Friday, February 9, 2018

Circular 03-2018

15/1089-90, VASUNDHARA, VASUNDHARA (P.O.), Dt. GHAZIABAD (U.P), PIN-201012

Reference: AIA/Circular-03/2018                                                       Dated:  9th February 2018

To
Unit Secretaries,
Members & Spl. Invitees – NE &
Members of Women’s Committee

Dear Comrades,

PROPOSALS ON RESTRUCTURING OF CADRES IN IA&AD SUBMITTED

As you are aware, the National Executive Committee of the Association met at Chennai on 4th February 2018 to finalise our proposals on restructuring of cadres in IA&AD on the basis of comments/views received on a draft paper that was already circulated to all Units.

On coming to conclusion on our approach with some modifications to the draft circulated, the Secretariat interacted with All India Audit & Accounts Officers Association who were also in session at Chennai.

Both the Associations jointly updated and finalised the paper on restructuring of cadres. It was decided that - keeping into the organisational requirements and honouring the members aspirations of each Association - to make slightly different postulations on one aspect, i.e. on the question of Direct Recruitment to the AAO cadre and promotion of SA as AAO with combined gradation/seniority list.

Gist of the proposals is:
  • Each Group “C” or Group “B” personnel from the entry level should be entitled to five promotions in the entire career – the one who passes departmental promotional examinations getting promotions faster and probably, more number of promotions. For e.g., one recruited as MTS during his career spanning for 30 years (presuming that he/she entered the Department at the age of 30) should get promotions to DEO, Auditor, Sr.Auditor, one non functional upgradation and one functional promotion and an Auditor getting promotions to SA, non Functional Up gradation with one functional promotion in between on seniority cum fitness.

  • Non Functional Upgradation as well as promotions should accrue based on the time bound manner. For every cadre, avenues for fast track promotion through examinations could also be considered. But such promotions shall be strictly to the next above cadre in the hierarchy.

  • The role of Auditor should be strengthened. Functional upgradation as Sr.Auditor and one Non functional Up Gradation to the pay Level 7 and one functional promotion to the pay level 8 should be awarded with the residency period of 5 and 6 years respectively. Audit of High Value of transaction with prescribe limit to be assigned to Non Functional Upgradation Sr. Auditors.
  • AAOs be guaranteed of promotion as Audit Officer on completion of 8 years of completed service as AAO.

  • There could be only common nomenclature in IA&AD. The Auditor, Sr.Auditor, Assistant Audit Officer, Audit Officer and Sr Audit Officer could be the designation.

  • The present age restriction of 53 years for induction to IAAS shall be removed. This is the serious hurdle experienced by the SR AOs cadre in their career progression. This has adverse impact on the promotion of AAOs.

  • Recruitment shall be at the Points of MTS, DEO, AUDITOR & IA&AS Levels.

·         Percentage system of promotions to be the basis for the time bound Non Functional Upgradation.

·         Stenographers of the same station be pooled together for the purpose of promotion

·         Stenographers at field offices be considered for higher posts available at HQr office

  • Post of LDC has become redundant and hence may be upgraded and merged with DEO.
  • The RR for each cadre with DR element may contain a specific percentage earmarked for unilateral transfer/deputation.
We, therefore, propose the following cadre structure for IA&AD:

1
MTS
DR and through regularisation of those at -1S

Clerk
The posts of Clerk may be up-graded and merged with DEO and redesignated as Audit Assistant at Pay Level 4
2
DEO
Direct Recruitment as well as promotion from MTS (through examination and seniority-cum-fitness promotions).  Pay Level 4.
3
Auditor
75% through Direct recruitment  and 25% through promotions           from    DEO and MTS - through Examinations for Graduate (DEO&MTS) on completion of 3 years and      seniority on completion of 5 years for others.    Pay level 5.
 4
Sr. Auditor Gr I
100% through seniority (after passing Confirmatory Examination) on completion of 3 years against the total strength of Grade I & II to the Pay Level 6.
5
Sr. Auditor Gr II
Non-Functional Up-gradation with the residency period of 5 years.  50% of Sr. Auditor posts should be upgraded (Non-Functional Up-gradation) and placed in Pay Level 7
6
AAO Gr I
60% through SAS Examination, 40% through seniority-cum-fitness promotion of SA Gr II - with single/integrated seniority list.
 Pay Level 8.
7
AAO Gr II
AAO Gr II (5400) on completion of 4 years in AAO Gr I cadre – only through seniority (Non-Functional Up-gradation).  Pay Level 9.
8
Audit Officer
100% promotion on seniority basis against the total strength of AO and SAO Gr I, II, III on completion of 8 years from the date of promotion as AAO Gr I to the Pay Level 10.
9
SAO Gr I
Senior Audit Officer Grade I – only through 100% seniority promotion from AO towards the combined strength of SAO Gr I, II, III on completion of two years to the Level 11.
10
SAO Gr II
SAO Gr II : Two non-functional up-gradation: 30% of SAO posts should be upgraded (Non-Functional Up-Gradation) and placed in the pay Level 12 with suitable designation and clearly defined work content.
11
SAO Gr III
SAO Gr III:  Another 20% of posts should be upgraded (Non-functional Up-gradation) and placed in the pay Level 13.  Filling up of upgraded posts of Level 12 & 13 to be treated as on completion of 5 & 6 years respectively.
12
Induction into IA&AS
On merit / seniority from SAO Gr I to the extent of 50% without age limit.  Pay Level 11.
Full text of the paper on proposals on restructuring of cadres in IA&AD is placed in our blog.

All the Units are requested to publicise the proposals and educate the members, preparing them for struggle in the days to come.

With greetings,
Yours fraternally 
                                                                                                                                                                                                                                                                                                                                                             Sd/-
M. S. Raja
Secretary General

ALL INDIA AUDIT & ACCOUNTS ASSOCIATION
CSV WARRIER BHAWAN
15/1089-90, VASUNDHARA, VASUNDHARA (P.O.), Dt. GHAZIABAD (U.P), PIN-201012
Ph: 01202881727/98681 45667

Reference: AIA/B-1/12/2018                                                                                 8th February 2018                                                        

To
The Comptroller & Auditor General of India,
9, Deen Dayal Upadhyay Marg,
New Delhi – 110124
           

            Subject: Restructuring of Cadres n IA&AD – Reg.

           
Sir,
            I am to invite a kind reference to letter No. 97 Staff (JCM)/8-2018 dated 23.01.2018 conveying there-in the terms of the reference of the Cadre Review Committee that has been constituted. In this regard, I would like to state that

            i) On item No.1, a detailed response is attached herewith.

            ii) on item No.2, the views are contained in the aforementioned response

            iii) On item No.3, we neither subscribe nor agree with the idea of having All India Audit &           Accounts Subordinate service as it will be divisive in nature and hence functionally damaging. We also see it as a ploy to deny promotion to the personnel born in the non     IA&AS cadres to IAA&S.

            iv) On item iv) & v), does not arise in view of iii) above.

Thanking you in anticipation,

Yours faithfully,
                                                                                                                                                                           Sd/-
 (M. S. Raja)
Secretary General

Enclosure: Detailed proposal on restructuring of cadres in IA&AD

Proposals on Restructuring of cadres in IA&AD

I).Introduction:

The IA&AD has a unique role and status in Governance. It is headed by the C&AG who is a Constitutional Authority. It is entrusted with the duty of ensuring Public Accountability in public spending and revenue receipts. It is an instrument of the legislature in their function of Parliamentary Control over the Finances of the Government. This means it works for, and for the benefit of, the common man. The C&AG's reports provide information to the common man about the efficiency and the propriety in revenue collection and spending by the State.  The reports of the C&AG help our economy and society   by suggesting and enabling improvements in financial management. This is a challenging and varied work that really benefits the nation.

II.The Institution called IA&AD:

Articles 148 to 151 of the Constitution prescribe a unique role for the C&AG of India in assisting Parliament to enforce the legislative accountability of Government Departments. The Constitution mandates the C&AG to audit both the Central and State Governments and also to compile the accounts of the State Governments. The Comptroller and Auditor General of India discharge his duties through the Indian Audit and Accounts Department.

Article 148 to 151 of the constitution read with DPC Act 1971 prescribes a unique role for cag in public admin and financial management in the country. The institution is mandated to perform following functions

·         Responsible for review and certification of union accounts and bringing into Parliament through President
·         Responsible for preparation, review and certification of state/union territory accounts and bringing into legislature through governor/Lieutenant Governor
·         Audit of expenditure and receipts of central and state governments, union territories, autonomous and regulatory bodies
·         Enstrusted with capacity building, supervision of accounts and audit of Local Bodies under TGS module
·         Indian Companies act 2013 read with DPC act CAG has a unique role in the certification of accounts and auditing of transactions of PSUs and preparation of audit reports.

Besides compiling the accounts, the C&AG is responsible for preparing and submitting the accounts to the Governors of States and Administrators of Union Territories having Legislative Assemblies. Besides, the CAG submits the audited accounts statements of union government to the President. He may also give information and render assistance, related to preparation of the accounts. The accounts of the State Governments are compiled, wherever entrusted, from the subsidiary accounts submitted by treasuries and other officers of the State Governments. In addition to the compilation of accounts the department raises alerts if monies are being drawn in excess of authorization. Expenditure patterns are monitored and advised on excesses, surrenders and lapses of funds are issued to enable proper control.

India is having the largest numbers of public sectors in the world. Within these there is a recognized need to strengthen performance, accountability and credible financial management systems. In this environment, the scale and complexity of the Indian Audit and Accounts Department’s work are extensive.  There are many challenges that impact public administration and need to be taken into account by the C&AG while discharging his duties. There is a recognized need to strengthen accountability for results and improve performance within the Government. Further, the Indian civil service is hierarchical in nature and process driven, with the focus of governance more on inputs than outcomes. Government reviews have also noted shortcomings in financial management systems and the authority, independence, coverage, capability and impact of internal audit functions. Several other features distinguish Indian Audit and Accounts department working environment from that of many of its international peers:

            • The extent and span of its audit work, which covers multiple levels of Government         and many different types of organisations across India and
            • Significant diversity in language, governance and development in the different states      in which it works.

III) Our Human Resources:

The C&AG's office located in New Delhi is the headquarters of IAAD. During 2016-17, it was supported by 138 field offices (133 offices spread across India and 5 offices located abroad). Its personnel are its key assets as it is a knowledge based organization. ISSAI (International standards for Supreme Audit Institutions) 40 prescribes that the SAI should establish policies and procedures designed to provide it with assurance that it has adequate number of competent and motivated staff to discharge its functions effectively.

In IA&AD, 33.75 per cent of the personnel are at different managerial and supervisory levels and 57.09 per cent constitute audit and accounts staff. Only 9.16 per cent (MTS) of the total strength provide support service. Of the sanctioned strength of 68,198 only 68.34 per cent staff is presently employed in the Department. During the year 2016-17, 2860 were recruited in the category of Audit & Accounts Staff. This helped in mitigating the deficiency to some extent. The officers and staff in Group 'B' & 'C' cadres are well qualified. (There are 175 doctorates, 3148 professionally qualified personnel, 5257post graduates and 26759 graduates in these cadres.)

The cadre wise person – in- position is given below 

(a)Indian Audit & Accounts Service (IA&AS) Officers are recruited through Union Public Service Commission. The top, senior and middle management level of IAAD are manned by officers from this service. They belong to the Group A services. The present Strength is 710.

(b)Supervisory Cadres: The Gazetted supervisory cadre (Group B-Gazetted) consists of Senior Audit/ Accounts Officers, Audit/Accounts Officers and Assistant Audit/Accounts Officers.  They form the critical operating management in our hierarchy. Assistant Audit / Accounts Officers are recruited either by a departmental examination or directly.  Among the Gazetted supervisory cadre, Senior Audit / Accounts Officers, Audit / Accounts Officer constitutes the middle level management, the cutting edge, and function as a bridge between the IA&AS Officers and subordinate officials functioning under them. These Group B officers constitute the face of the Indian Audit & Accounts department. Their total strength is 15,730 only

(c)Audit & Accounts Staff– Auditors/Accountants, Senior Auditors/Accountants are the mainstay of this segment. This cadre discharges the basic Auditorial and Accounting functions. This cadre is supported by Data Entry Operators (DEOs) and Clerks, Together they constitute 57.08 per cent of our total manpower. They are recruited by the Staff Selection Commission or promoted from feeder cadres. Their Present strength is 26,605 only.

(d)Multi-Tasking Staff–All support functions in various IA&AD offices are carried out by multi-tasking staff (MTS).  Their present strength is 4270.

IV) The need for restructuring of cadres in the IA&AD:

A cadre review in IA & AD took place, Audit in 1984 and later extended to A&E wing in 1987.  In both stages the cadre of AOs remained untouched.  However, in the year 1992, 80% of the posts of AOs were upgraded to SAOs with the pay a scale of Rs.2200-4000. The up gradation did not bring in any new post or changes in the duties. It was an attempt to create a sense of gratification among the stagnating officers, a mere non functional up gradation. The up gradation did not take into account the extent of stagnation, resultant frustration, the changes and challenges that the officers faced, the need to reorient them for the greater achievements and challenges that the department was aiming etc. Any cadre review, while taking into consideration the acute stagnation in the cadre, would also consider the work content, the changes in the working environment, changes in the objectives, the need for motivation and how best the expertise could be put to optimum  use and how to keep the morale high. It is imperative that such a review is undertaken without loss of time.

The IA &AD department employs about 15,730 Officers ( AAOs, AOs & SAOs) supported by 26,605 supporting staff. It audits the financial transactions of the Governments (which amounted to Rs.94,19,534 crore  (as per table A ) in the year of 2015 -16, an increase from  Rs.4,13,173  crore (as per table B)  in the year 1990-91. It carries the responsibility of certifying the accounts of the Centre and the States. The value of transactions might go high during the year 2016-17 and 2017-18, but there may not be matching improvement in the staff strength considering their retiring rate during these years. The present strength as on 1st November 2017 is, Sr.Accounts Officer 386, Sr.Audit Officer 3182, Accounts Officer 238, Audit Officer 1216, Asst Accounts Officer 2598, Asst.Audit Officer 6691 Supervisor 676, Welfare Assistant 85, Sr.Accountant 7118, Sr.Auditor 9013, Accountant 1565, Auditor 3741, Stenos 495, Clerk 1049 Hindi Posts 300, SG.Record Keeper 42, Misc Posts 126, EDP Posts 2399, and MTS 3913. In Short there are 14311 Officers (AAO, AO & SAO) supported by 26,050 (Clerk, DEO, Auditors/ Accountant, Sr.Auditor/Sr.Accountant, Stenos, Supervisors). The increase in the transactions would not result in an increase in the manpower deployed.

In India, the Audit and Accounts Department carries such heavy work load has been discharging the very important public Accountability function with such thin man power. It is essential that the morale of the employees needs to be maintained at the highest level. This makes the authorities of IAAD to attend the concern of the employees and officers. It is stressed here that there is an urgent need for the restructuring for removal of the stagnation which has plagued the cadres for long.

V. Significance and Dynamism of IAAD:

Budget after budget, the Tax Net, Expenditure Area, Investment options of the Centre and States grow. India is evolving to be the Fifth biggest economy in the world. The taxation laws, taxation concepts, public spending concepts, their magnitude and the rules governing them are all constantly changing. Expanding, Diversifying, Sharing PPP model and every growing activity in the economy bring lots of cheer as well as challenges and risks of scam.

That the changing priorities of the Governments and their pattern of transaction necessitates changes in the quantum of work carried out by the department can be appreciated by the dynamism in the number of reports presented by the C&AG.



No. of reports prepared and presented during the year
Recommendations Made
Recommendations accepted

2015-16
2014-15
2013-14
2015-16
2014-15
2013-14
2015-16
2014-15
2013-14
Union  Government
53
38
32
348
276
378
143
75
224
State and Union Territory Governments
135
124
102
1777
1540
1726
721
556
480
TOTAL
188
162
134
2125
1816
2304
864
631
704

It would be agreed that the growth in financial transactions resulted in consequent demand on the department despite the near static human resources.

The general organisation in the Accounts and Entitlement wing (A&E) of IA&AD is similar to that of the Audit wing. Accounts work also involves greater expertise, continuous updating of knowledge, ability to handle various nature of transactions, greater judgmental balance and so on. Besides being instrumental in promoting economy, avoidance of waste, changes of rules/procedure etc. aimed at improving efficiency and in doing so save considerable amount of public funds. In the changing pattern of the working of the states and the quantum jumps the personnel of this wing need to be constantly watchful, update their knowledge and be alert for the changing requirements in the accounting and entitlements front.

The personnel of the IAAD are involved in the noble cause of ensuring financial propriety in public finances. There is a constant demand on them to update their knowledge and to evolve speedy but accurate audit techniques. The very credibility of the department lies in their ability to meet the challenges of the dynamic and liberalized public finances.   That the C&AG continue to be a respected institution amply proves the worth of their contribution.    This is very highly technical work linked with the global challenges and situations. The Employees of the IA&AD have always risen up to the challenge of being a credible watchdog of the financial discipline. To establish an effective system of checks and balances, suitable tool has to be devised by the IA&AD. Hence, there is a need for restructuring   for removal of stagnation in their cadre and to provide comfort zones, suitable training and better powers to staff to discharge their accepted responsibilities. Non Functional Upgradation should be introduced to these stagnated technical cadres to achieve motivation. The stagnation is acute in the cadres of Sr.Auditor/Sr Accountant, Asst.Audit officer/Assistant Accountants Officer and Sr.Audit Officer/Sr.Accounts Officer. There is an urgent need for a suitable grade system of non Functional up gradation with higher audit responsibilities. Here, a higher responsibility means sharing of higher risks.

VI) Principles to be considered while restructuring the IAAD:

(i) Independent of the Executive: The Institution of Comptroller and Auditor General  is  envisaged as an agency on behalf of the legislature, to report to the appropriate legislatures, the irregularities and improprieties of the Executive in Financial matters in order to enable the legislature to exercise control over the Executive and make it accountable to the people. For achieving this objective, as would be apparent from the debate on this issue in the Constituent Assembly, the Comptroller and Auditor General of India and the staff under him need to be independent of the Executive and at a higher level. Accordingly Article 148 was finalized with Clause (3) providing the “ the salary and the other conditions of Service of Comptroller and Auditor General shall be such as may be determined by the Parliament by law” and with the clause (5) providing that “Subject to the provisions of the Constitution and of any law made by Parliament, the conditions of service of persons serving in the Indian Audit and Accounts Department shall be such as may be prescribed by rules made by the President after consultation with Comptroller and Auditor General.

Despite the fact that more than 7 decades have lapsed since the Constitution has come into effect, such a law has not been enacted nor have the rules as envisaged in the Article 148(5) been framed. Further the service conditions are being prescribed not by the President of India, but by the Government by merely extending the general rules, issued under proviso to Article 309, to the IA&AD personnel after consultation with the Comptroller and Auditor General, and that too without giving due weight to his recommendations. Consistently all the Comptroller and Auditors General have recommended for the IAAD personnel a status and salary structure on par with those in the Secretariat. Office of the Comptroller and Auditor General tendered written and oral evidence before the 7th Central Pay commission. Specific recommendations like not to create exceptional clause in order to deny Group ‘A’ status to Sr. AOs of IAAD and other recommendations were made on similar lines. But all such advices were not heeded to. The IAAD personnel continue to be on par with those of the “Subordinate Administrative offices”.

The Audit employees and officers have enough valid reasons to feel that the approach of the Government is a part of the policy of keeping Audit less independent and less effective. Successive Comptrollers and Auditor General have revealed in unambiguous terms that “ his staff have been kept under the mercy of the Government(Finance Ministry) for staff, accommodation, Office establishment and so on, whereas it is the Finance Ministry which comes most under the criticism of Comptroller and Auditor General, that the existence of the ‘whip hand’ that the finance Ministry holds on Comptroller and Auditor General “; " This reflects the Government’s Attitude towards Auditor General’s Office” and that the “sooner it ends the better it will be” . With the increase in Governmental activities both in magnitude, volume and extent, there should have been corresponding increase in the activity of IA&AD, but this has not happened. The Executive appears to have lost all respects for the institution. In this back drop there is a need to insist that the concept of Independent Audit be respected and practiced. Towards this  the possibility of appointment of High power committee for suggesting appropriate remedial measures for the Independent Functioning, appropriate staff strength, proper independent wage Structure for the IAAD employees free from the Finance Ministry as this would enable and ensure that the Institution of Comptroller and Auditor General acts independently and effectively needs to be explored.

(ii) Develop Competency and award proper mix of Functional promotion with time bound Non functional Upgradation: The staff of the Indian Audit and Accounts department had developed high level of competency in: 1. Analysis of data to draw sound conclusions 2. Demonstrating Sound Judgment 3. Communicating effectively with others 4. Demonstrating Enthusiasm initiative and drive 5. Building and maintaining effective Team relationship 6. Builds and maintain effective client relationships 7. Planning and organizing work to deliver high quality results while meeting the dead line 8. Understanding the larger picture to discharge the public accountability mechanism.  Suitable mechanism should be devised to develop the professionalism to meet the International Standards by imparting suitable training. In order to retain the talents in this segment a motivating time bound promotional policy which awards the proper mix of the  functional promotion and time bound non functional up gradation would be the fitting solutions for the craving stagnated cadres in the highly professionalized department.

(iii) Ensure superiority of IAAD: Officers and subordinate staff in the Indian Audit and Accounts department, facilitate the C&AG in formulating policies relating to audit and maintenance of accounts, in creating directions to the staff in various field officers on audit and accounting matters, in devising training for various cadres in the department for up grading  technical knowledge and skills, in compiling the reports, in facilitating and assisting in the Public Accounts Committee and the Committee on Public Undertakings. The variegated and onerous functions of these officers demand knowledge of widely divergent areas and constant updation. Hence the Restructuring of Indian Audit and Accounts department needs to reckon   the superior functions of the employees compared to their peers in other departments, the superior skills and knowledge required, and its contributions to the economy.

iv) Increase manpower: Being knowledge based Organization; human Resources are the key assets of Indian audit and accounts department. As per ISSAI 40 the SAI should establish policies and procedures designed to provide assurance that it has adequate number of competent and motivated staff to discharge its function effectively. However, the IA&AD is functioning with acute shortage of staff. The department had a sanctioned strength of  around 70000 employees. The current strength is about 46,610 only.  The deficit in manpower (32.83%) is due to two major factors. (1) Recruitment of new employees has remained almost frozen for two decades. (2)  Retirement of employees in the B & C groups without replacement. The major factor, contributing to areas of concern within the department, has been the fact that the work norms defined for Audit and Accounts has not been updated.  The staff strength required for each office has to be reworked on scientific work study norms; volume of work involved, and audit mandate and risk perception.  The functions and processes of the Government Departments to be audited have undergone sweeping changes since 1984 ( bifurcation of the department into Audit and Accounts) because of factors such as the huge increase in the volume of government transactions, budgeted revenue and expenditure, automation of certain government functions, increased role of Public Private Partnership (PPP) , increase in regulatory functions, e- governance, changes in public funding of major programmes and in numerous  schemes, etc. In the case of Accounts & Entitlements (A&E) Offices, the working environment has changed from manual accounting system to an IT based system. Considering the huge increase in the volume of works in the changed scenario, there is an urgent need to reassess the sanctioned strength and the adequacy of the existing strength.

v) Earlier restructuring of IAAD and the approach of the subsequent pay commissions: Though the restructuring was affected only in two cadres’ viz. Auditors and Section officers all other cadres per force had to exercise option to be in the parent office (ie A&E Office) or in the newly created office – as far as the offices of Accountants General were concerned. 80% of the posts in the cadre of Auditor (330-560) was functionally upgraded and granted the pay scale of 425-800, at par with Assistants in CSS and redesignated as Senior Auditor. The cadre Section Officer (500-900) was similarly restructured into Section officer (20%) and Assistant Audit Officer (80%) with pay of 650-1040 (Gazetted). The higher, functional scales were available only in the newly created offices of Accountants General (Audit) and all separate audit offices. The pay scale in the offices of Accountants General (A&E) continued at 330-560 for (newly designated) Accountants with 20% post in Selection Grade of Rs. 425-700 and 500-900 for Section Officers. The Fourth CPC recommended the same pay scale for Senior Auditors and Assistants in CSS ie 1400-2600 on the basis of merits. It further recommended restoration of the ‘broad parity that existed between audit and accounts’. Govt of India accepted this recommendation  vide OM dated 12th June 1987 extended the same pay scale for Accounts staff (of IA&AD and organised Accounts) with effect from 0.1.04.1987 ie 1400-2600 for Senior Accountants (80%) and 1640-2900 for Assistant Accounts Officers.

The main thrust of the restructuring of cadres of 1984 was that it gave a much sought after up gradation of pay scale as well as a movement to the cadres which otherwise were stagnating at the entry stage itself. Even today, the same pattern is continued in IA&AD. Though the pay scale of Assistants is continuously being raised each time after the audit and accounts staff attains parity is a pernicious act that demoralizes the entirety of IA&AD personnel.   The auditor/accountant onwards expect that the cadre restructuring would address one of basic issues i.e. parity with Assistants in CSS (maintaining vertical relativity) along with opening up chances for further career advancements.  It has to be pointed out that Sixth Pay Commission’s recommendations have not been fully implemented. If implemented Auditors & Accountants (Pre-revised Pay Scale 4500-7000) should have been in PB-2 with Grade Pay of Rs.4200 & Senior Auditors/Sr. Accountant in PB-2 with Grade Pay of Rs 4600 because the Government had granted PB2 with Grade Pay of Rs.4600 to Assistants of Central Secretariat – parity which had been recommended by the VI Central Pay Commission. Taking into account the assignment of PB-3 with Grade Pay of Rs.5400 to the Divisional Accountant Officer, the AO should have been placed in PB-3 Grade Pay 5400. 7th CPC has preferred not to touch the above issues except to grant of GP 5400 to AAOs on completion of 4 years.  The fact remains that these have only been adhoc measures bereft of any scientific study of the relative workloads and skill requirement.

vi) Upgradation of AAO on completion of 4 years of Service:  In case of Assistant Audit Officers/ Assistant Accounts Officers of Indian Audit & Accounts Department, who are in Grade Pay of Rs 4800, the recommendations made by the 7th CPC with regard to “upgrading on completion of four years’ service to Grade Pay of 5400 (PB-2), viz., Pay level 9, in the pay matrix” has been approved by the Cabinet. However, in Gazette Notification, it was mentioned that the matter regarding Defence Accounts Department and Railway Accounts Department would be referred to the Secretary, DOPT for examination. Unfortunately, despite Cabinet’s approval, the recommended pay scales for the Assistant Audit Officers/ Assistant Accounts Officers of IA&AD & Organised Accounts Department as approved by the Cabinet have not yet been implemented. Hence, it is very essential to consider for conferring the approved pay fixation benefits to the AAOs, by upgrading their Grade Pay to Rs 5400 (PB- 2) in pre revised pay scale on completion of 4 years of service as AAO and thereafter fixing the pay under the new Pay level - 9 in the pay matrix as recommended by the 7th CPC.

vii) Justification for Group ‘A’ status to the SAOs. The Honourable High Court of Delhi, in its order dated 17.09.2013 (W.P.(C) 2698 / 2013) ruled that the classification of Senior Audit / Accounts Officers as group A  officers was mandated under the applicable rules. The judgement has not been implemented by the Government of India. The GOI has, instead, appealed before the Honourable Supreme Court of India.  In order to boost the morale of the SAOs, it is imperative to grant them Group ‘A’ status with the time bound promotions as available to Group ‘A’ Cadre.

VII) Proposal:

 In the light of complexities that have developed in Government functioning, the demands on our department with respect to quality and quantity of work have enormously increased.  The institution has emerged as most respected constitutional institution in the public domain.  This has become possible, only because of the unrelenting efforts of the employees, especially AAOs/AOs/SAOs, and other staffs who carry out their tasks without fear or favour and with

utmost integrity. Unfortunately these Group ‘B’ Officers have very few opportunities for their future advancement and often stagnate in the same post for nearly 20 years.  Considering the role played by these Officers in the audit process, adequate promotional avenues for career advancement have necessarily to be created to enhance their sense of commitment.

The induction to the cadre of IA & AS cannot be considered as promotion as only 33.33% of that cadre strength is earmarked for induction and that too is fraught with too many restrictions.  Therefore there is an immediate need for cadre review to address these issues.  Presently, the complexities, in the preparation of Finance Accounts and Appropriation Accounts, and their audit, have enormously increased.  Maintenance of accounts in IT environment, likely implementation of new list of classifications and change in the format of maintenance of accounts etc. demand expertise and improved technicalities.  Already the Department has introduced examinations and training programmes to prepare the officers for the new challenges.  Today the C&AG is not merely an Auditor but also the custodian, and watchdog of Financial Management and Public Administration. Audit Reports, on various aspects of policies and programmes of the Governments, do reflect the new challenges which are ably handled by the AAO/AO/SAO. 

There is bottleneck prevailing in two cadres in the IAAD's structure. First at the Sr.Auditor/Accountant  Level. Pay Commission strongly opined that the person who clears the written  qualifying examination only are eligible for higher functional cadres. But in practice, in IAAD higher volume of transactions and work are assigned to those persons who have experience and got expertise due to their longevity of service. This should be suitably compensated. Hence introduction of non functional up-gradation must be seen as a proper solution to restructure this cadre. Another bottle neck is at the level of Sr.Audit/Accounts Officer. This is due to restrictions on the induction in to IA&AS cadre. The Sr.AO is the cutting edge cadre and backbone of this department. By introducing the non functional up gradation in these cadres, these expertise talents would be retained in the department itself. Keeping all these aspects the following suggestions are made for cadre restructure of IAAD:

  • Each Group “C” or Group “B” personnel from the entry level should be entitled to five promotions in the entire career – the one who passes departmental promotional examinations getting promotions faster and probably, more number of promotions. For e.g., one recruited as MTS during his career spanning for 30 years (presuming that he/she entered the Department at the age of 30) should get promotions to DEO, Auditor, Sr.Auditor, one non functional upgradation and one functional promotion and an Auditor getting promotions to SA, non Functional Up gradation with one functional promotion in between on seniority cum fitness.

  • Non Functional Upgradation as well as promotions should accrue based on the time bound manner. For every cadre, avenues for fast track promotion through examinations could also be considered. But such promotions shall be strictly to the next above cadre in the hierarchy.

  • The role of Auditor should be strengthened. Functional upgradation as Sr.Auditor and one Non functional Up Gradation to the pay Level 7 and one functional promotion to the pay level 8 should be awarded with the residency period of 5 and 6 years respectively. Audit of High Value of transaction with prescribe limit to be assigned to Non Functional Upgradation Sr. Auditors.
  • AAOs be guaranteed of promotion as Audit Officer on completion of 8 years of completed service as AAO.

  • There could be only common nomenclature in IA&AD. The Auditor, Sr.Auditor, Assistant Audit Officer, Audit Officer and Sr Audit Officer could be the designation.

  • The present age restriction of 53 years for induction to IAAS shall be removed. This is the serious hurdle experienced by the SR AOs cadre in their career progression. This has adverse impact on the promotion of AAOs.

  • Recruitment shall be at the Points of MTS, DEO, AUDITOR & IA&AS Levels.

·         Percentage system of promotions to be the basis for the time bound Non Functional Upgradation.

·         Stenographers of the same station be pooled together for the purpose of promotion

·         Stenographers at field offices be considered for higher posts available at HQr office

  • Post of LDC has become redundant and hence may be upgraded and merged with DEO.
  • The RR for each cadre with DR element may contain a specific percentage earmarked for unilateral transfer/deputation.
We, therefore, propose the following cadre structure for IA&AD:

1
MTS
DR and through regularisation of those at -1S

Clerk
The posts of Clerk may be up-graded and merged with DEO and redesignated as Audit Assistant at Pay Level 4
2
DEO
Direct Recruitment as well as promotion from MTS (through examination and seniority-cum-fitness promotions).  Pay Level 4.
3
Auditor
75% through Direct recruitment  and 25% through promotions           from    DEO and MTS - through Examinations for Graduate (DEO&MTS) on completion of 3 years and      seniority on completion of 5 years for others.    Pay level 5.
 4
Sr. Auditor Gr I
100% through seniority (after passing Confirmatory Examination) on completion of 3 years against the total strength of Grade I & II to the Pay Level 6.
5
Sr. Auditor Gr II
Non-Functional Up-gradation with the residency period of 5 years.  50% of Sr. Auditor posts should be upgraded (Non-Functional Up-gradation) and placed in Pay Level 7
6
AAO Gr I
60% through SAS Examination, 40% through seniority-cum-fitness promotion of SA Gr II - with single/integrated seniority list.
 Pay Level 8.
7
AAO Gr II
AAO Gr II (5400) on completion of 4 years in AAO Gr I cadre – only through seniority (Non-Functional Up-gradation).  Pay Level 9.
8
Audit Officer
100% promotion on seniority basis against the total strength of AO and SAO Gr I, II, III on completion of 8 years from the date of promotion as AAO Gr I to the Pay Level 10.
9
SAO Gr I
Senior Audit Officer Grade I – only through 100% seniority promotion from AO towards the combined strength of SAO Gr I, II, III on completion of two years to the Level 11.
10
SAO Gr II
SAO Gr II : Two non-functional up-gradation: 30% of SAO posts should be upgraded (Non-Functional Up-Gradation) and placed in the pay Level 12 with suitable designation and clearly defined work content.
11
SAO Gr III
SAO Gr III:  Another 20% of posts should be upgraded (Non-functional Up-gradation) and placed in the pay Level 13.  Filling up of upgraded posts of Level 12 & 13 to be treated as on completion of 5 & 6 years respectively.
12
Induction into IA&AS
On merit / seniority from SAO Gr I to the extent of 50% without age limit.  Pay Level 11.

Ø    13. The ratio of Group ‘A’ Officers (Group Officers) to Group ‘B’ officers (Senior Audit            Officers, Audit Officers and Assistant Audit Officers) is very high. In knowledge based Organisation an optimum span of control is very much required. The existing supervisory span of control 40 (12 to 15 audit parties) may be reduced to 15 (5 audit parties) to increase effectiveness of management         control by Group Officers. Accordingly the strength of number of Group Officers may be increased proportionately.

Ø    14. Functional expansion must be considered urgently. Strengthening of LB audit should be    seriously considered and acted upon.  In order to discharge            the       onerous responsibility vested in him, the C&AG as a custodian            caretaker, and the trustee of the finance of the State Government, the             accounts written up by him constitute the correct fiscal position of the state         government. the revenue realized in the process of discharge of their functions,       the taxes levied by them, the assignment of the Union levies to the state,         the       various grants             government sanctioned by the Union Government towards the        discharge of the various plan activities as well as the grants sanctioned to             bridge the gap between the plan and non plan resources are the main source of revenue of the states.  The expenditure met therefrom the public debt       assistance received to build up the    assets of the Government, whether the            revenue, capital expenditure is in commensurate with the resources of the       consolidated Fund.  Proper classification of the revenue and the expenditure in    accordance with the established principles laid down in the basic accounting            manuals. Hence the constitutional function           of the C&AG related to the state        Government Accounts should be ensured in the environment of Integrated     Financial Management system.        

Ø  15. Appointment of Bilateral Committee including all the recognised Federations   for restructuring the existing cadre set with a view to removing the stagnation in all cadres of Indian audit and Accounts Department from MTS to    Sr.Accounts/Sr.Audit Officers.                      

Ø    16. Accord professional recognition to the Accounts/Audit Officers and      Asst.Accounts/Asst.Audit Officers of Indian Audit and Accounts Department   treating them on par with the Chartered Accountants and Cost Accountant for         the purpose of auditing the accounts of commercial concerns and for practicing        as tax consultants.

Ø    17.Appointment of High power committee at the Government Level for    suggesting appropriate remedial measures for the Independent Functioning,           appropriate staff strength, Proper independent wage Structure for the IAAD employees free from the Finance Ministry Control as would enable and ensure             that the Institution of Comptroller and Auditor General acts independently and     effectively.
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