Correctional Service of Canada: Responses to the Implementation Advisory Panel’s first annual report 2021-2022 on the implementation of the structured intervention units

The Correctional Service of Canada’s (CSC) fundamental purpose is to rehabilitate inmates. Everything we do is focused on assisting inmates prepare for a successful reintegration into the community upon their release.

In November 2019, as part of a historic transformation of the federal correctional system (former Bill C-83), CSC eliminated both administrative and disciplinary segregation and implemented Structured Intervention Units (SIUs) to temporarily house those inmates who pose a risk to others or are themselves at risk. In addition, former Bill C-83 also made significant amendments relating to health care, including formal legislated recognition of the professional autonomy and the clinical independence of registered health care professionals. For example, in their promotion of patient-centred care and patient advocacy, health care professionals can make recommendations to the institutional head to alter the conditions of confinement or release inmates from an SIU for health reasons.

SIUs are in place at 15 of our 43 institutions. SIUs are not about punishment or causing harm – quite the opposite. SIUs are about helping inmates and providing them with the opportunity to engage in targeted interventions and programs to support their safe return to a mainstream inmate population as soon as possible.

On average, there are approximately 150 inmates in Structured Intervention Units on any given day, which represents 1.2% of federal inmates in Canada.

CSC research has found that the SIU population displays complex risks and needs that require intensive levels of service beyond that of the mainstream inmate population. Therefore, interventions for inmates in an SIU are not a “one-size fits all approach”. For example, inmates who present with complex needs, such as tendencies towards violence or aggression, often require ongoing support and assistance to help safely reintegrate them to a suitable mainstream population.

Since the implementation of SIUs, CSC has had to manage through the pandemic, which had a significant impact on its staffing levels and delivery of programs and services. Despite these challenges, CSC continued its work and completed two audit engagements related to SIUs. Based on the findings of these audit engagements and our experience to date, CSC is in the process of enhancing its SIU staffing model, by adding new positions to best support inmates in achieving positive outcomes.

As we continue to learn and make adjustments, we remain steadfast in our commitment to ensure the success of this new correctional model. A transformation of this magnitude requires ongoing and sustained effort over time. Indeed, this is a cultural shift in corrections.

CSC continues to engage with staff and work with external oversight bodies and stakeholders, to gather their views and work to address any challenges or recommendations they bring forward. CSC recognizes that policies, practices and procedures will need to evolve over time as we gain more experience with this new model.

CSC welcomes the Implementation Advisory Panel’s first annual report. CSC has carefully considered and responded to all recommendations directed to the Service. CSC’s responses below are in addition to those provided by Public Safety Canada.

IAP Recommendations

1.1: No prisoners are to be assigned to any form of restrictive housing until all other options have been explored and their lack of suitability documented.

CSC Response:

Under the SIU model, restricted movement is the only other type of restrictive housing permitted by the legislation. It can only be used for a maximum of five working days. During those five days, the staff must explore every possible alternative to return the inmate to the mainstream inmate population and the Institutional Head must make a decision on whether the inmate’s transfer to an SIU should be approved.

Alternatives include, but are not limited to, a transfer to a different unit or range within the institution, involvement of the Inmate Committee or the institutional range representative, mediation or conflict resolution, transfer to another institution or regional treatment centre, or involvement of staff who have influence over the inmate, such as an Elder, Chaplain or Indigenous Liaison Officer.

CSC will continue to reinforce the importance of thorough documentation every time an inmate is authorized to be transferred to an SIU, including a sound rationale for the transfer and any alternatives that were considered.

1.2 Each institution is to catalogue all forms of housing that are not used for the mainstream population, including any with restrictions on movement and association. Prior to placement in any form of restrictive housing, a formal assessment must be completed that will document why restrictions are necessary and detail a plan for removing restrictions as soon as possible. Placement in any form of restrictive housing will be approved by the Institutional Head.

CSC Response:

Placement in any form of restrictive housing must be approved by the Institutional Head and must specify the reasons for the placement. The continued placement of an inmate in restrictive housing must also be justified.

Examples of other restrictive housing that is closely monitored include: placements in a dry cell, observation cell and medical isolation. There is oversight in place for all of these.

CSC’s mandate is to encourage and assist inmates in their rehabilitation journey. As such, all alternatives are explored to minimize placement in restrictive housing and keep our institutional environments safe and secure.

1.3: The Office of the Correctional Investigator is be informed of the use of all forms of modified routine/restrictive housing through quarterly reports.

CSC Response:

CSC remains open to increasing transparency and information flow with its advisory bodies and the Office of the Correctional Investigator. The Commissioner commits to continuing to work with the Correctional Investigator to identify any additional information it requires relating to SIUs or the work of CSC.

2.1: The timeframe and process for review of the length of time a prisoner spends in an SIU must be streamlined to ensure reviews are both timely and meaningful. Pending the 5-year legislative review, interim policy and direction must be provided so that if a SIU stay beyond 15 days is confirmed, the case is automatically referred for IEDM review and a decision issued 15 days after the referral.

CSC Response:

Regarding any changes to current legislation, CSC commits to working with Public Safety Canada, who is responsible for Independent External Decision Makers, to explore the feasibility of this recommendation.

3.1: The CSC Internal Audit Committee should consider an audit to determine reasons for prisoners not availing themselves of time out of cell offers and reasons why offers are not made or not properly documented.

CSC Response:

CSC’s Risk-Based Audit and Evaluation Plan for 2022-2027 includes a joint audit and evaluation engagement of the Structured Intervention Units. It will build upon the Structured Intervention Unit Audit Readiness that the Internal Audit and Evaluation Sector completed in 2022.

The preliminary objectives of this joint audit will be to ensure that a management framework is in place to support the SIUs and to assess compliance with relevant legislation, policy and procedures. The evaluation portion of the engagement will examine the SIU model’s effectiveness and efficiency. It will also examine other aspects such as whether SIUs are meeting the needs of inmates with mental health issues and the reasons for which inmates are not availing themselves of time out of cell offers.

3.2: To help address regional variation, CSC must immediately share proven best practices for offers and activities that result in achieving legislated time out of cell targets. Once best practices are shared, each SIU institution must prepare an action plan to implement these practices.

CSC Response:

CSC can confirm that best practices are gathered and shared nationally on an ongoing basis. As a next step, CSC commits to having each SIU institution prepare an action plan to implement best or promising practices, based on the inmate populations they serve.

With the implementation of the SIU’s revised staffing model, CSC will have increased access to supplementary information at the site level, through the data analyst/activity coordinator position. This position will also be responsible to create a site-specific schedule of daily activities for inmates in an SIU, which aims to increase their time out of cell and interaction with others.

In addition, CSC will hold quarterly national SIU meetings with Institutional Heads and Regional/National representation. These meetings will serve as a mechanism for sharing best practices, trends, population management, and discussing issues and challenges.

3.3 Develop and implement mechanisms, including computer-based learning options, to allow SIU prisoners access to a broad range of education and training opportunities.

CSC Response:

Education and vocational training is available to the SIU inmates as a dedicated teacher is assigned to each SIU.

Partnerships and supports exist for inmates to pursue their goals and continue to make progress against their correctional plans. For example, one type of best practice is a program that has been implemented at the Millhaven Institution SIU called Health for Life. This initiative and the rapport built with the teacher has assisted ten inmates in completing their high school diploma.

Aligning with the Government of Canada’s data strategy framework, CSC recognizes that its future state needs to include increased digital options to support both staff and inmates. We have established a vision to move towards digital service delivery. Overtime, this will require significant financial, time, equipment, and infrastructure investments.

In the meantime, CSC is actively pursuing options to increase its delivery of digital programming and educational opportunities for inmates.

In November 2020, CSC implemented its first Digital Education Project pilot, which is now available at three institutions. The pilot project provides access to provincial curricula in a computer-assisted learning environment, and offers opportunities for inmates to gain foundational computer skills needed to increase their literacy levels.

As this project expands to more institutions over time, the goal will be to ensure that inmates engaged in digital education maintain uninterrupted access to their education, even if transferred to an SIU.

4.1: There is an immediate need for CSC to provide guidance to staff through a Commissioner’s Directive Policy Bulletin regarding what constitutes meaningful human contact and how to best meet the obligations imposed in law and policy.

CSC Response:

CSC provides guidance to staff on what constitutes meaningful human contact in Commissioner’s Directive (CD) 711 and other guidance documents. Meaningful human contact is defined as “the opportunity for human interaction with others that is conducive to building rapport, social networks, or strengthening bonds with family or other supports.”

CSC will develop a communications approach to provide examples on ways to participate in meaningful human contact, and how inmates can take part in different activities provided by community organizations.

In addition, meaningful human contact is an area of focus in the joint audit and evaluation of the SIUs.

4.2: The Senior Deputy Commissioner is to ensure meaningful human contact activities are carefully documented and shared between SIU sites.

CSC Response:

CSC staff record the types of activities offered to inmates in the SIU, including the opportunities for meaningful human contact, using the Long Term Evolution (LTE)-SIU application.

Using new and improved operational reports, the Senior Deputy Commissioner will provide enhanced national oversight of the SIUs and follow up with Regional Deputy Commissioners on regional trends and variations to implement any actions required.

4.3: Each SIU site should convene an open house inviting community partners and service providers to explore opportunities that would improve the frequency and quality of time out of cell for meaningful human contact.

CSC Response:

CSC will develop a plan to create and communicate additional opportunities for partners and community organizations to engage in SIUs. We agree with the “open house” concept, but will need to structure the visits accordingly given the various security requirements.

Discussions with community partners are ongoing and many are already involved with mainstream populations and SIUs. CSC also engages its volunteer base in creating meaningful opportunities to connect with inmates in SIUs.

Some examples of partnerships that we will build upon in the SIUs across the country include implementing more Volunteer Mentor Programs as well as partnering with colleges, where students provide educational programs to SIU inmates as part of their college program, and inmates receive micro-credits from the college.

5.1: Policy must require a review at the regional level of every instance when a prisoner transferred out of an SIU is transferred into a different SIU within 5 days.

CSC Response:

CSC commits to putting in place a mechanism to monitor, report and review any cases of inmates authorized to transfer to an SIU within five days of their transfer out of an SIU. This case-by-case review will ensure that all such cases are tracked and identified. This will help to shed light on root causes, and any gaps and opportunities. This analysis will also help determine if any changes to policy are required.

The addition of the Behavioural Counsellor positions in each SIU site will provide inmates with enhanced support to assist in their safe and effective reintegration into the mainstream population. This will lead to a more robust “prise en charge” of inmates and their successful reintegration.

5.2: All inter-regional transfers from or to an SIU must be approved by the Senior Deputy Commissioner.

CSC Response:

All inter-regional transfers are authorized by the Assistant Deputy Commissioner of Correctional Operations in each Region. This position is best suited to fulfill this role as they have direct sightline on operations at the grassroots level. As noted in 5.1, CSC commits to putting in place a mechanism to monitor, report, and review any of these cases.

6.1: In consultation with the SIU sites, policy and procedures are to be developed that will appropriately ease the health care documentation burden by reducing duplication.

CSC Response:

CSC appreciates the significant amount of time required to ensure comprehensive documentation in each inmate’s electronic health care record. Comprehensive and timely documentation is fundamental to ensuring continuity of care for patients. In addition to documenting information in the patient’s electronic health record, health professionals must also document certain information that is relevant to correctional decision making in the Offender Management System.

This form of dual documentation is designed to protect the patient’s privacy rights as only health care staff can access the electronic health care record.

CSC is committed to ensuring documentation is as streamlined as possible and will undertake a review in collaboration with Health Professional Practice Leaders and frontline health staff working in the SIU. The review will be completed by December 2023.

6.2: When implementing the enhanced staffing model for SIUs, CSC should reconsider its policy on the allocation of health human resources and dedicate clinical staff to the units.

CSC Response:

The same legislation that created the framework for SIUs also had, as a second area of focus, numerous legislative amendments and new funding to transform health care in federal corrections. The initiatives associated with transforming health care in federal corrections have only just begun and over 400 new positions will be added to health care in CSC by March 2025.

For inmates transferred to the SIU, who are already receiving health services, keeping the same providers ensures better continuity of care for these patients and does not interrupt their treatment plan. That said, as new positions are in place over the next two years, CSC will explore how it assigns work in the SIU with a particular focus on nursing duties.

This work will include consultation with frontline health and operational staff/managers and labour partners. We will also consult with inmates in SIUs so we can better understand their health care needs. Consultations will begin in the spring of 2023 and continue through the fall of 2023.

6.3: Information exchange between IEDMs, healthcare, and frontline program and security staff must be reviewed to identify opportunities for increased transparency and sharing.

CSC Response:

CSC commits to working with Public Safety Canada to identify additional opportunities for collaboration and information sharing with Independent External Decision Makers and CSC staff.

CSC understands the importance of interdisciplinary work and close collaboration from all professions in order to support the best possible outcome for all inmates. As such, current policy emphasizes the importance of regular interdisciplinary team meetings both in the SIU and throughout an inmate’s entire sentence.

By summer 2023, recommendations made by registered health care professionals to alter the conditions of confinement or remove an inmate from an SIU will be included in the LTE-SIU application. These recommendations, consistent with professionally accepted standards and legislation, are currently documented in the Electronic Medical Record (EMR). This new change will promote more timely and effective information sharing among all relevant parties.

In addition, CSC has begun a comprehensive review of its Health Information Sharing Guidelines. The goal of this review is to ensure the timely and appropriate sharing of health information, authorized by law, between all relevant groups of staff. CSC anticipates to finalize the revised Health Information Sharing Guidelines by winter 2024.

In the interim, CSC will issue a reminder outlining the current information sharing requirements in order to reinforce the importance of timely information sharing, authorized by law and policy, in the SIU.

7.1: A National Elder position must be re-established, and CSC should immediately consult with the Regional Elders Councils and the National Elder to resolve long-standing concerns regarding terms and conditions of appointment and work, the contracting process, training, retention, and succession planning.

CSC Response:

Recognizing the diversity of perspectives and the need for First Nations, Metis and Inuit representation, CSC has implemented a National Elders Working Group (NEWG) as the national advisory body on Elder Services. The SIU team engaged the NEWG as recently as October 12, 2022 on issues related to the SIUs.

In addition, with the completion of CSC’s recent Audit on the Management of Elder Services, a Management Action Plan has been developed and work is underway to address the issues of recruitment as well as the overall model supporting Elder interventions, including training, retention and succession planning.

CSC will be conducting a review of the current Elder contracting model and exploring alternative options to ensure that the approach is effective and efficient, as well as culturally appropriate.

7.2: All Elder and Indigenous Liaison Officers positions must immediately be staffed.

CSC Response:

Given the overrepresentation of Indigenous inmates in SIUs, it is essential that Elder and Indigenous Liaison Officer positions be fully staffed to support inmates. As such, CSC will prioritize the staffing of Elder and Indigenous Liaison Officer resources, where vacancies exist.

In 2023, as committed in the Management Action Plan, CSC will conduct a review of the model used to contract Elders with the goal of achieving the most efficient and effective contracting methods.

7.3: An Indigenous Human Resources strategic plan should be developed this fiscal year with input from the National and Regional Elders and the National Aboriginal Advisory Committee.

CSC Response:

A Tiger Team on Indigenous Recruitment and Retention developed an action plan, that was presented to the National Indigenous Advisory Committee in the Summer 2022.

CSC is also working with the National Elder Working Group to develop strategies for recruitment, as well as SIU onboarding initiatives.

CSC is also implementing innovative and multi-pronged approaches, including promotional and advertising campaigns, to attract and recruit Indigenous employees.

7.4: Minimum expectations for on-boarding, supporting, and meaningfully involving Elders working in SIUs immediately be promulgated and a governance and accountability structure put in place to ensure compliance.

CSC Response:

As previously noted, Elders need to be properly onboarded and meaningfully integrated into the SIU team. To this end, the national SIU team met with the National Elders Working Group in mid-October 2022 to seek advice and guidance with regard to Elder interventions in SIUs and develop an action plan. This will ensure that Elders and their interventions are better integrated into the overall SIU operations.

7.5: A formal agreement guaranteeing Elder access to prisoners, appropriate meeting, program and spiritual space, and required information sharing be developed in each CSC institution.

CSC Response:

CSC recognizes the vital role Elders play in an inmate’s correctional journey and agrees that they should have timely access to inmates as well as the appropriate spaces to conduct ceremonies and complete interventions.

CSC will work closely with both of its advisory groups, the National Indigenous Advisory Committee and the National Elders Working Group to identify the best mechanism to ensure this occurs operationally.

8.1: Whenever possible, programs and meaningful activities are to be offered to SIU prisoners in association with others.

CSC Response:

The SIU model is about helping inmates and providing them with the continued opportunity to engage in interventions and programs to support their safe return to a suitable mainstream population. It is always our goal to have programs, interventions and activities take place together with others. CSC will continue to leverage opportunities to involve volunteers, partners, and outside organizations in activities.

8.2: An audit of the impact of Interim Policy Bulletin 690 (CD711) on progress against the correctional plans of SIU prisoners must be conducted to determine if the direction given to clarify the management and delivery of programs, interventions, and services within a Structured Intervention Unit, and to provide flexibility when determining referrals to programs and interventions, has provided positive results.

CSC Response:

As indicated in 3.1, the joint audit and evaluation engagement will review compliance with relevant legislation, policy and procedures as well as examine the SIU model’s efficiency and effectiveness. Therefore, the SIU audit and evaluation will include a review of the impact of Interim Policy Bulletin 690 (Commissioner’s Directive 711), and whether it has yielded positive results.

8.3: A strategy to enhance involvement of community partnerships in the provision of programs, services and other supports for SIU prisoners must be developed and implemented.

CSC Response:

CSC will develop a strategy to enhance the involvement of community partners, more specifically in the provision of programs, services, interventions and supports.

In addition, opportunities for these types of partnerships across CSC institutions will be explored during quarterly SIU meetings. These meetings, chaired by NHQ SIU Directorates, will have representation of Institutional Heads and regional/national headquarters and will serve as a mechanism for communicating partnerships, other best practices, and SIU related communications.

9.5: CSC must advise the decision-making IEDM of the disposition of a direction to remove a prisoner from an SIU within 5 days of receiving the decision, including a transfer plan or an explanation of why the transfer will be delayed or not actioned.

CSC Response:

CSC and Public Safety are in the process of consulting with the Independent External Decision Makers on the information sharing process to ensure it meets their needs, including the outcome of their decision.

10.1: An immediate deficiencies survey of all SIU sites be conducted. Information collected through the survey should be used to develop capital plans and budget requests for the next fiscal cycle.

CSC Response:

From the inception of the SIUs, there has been a comprehensive tracking system for all SIU infrastructure related projects. Each month a progress report, by site and region, is reviewed by senior management in operations and corporate services. The majority of the projects at all SIU sites are completed. Some work remains outstanding at a few sites, which will be completed this fiscal year and in early 2023-24.

CSC also reviews infrastructure requirements on an ongoing basis. If changes or enhancements are required, project design, costing and capital plans are developed and included in CSC’s Capital Plan for implementation on a priority basis. Funding is available for this purpose.

10.2: Funds be made available this fiscal year to ensure adequate common area furnishing, exercise equipment, working televisions, and amenities to support meaningful human contact are in place in each SIU.

CSC Response:

CSC has prioritized the provision of requirements for each SIU, including additional furnishings, exercise equipment, televisions or amenities as appropriate and has identified funds for this purpose.

The review of the SIU accommodation guidance (recommendation 10.1) may result in different or new types of furnishings being recommended and CSC will incorporate this information into its overall SIU design plans, as appropriate.

10.3: A National Standard for secure interview and meeting spaces must be developed and all SIU sites must be immediately provided resources to ensure compliance.

CSC Response:

CSC will develop a National Standard for secure interview and meeting spaces, and funding will be made available to ensure the standards are met. Stakeholders, including the Implementation Advisory Panel, will be consulted as part of this process.

Currently all SIU sites include program, meeting and interview rooms. This was part of the design for the initial SIU implementation plan.

10.4: An IT and digital readiness and capacity audit of all SIU sites should be completed this fiscal year and a plan developed to eliminate all identified gaps and shortcomings.

CSC Response:

As part of CSC’s ongoing assessment of the digital readiness of SIUs, the following work was conducted to eliminate gaps and shortcomings:

CSC’s Information Management Services continues to support the SIU digital infrastructure, with regular identification of business requirements and regular LTE-SIU application releases to identify needs and ensure continuous improvements expected over the next fiscal year (2023/24).

11.1: A strategic SIU Human Resource Plan must be developed based on diversity, equity, and inclusion targets as well as SIU operational experience that will address high turnover, absenteeism, reliance on underfilling and use of acting positions, and recruitment of targeted occupational groups.

CSC Response:

An SIU readiness operational audit was completed in January 2022, and made a similar observation, which CSC committed to implementing.

By March 31, 2023, CSC will develop a Human Resources Strategy to recruit and retain staff in SIUs. This plan will take into consideration diversity, equity and inclusion objectives. It will also assist SIU management in addressing, where necessary, gaps in training, high turnover, absenteeism, and will serve to stabilize acting assignments.

11.2: Specific targets and key performance measures be developed this fiscal year to determine if the soon-to-be-implemented enhanced SIU staffing model is addressing priority needs.

CSC Response:

CSC has recently updated its national resourcing model for SIUs. This revised model includes the addition of data analyst/activity coordinators, behavioural counsellors for men’s institutions, security intelligence analyst, additional administrative support and enhancement to the management and program teams. These resources will supplement the current interdisciplinary team, providing program, health, correctional planning support and contribute to the successful reintegration of SIU inmates to a mainstream population.

CSC will also develop specific targets, key performance measures, and SMART indicators to ensure the positions added to the SIU structure are yielding the anticipated results.

12.1: Training focused on understanding the history of segregation in federal corrections and the reasons for the creation of SIUs be developed and delivered to all CSC staff and should be frequently updated to reflect court decisions, legislative amendments, and reviews and evaluations related to the operation of the SIUs.

CSC Response:

As part of the SIU implementation, a variety of communications products were developed and shared broadly throughout CSC, and externally, and managers briefed their staff on the new model, its goals, and its impact on their respective roles and responsibilities.

CSC also provided initial onboarding orientation workshops to all staff working in the SIU, where the history of the previous model and the rationale for the creation of SIUs were discussed.

The Correctional Training Program that is currently offered to new Correctional Officer recruits reviews the underlying principles and concepts that led to the creation of SIUs, including legislation and policy as well as court and other cases that have led to recommendations to reform segregation.

In addition, CSC is exploring the implementation of a National Onboarding Program for new recruits in its institutions with structured mentoring, coaching, and training to support the application of the skills and knowledge to the realities of working in a correctional environment.

12.2: All staff assigned to work within SIUs must complete annual Human Rights and anti-discrimination training.

CSC Response:

Over the next three years (2022-2025), a new mandatory training called ‘’Working in an Environment Free of Bias and Racism’’ will be provided to all staff.

The training program will include a 1.5-day session on “Unconscious Bias”, which aims to strengthen awareness, encourage self-reflection and create a safe space to discuss bias and systemic barriers in the workplace, and “Uniting against Racism”, which examines race and racism and addresses employees’ knowledge and gaps with regards to the history of racism in Canada. It also explores concepts such as individual and systemic racism, dehumanization and discrimination. “Uniting against Racism” is composed of an online and virtual session. The online component will commence in December 2022, and the virtual component will commence in February 2023. In addition, all Managers will be required to complete the Manager’s Toolkit for Action, which contains resources and information to lead conversations on systemic racism and racial discrimination with employees

Finally, CSC is assessing the necessity of developing training standards specific to SIU staff. A review of the training needs will be completed by November 2023 and will guide improvements to be made to the training program for SIU staff and help to sustain organizational support for the SIUs.

12.3: Mental Health awareness and intervention initial and refresher training (including de-escalation) be required for all staff assigned to work within SIUs.

CSC Response:

CSC currently offers training pertaining to mental health awareness of inmates (i.e. Fundamental of Mental Health Training; Suicide and Self-Injury Initial Training and Suicide and Self-Injury Intervention Continuous Development Training).

The Fundamental of Mental Health Training focuses on increasing awareness of mental health needs in the inmate population; promotes a collaborative, interdisciplinary approach within the correctional environment; and, enhances skills and strategies of effectively interacting with and supporting inmates with mental health needs. All front line staff receive relevant training to identify and effectively manage the mental health needs of inmates.

Correctional Officers are trained to utilize de-escalation techniques and involve healthcare and mental health intervention in accordance with the Engagement and Intervention Model (EIM).

As part of the enhanced model, CSC is developing targeted training for all staff working in the SIUs to provide them with additional tools in supporting inmates to adopt more positive behaviours.

13.1: The next risk identification and assessment that is undertaken to determine internal audit priorities must reflect the operational challenges faced by SIUs.

CSC Response:

SIUs have been identified as an audit priority through CSC’s annual risk-based audit planning process. An engagement on SIUs was first identified in the 2019-2022 Risk-Based Audit Plan, and work on this engagement was completed in 2020. Additionally, the 2022-2027 Risk-Based Audit and Evaluation Plan identified a joint audit/evaluation engagement that is scheduled to commence in Fall 2022.

Going forward, the operational challenges of SIUs will continue to be considered as we update the Risk-Based Audit and Evaluation Plan.

13.2: To support accountability and transparency, CSC must prepare a consistent and meaningful set of key performance indicators for SIUs and published on a quarterly basis.

CSC Response:

CSC has developed a performance measurement framework for SIUs and, as previously committed, is reviewing its suite of SIU key performance indicators and reporting strategy in light of the knowledge acquired in the first years of the SIU implementation.

CSC will report back to Treasury Board in the Spring of 2023, as required, and implement changes to its reporting for the 2023-24 fiscal year.

Results against our key performance indicators will be published in CSC’s Annual Departmental Results Report and will also be available on a quarterly basis.

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