

The guidance regarding staff sharing in paragraphs 3.79 to 3.81 relate to both tables in the remuneration report. The matter is addressed in the introductory comments for this section of the report, intending this aspect of guidance to be applicable to the requirements that follow. A consistent approach between the 2 tables is therefore expected to be taken on this matter.

Comment and DHSC decision

Paragraph 3.97 discusses the approach to disclosure where a member has opted out of the pension arrangements. Specific guidance in relation to other arrangements, in place of pension contributions, would be useful.

This point is also raised in regard to comments relating to stakeholder pensions.

Significant detail is provided as to what is and isn’t considered salary as part of the remuneration guidance in the GAM, which has interplay regarding the issue raised.

Comment and DHSC decision

A specific approach has been clarified regarding the treatment of pension remedy impacts in relation to disclosure in the remuneration reporting tables, but is any additional general statement required where pensions information is detailed?

This issue was discussed with NHS Pensions and it was agreed that reference to the remedy beyond where it has impacted the remuneration reporting, was not informative to the user of the accounts.

Comment and DHSC decision

The fair pay disclosure in paragraph 3.122 of the GAM is not the same as paragraph 2.93 of the FT ARM.

The consistency between the 2 documents has been reviewed and, while presentation of the requirements differs slightly, the content is consistent. DHSC does collaborate with NHS England on the compilation of updated guidance that impacts both manuals.

Comment and DHSC decision

It would be helpful to include in the GAM the guidance in paragraph 2.1 of the Hutton guidance that the highest paid director should be consistent with the single total figure table for remuneration.

We are content that the cross reference to the Hutton Review of Fair Pay implementation guidance in paragraph 3.124 is sufficient in grounding this expectation in compiling the fair pay disclosure.

Comment and DHSC decision

In relation to partially completed spells guidance in chapter 4, it would be helpful to refresh the guidance to refer to aligned payment and incentive arrangements and whether they could result in partially completed patient spells.

We agreed with the need to refresh the guidance. Updates have been made to reference the requirements of IFRS 15 where partially completed treatment spells arise, reflecting guidance that was in place prior to the 2020 to 2021 GAM.

Comment and DHSC decision

DHSC should consider amending the capitalisation threshold, which has been in place over several decades, with changes stemming from the non-current asset thematic review being an appropriate time to revisit this.

DHSC is considering the implications of changing the capitalisation threshold and will consult further with DHSC group bodies if an implementable proposal can be developed.

Comment and DHSC decision

It would be helpful to provide additional budgeting guidance for provisions and the difference between provisions and accruals.

We don’t consider the GAM to be the appropriate vehicle for such guidance, with only high-level messaging around budgeting misalignments with accounts being detailed in chapter 2 of the GAM. DHSC will consider the benefit of such guidance and the appropriate housing of this guidance with NHS England.

Comment and DHSC decision

Reference is made to charities where trustees are appointed by NHS England. This is no longer the case as NHS charities are either independent or have an NHS body as the corporate trustee.

This reference will be reviewed ahead of the 2025 to 2026 GAM consultation. It does not impact the accounting and reporting considerations detailed in chapters 4 and 5 of the 2024 to 2025 GAM.

Comment and DHSC decision

It is not clear what is meant in paragraph 4.399.

Paragraphs 4.398 to 4.400 describe the modified absorption transfer accounting treatment that entities, within the departmental group, have employed for certain transfers of function. We are content with the detail covered in these paragraphs.

Comment and DHSC decision

Regarding chapter 4: annex 1, should IFRS 17 be included in the table of standards, as it has been published but is not yet applicable to the NHS?

As IFRS 17 is not applicable until 2025 to 2026 for the NHS, it is appropriately included in chapter 4: annex 2 as a standard issued but not yet adopted in the FReM, alongside IFRS 18 and IFRS 19, which were published after the consultation concluded.

Comment and DHSC decision

The paragraph in chapter 4 on new models of care may need updating to reflect the latest practice, such as provider collaboratives and other joint working arrangements.

DHSC agrees with this point and will continue to monitor whether there are specific updates to be made in this regard.

Comment and DHSC decision

Valuation of right of use assets has been raised as an issue by auditors, with some firms insisting that a valuation is required as lease contracts do not reflect market price. Similarly, auditors have noted that some organisations are also considering revaluing right of use assets.

It was expected that it would be rare that an external valuation for a right of use asset would be required. It would be helpful if the GAM could make this clear.

The FReM and GAM make clear that the cost model can be an appropriate proxy in the following certain scenarios:

• when arrangements contain regular provisions to update rental payments
• where there are shorter useful lives and lower value assets
• when those assets don’t have significant fluctuations in fair values or current values in use, due to changes in market prices and conditions

Otherwise, a revaluation model needs to be applied.

The GAM is appropriately clear in this respect and provides a decision tree that helps entities identify, on a principles-based approach, what type of approach to valuation is applicable, given the circumstances surrounding a particular asset. As such, no further updates are planned to the guidance in this respect.

Comment and DHSC decision

NHS England developed useful guidance that was presented at an accounts conference on the difference between a lease modification and a lease remeasurement. It would be helpful to include that guidance in the GAM.

The NHS England IFRS 16 webpage would be the correct place to house this additional guidance. No further update to the GAM is proposed.

Comment and DHSC decision

Entities are now struggling with the impact of IFRS 16 on budgeting. It is important that budgetary impacts of proposed changes are fully explored and understood so there aren’t unintended consequences.

Prior to the implementation of a standard, HM Treasury provides opportunity for departments and entities to confirm the extent of the budgetary impact of a standard being implemented, to ensure that budgets are appropriately adjusted through the estimates process. DHSC and NHS England worked closely with NHS bodies, arm’s length bodies and HM Treasury in completing this process, though we are always open to reflecting on how these processes can work better.

Comment and DHSC decision

It might be useful to include reference in paragraphs 5.264 and 5.265 to Managing public money and the need to seek HM Treasury approval before making a donation to charity from exchequer funds.

Managing public money considerations are detailed in paragraph 2.85 of the GAM and followed up in chapters 3 and 5. No additional content is proposed.

Conclusion to the consultation

We are grateful for all the responses we received to our consultation. As a result of these, we made a number of changes to the 2024 to 2025 GAM and the 2023 to 2024 GAM as part of its April 2024 year-end update.

In considering the comments received, we have needed to ensure that the guidance given in the GAM is clear and sufficient, without becoming overly detailed or prescriptive. In some cases, therefore, we have noted comments made, but have concluded that the guidance should remain as drafted as identified above.

We would like to thank all respondents for their direct input into delivering a product that FRAB was content to approve.

There is always scope to deliver further improvements to the GAM. We have taken away a number of issues from this consultation for consideration in drafting the 2024 to 2025 additional guidance updates and the 2025 to 2026 manual, which will be subject to consultation in early 2025.

Annex 1: list of respondents to the consultation

The below respondents responded to the GAM consultation directly through the consultation platform:

• Grant Thornton UK LLP
• Healthcare Financial Management Association
• University Hospital Southampton NHS Foundation Trust

Separately, the below respondents discussed the contents of the consultation with DHSC during and after the consultation had concluded to help finalise contents of the guidance provided in the GAM:

• Financial Reporting Advisory Board
• HM Treasury
• National Audit Office
• NHS England