BSC audit: Suppliers, SVA Agents and CVA Registrants
This page sets out the specific details for the BSC Audit that relate to Suppliers, Supplier Volume Allocation (SVA) Agents and CVA Registrants. This process is separate from the BSC Audit for ‘central systems’ and CVA Meter Operator Agents (CVAMOAs).
What’s new
As with the 2018/2019 BSC Audit, the SVA element of the BSC Audit will again be covered by the new Process Assessment approach, with continuing significant oversight from Elexon over the detailed on-site work undertaken by the BSC Auditor, including work papers and Audited Entity Selection. As with the 2021/2022 BSC Audit, CVA Registrants are covered by the new Process Assessment approach.
How it relates to you
Elexon continue to have control over the process by which Performance Assurance Parties (PAPs) are selected for audit and by which each audits’ intensity is determined. There is a greater flexibility in respect of audit site work when compared to previous years, with a drive to hold more site visits in November and December as opposed to the usual peak of activity in February and March, with the aim of reducing potential delays caused by tight scheduling.
The range of audit intensity continues to be “Full, Targeted and Limited”, with the Targeted intensity linking more closely with the new Focus Risks detailed in the Risk Operating Plan (ROP) and utilizing work papers linked to those Risks. Consideration is also given to each individual PAPs’ performance against processes and Settlement Risks covered by the BSC Audit in prior years’ in order to set a customised scope of testing for ‘Targeted’ intensity audits.
The approach to audit testing will remain largely unchanged; however the specific audit testing work papers to be covered at each audit intensity have been assessed against a broad range of factors intended to highlight the tests which have been most effective at addressing the areas of greatest risk.
Process improvements
While it is our expectation that you shouldn’t notice too many changes in respect of your audit site visits, a number of the improvements to the BSC Audit service we are implementing may have some operational impacts. We hope that you’ll find all of these improvements make for a more insightful audit and improve your experience of the audit but it’s still a good idea to look over the changes below to avoid any surprises during your audit.
Audit Planning Memorandums
The APMs are the formal notification that a PAP will be audited, and outline the work the BSC Auditor will carry out. Your Operational Support Manager (OSM) will contact you to set up a planning meeting to talk about arrangements for a site visit and any data we may request.
New changes: The APMs are being refined for the 2019/20 audit period and will provide further detail of the work to be performed, including the changes to the BSC Audit approach and the specific processes that will be covered for each audit testing work paper and data request.
Greater opportunity will also be provided for PAPs to plan how resource will need to be allocated to the BSC Audit during site visits.
Data requests
Requests for data will be planned ahead of time as part of the APMs. Your APM will be issued at least 20 working days ahead of your audit site visit (unless otherwise agreed) giving you at least 15 working days to provide the data requested as all data requested must be returned to the BSC Auditor at least 5 working days ahead of your audit site visit.
New changes: Industry feedback has indicated that BSC Audit Data Requests have a significant impact on PAPs’ resource. Elexon aim to improve the BSC Audit in this area by reducing this impact by finding alternative data sources and assessing the time given to respond to Data Requests.
Data Transfer Network testing
As part of the audit on-site work, scripts are be used to identify potential exceptions using the Data Transfer Network (DTN) data Elexon and the BSC Auditor have access to.
New changes: Feedback from prior years’ audits has indicated that certain DTN tests currently being operated as part of the BSC Audit have highlighted significant volumes of false exceptions. Elexon and the BSC Auditor are working to understand the root causes contributing to this and will be revising and testing DTN test scripts to reduce the volume of false exceptions returned.
Improvements to DTN tests will be ongoing with a view to designing and implementing new DTN tests once the existing tests are operating effectively. The effective use of DTN data presents the opportunity for the BSC Audit to deliver greater value insight into process failures and for a reduction in the volume of data that PAPs need to provide to support the audit.
New processes
Senior Stakeholder Audit Issue Summary Sign-off and Engagement
Following each audit the BSC Auditor will work to produce an executive summary of the Audit Issues identified, linking Audit Issues to the considerations most relevant to market participants operating in each BSC role.
These include the financial impacts of unresolved issues, Supplier Licence Obligations (where applicable) and reputational impact.
These summaries are aimed to build engagement with senior stakeholders, aid in issue resolution, improve awareness of the BSC and its relevance to your businesses.
Greater Audit Issue insight
The BSC Auditor will now be providing additional insight through the raising of BSC Audit Issues. This will include MPAN level detail of issues and root cause analysis.
This will help to provide a more complete view of Audit Issues and the associated root causes. It will also provide Elexon with more detail in support of its other remedial and assurance activities.
Audit Issues resolved within period
‘Resolved within period’ flags are being introduced to recognise where issues may have been resolved within the audit period removing the need for Error and Failure Resolution (EFR) plans to be drafted where issues have already been resolved.
In order for this flag to be applied the audited Party or Party Agent must be able to evidence to the BSC Auditor’s satisfaction that the issue has been resolved. In order to do this there needs to be at least three (3) months of data available subsequent to the resolution of the relevant Audit Issue.
Ad-hoc and repeat audit site visits
To ensure that the BSC Audit is risk based, flexible and responsive, we have created the opportunity for ad-hoc audits to be carried out in response to new and evolving risks.
Also to this end, we have also introduced the opportunity for the BSC Auditor to carry out repeat audit site visits within the audit period in response to Parties’ and Party Agents’ performance against the BSC Audit and the associated risk each Party or Party Agent presents.