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Procurement Compliance Improvement

Public Procurement

As the largest public sector organisation in the State, the HSE is accountable for effective and compliant procurement which delivers value for money.

All procurement activities take place within a regulated environment underpinned by complex EU and national legislation, meaning the HSE organisation must ensure that it is fully compliant with legal, policy and corporate governance obligations. 

The HSE is committed to achieving value for money and conducting all procurement activities in a fair and transparent manner which will drive improved compliance with procurement regulations.

What is Procurement Compliance?      

Any spend with a Vendor/Third Party/ Supplier requires public procurement rules to be adhered to in full and in advance of engaging with a vendor and committing to any expenditure.

Public procurement regulations are set out in the HSE National Financial Regulations B-1 Procurement document.

Procurement Compliance Improvement and Reporting

Within HSE Finance, the Corporate Procurement Compliance and Improvement Team monitors procurement compliance retrospectively at the invoice level using the in-house developed Procurement Assessment Compliance Tool (PACT), which was created as an interim solution ahead of the full rollout of the Integrated Financial Management System (IFMS).

The PACT process is done as a ‘Self-Assessment’ by every function within the HSE.

Ownership for T&T Self-Assessment resides with myself and my team:-

  • On a retrospective monthly basis, Finance Shared Services (FSS) provide National Procurement with a data extract of invoices from the HSE financial systems.
  • Procurement sanitise the data to isolate all procurable spend invoices over €25,000 (ex VAT) and upload invoice information to the PACT system.
  • The owner completes a review and assessment of each invoice to determine if the spend is/is not compliant with National Financial Regulations (NFRs);
  • Vendor spend is assessed as Compliant: 
    • Valid contract exists pertaining to the Spend Under Management (SUM) as set out within the contract term, value and scope -  or vendor spend is assessed as Non- Compliant.
  • Vendor spend is assessed as Non-Compliant:
    • Valid contract does not exist.
    • As part of a ‘Non-Compliance’ Assessment, details regarding the proposed plan of action to address this must be uploaded to PACT.

Following full deployment of IFMS, PACT may not be required long-term as functionality within IFMS supports compliance recording and reporting at source.

Senior Management Reporting

At the end of each quarter, the Procurement Compliance Team submit a summary report of all HSE expenditure and compliance/non-compliance status to the National Director of Procurement.

At the close of the financial year, final figures are included in the annual board report which is submitted to the CEO. The report includes a summary of contracts/spend which is non-compliant with public procurement guidelines – the report also details the reason for the non-compliance and the individual department’s plans to address this through an agreed plan of action.

There is an obligation on the T&T Function to ensure that all of our expenditure, and supporting contracts, are compliant with procurement regulations.

WHO is responsible for procurement compliance?     

Compliance with HSE National Financial Regulations (NFRs) is everyone’s responsibility, both at an individual level and also collectively as Technology and Transformation Budget Holders.

If in your current role you engage with a vendor(s) to request provision of services, purchase of goods and/or approve invoices for payment you should be aware if a valid contract exists prior to initial engagement and committing to expenditure.

In 2025 the aim is to improve T&T procurement compliance posture within the organisation. We all need to play our part by ensuring that we are aware of and fully adhere to NFR – B1 - a HSE Procurement Guide for Budget Holders.

A HSE Procurement Guide for Budget Holders

HSE Procurement launched a training programme on HSELanD to support HSE Budget Holders.

The aim is to educate participants on how to procure in a compliant manner in order to meet HSE obligations under the NFRs – the course is very informative and worth allocating time to complete it.

Due to staff growth within T&T it is recognised that colleagues who are currently involved in managing budgets and approving payments with vendors may not have been involved at the commencement of the vendor engagement and may be unsure if a contract exists, or if it is still valid.