Who Audits the NAO?

As I have mentioned in passing I have recently been assisting some firms with fixed fee CCA audit appeals and some assessment of level 2 family claims. Alongside this there has been a National Audit Office assessment of files to which any number of our clients have been subject.
It is the latter which I suspect has provided the “evidence base” for this report. There are some obvious, and reasonable, objections to its findings made in this weeks Gazette.
Could I add some more?
The NAO way well be correct about the accuracy of LSC auditing. During the major Contract Compliance wars, for instance, we successfully achieved a downward reclassification of over 80% of CCA outcomes. A minority of these were subsequent to Cost Committee appeals. The files in this sample are subject to no such process so we do not know if their findings are either accurate or involve a reasonable interpretation of contract and guidance. This is of particular concern given the current “evidence of means” rule, and the other contract provisions re the new standard fees, have not been subject to any significant scrutiny – especially by way of applications for “Points of General Principle”.
This is a central flaw in the current fee and reporting regime there is no living appeals process which can inform billing practice. The death of the interactive Cost Committee system has exacerbated this.
These grandiose estimates of “over-claiming” are therefore simply that, estimates.