Internal Audit of the Administration of Grants & Contributions

Internal Audit & Accountability Branch
February 2016

Table of Contents

• Executive Summary
  • Why This Is Important
  • Key Findings
  • Audit Conclusion
  • Statement of Conformance
• 1.0 Background
  • Audit Objective and Criteria
  • Audit Scope and Approach
• 2.0 Findings and Recommendations
• Audit Conclusion
• Appendix A – Grants & Contribution Programs at CIC in 2013-14
• Appendix B – Management Action Plan
• Appendix C – Applicable Government of Canada Legislation, Policies & Directives

Executive Summary

An internal audit of the Administration of Grants and Contributions was included in the Citizenship & Immigration Canada (CIC) 2013-14 Risk-Based Audit Plan, as approved by the Deputy Minister, upon recommendation by the Departmental Audit Committee.

The objective of the audit was to provide assurance on CIC’s compliance with the Treasury Board Policy on Transfer Payments and other pertinent Departmental policies and related instruments. The audit also assessed recipient management practices in place to support efficient program delivery.

Why This Is Important

Transfer payments are key instruments for the Government of Canada to further its broad policy objectives and represent a major commitment of federal resources. The Government is committed to ensuring that transfer payments, which include grants, contributions, transfer payments made to other orders of government and international organizations, are managed in a manner that respects sound stewardship and the highest level of integrity, transparency, and accountability.

Key Findings

The Department has standardized program application processes for its major grant and contribution programs, however, established intake and assessment procedures were not always adhered to and funding decisions frequently lacked sufficient documentation to support the decision. To strengthen application processes, internal procedures and guidelines require updates and support through communications and/or appropriate training.

While a risk-based monitoring strategy has been developed for contribution agreements, which standardizes risk assessments and provides a clear framework for agreement monitoring activities, it is not always adhered to by program staff. A risk-based monitoring strategy has not been developed for CIC’s grants and contributions to individuals.

The department was not fully compliant with the requirements of the Financial Administration Act (FAA), as well as, related CIC and government-wide financial policies.

Audit Conclusion

Overall, the Department is generally compliant with the Treasury Board Policy on Transfer Payments. CIC has made significant progress towards modernization and standardization of its transfer payment programs. However, the Department should improve its compliance to the FAA and departmental financial policies. Further work is also needed to document and standardize decision-making related to application assessments and to strengthen recipient monitoring activities.

Statement of Conformance

The conduct of this engagement conforms with the Internal Auditing Standards for the Government of Canada, as supported by the results of the Quality Assurance and Improvement Review program.

The audit findings and conclusion are based on a comparison of the conditions that existed at the time of the audit against established criteria agreed upon with CIC management prior to the commencement of the audit.

1.0 Background

The 2012 Treasury Board Policy on Transfer Payments requires that transfer payments, payments which do not result in the acquisition of goods, services or assets by the Department, are managed in a manner that is sensitive to risk, strikes an appropriate balance between control and flexibility and establishes the right combination of good management practices, streamlined administration and clear requirements for performance. Deputy heads are responsible for monitoring compliance with the Policy on Transfer Payments, and its supporting directives, through periodic audits and other assessments to ensure their effective implementation and to take corrective action when needed.

In 2013-14, Citizenship & Immigration Canada (CIC) spent $956 million on its grant and contribution programs. Through nine programs, CIC aims to integrate newcomers and manage migration. Two of the programs – Settlement and Resettlement – represent 98 percent of CIC transfer payments (excluding the Canada-Quebec Accord). The Resettlement program is comprised of two sub-programs, with funding to non-governmental organizations (Resettlement-NGO) and government assisted refugees (RAP Income Support, or RAP-IS). A third program, Multiculturalism^{Footnote 1}, represents one percent of transfer payments. (See Appendix A for 2013-14 program objectives and descriptions for all grants and contribution programs.)

Functional authorities for the strategic development and implementation for these three programs are the Integration and Program Management Branch (IPMB) and Financial Operations Branch, while the regional offices, which are organized into four larger regions, Ontario, Western, Eastern and National Capital Region (NCR), are responsible for program administration.

At National Headquarters (NHQ), the International and Intergovernmental Relations (IIR) Branch, Citizenship-Multiculturalism Branch and IPMB are responsible for the administration of five smaller transfer payment programs: International Organization for Migration – Membership (IOM), Institute for Canadian Citizenship (ICC), Migration Policy Development Program (MPDP), Global Assistance of Irregular Migrants (GAIM) and the International Holocaust Remembrance Alliance Membership (IHRA)^{Footnote 2}. Each of these programs have their own Treasury Board approved terms and conditions, with total actual funding of $10.8M or 1.7 percent.

Grants and contributions administration at CIC has been undergoing significant changes:

• Over the last ten years, funding administered by CIC has increased from $261M in 2005-06 to current funding levels of almost $1B.
• The Grants & Contributions Modernization Initiative was launched in December 2011, in response to the Government of Canada action plan on grants and contributions reform.
• In 2012, as part of the deficit reduction action plan, new roles for IPMB and Finance were created to provide centralized functional guidance. This has led to national guidance now being in place for most key areas of Gs & Cs management including negotiating guidelines and financial monitoring.
• The iCARE system was launched in 2013. For the first time, CIC has a consistent way to collect data from service provider organizations (SPO) across the country to report on settlement and resettlement program clients, services and outcomes. iCARE is a performance measurement system that supports monitoring and evaluation processes. It allows program staff to track a SPO’s progress in meeting service targets under the contribution agreement.
• The first components of the Grants & Contributions System (GCS) were launched in 2015, to replace paper processes and incomplete legacy systems, and it is scheduled for completion in 2017.

In 2014, an Internal Audit of the Management Control Framework over Grants and Contributions was conducted. The audit concluded that progress has been made with the management control framework over grants and contributions and that an opportunity exists for the Department to further strengthen its compliance to the Policy on Transfer Payments. The Department is implementing an action plan to address the audit recommendations and recognizes that there is further work to be done.

Audit Objective and Criteria

The objective of the audit was to provide assurance on CIC’s compliance with the Treasury Board Policy on Transfer Payments and other pertinent departmental policies and related instruments. The audit also assessed recipient management practices in place to support efficient program delivery.

The criteria used were:

• CIC’s grants and contributions programs are administered with due diligence and transparency.
• CIC monitors recipients in a manner that is effective, efficient and informed by risks and performance results.
• CIC has effective controls in place to support compliance in the administration of the Policy on Transfer Payments and pertinent CIC policies.

Audit Scope and Approach

The audit covered fiscal year 2013-14. The scope included all active grant and contribution programs, with the exception of the Canada-Quebec Accord grant, as well as, all CIC regions that administered grants and contributions (Ontario, Western, Eastern and NCR).

The audit was conducted in accordance with the Standards for the Professional Practice of Internal Auditing. The examination phase was conducted from September 2014 – March 2015, and the following audit methodologies used:

• Conducted over 50 interviews with functional authorities and operational staff, in all regions.
• Reviewed documentation such as financial policies, training material, records of decisions and financial reports.
• Analytical reviews of Departmental documents and trend analysis of financial reports.
• Process walkthroughs and flowcharting.
• Collaboration with the CIC Internal Financial Control Team (ICFR) in the testing of internal financial control processes.
• A total sample size of 335 files comprised of 73 grants and 262 contributions.

Files were selected using a judgmental sampling approach representing files from all programs and regions.

2.0 Findings and Recommendations

2.1 Program Promotion and Funding Decisions

The Policy on Transfer Payments requires that transfer payments are managed in a manner which is fair, transparent, and accessible to all potential applicants. The audit expected potential recipients to have ready access to information about CIC transfer payment programs and that a description of each program would be made public, including application and eligibility requirements and the criteria used for assessment.

Further standardization is needed for application processes

Calls for proposals are used for most funding opportunities. Within the last four years, CIC has used the website to promote two large scale Calls for Proposals (CFP) for the Settlement and Resettlement programs. A CFP is a solicited call for organizations to submit applications, by a given deadline. For the Multiculturalism program, funding is available through three streams, events (grants), projects (contributions) and strategic initiatives (grants or contributions), with information and applications available on the CIC website. In 2013-14, the majority of Multiculturalism applications received were for events, which involves a continuous intake and assessment of applications.

On occasion, CIC also accepts unsolicited proposals submitted by organizations. These proposals are submitted for various reasons such as an organization missing a CFP deadline or as a result of discussions with CIC about a specific initiative. Unsolicited proposals provide flexibility to address new and emerging initiatives and accounted for roughly $19 million in 2013-14. Unsolicited proposals are submitted directly to program delivery areas, through the Minister’s Office or departmental policy colleagues. During the 2013-14 fiscal year, CIC did not have a standardized process to ensure that departmental staff treated all unsolicited proposals in the same manner. The absence of a standard process does not allow for full transparency and consistency and risks the perception of inequitable treatment amongst potential applicants.

Recommendation 1 – Medium Risk

The Department should ensure that intake procedures and processes are established and adhered to for all applications, including unsolicited proposals.

Funding decisions were not always supported by documentary evidence

Once submitted, applications go through a series of tiered assessments before funding decisions are made. Program officers review applications and provide senior managers with funding recommendations. As part of the assessment process, risk factors such as the financial viability of the organization, alignment with program outcomes/objectives, adequacy of proposed budget and funding history with CIC are used as criteria. The tiered review process supports a fair and transparent assessment of applications. In some instances, however, there were insufficient documented justifications on file to support funding recommendations and decisions. This was more concerning when the final funding decision was inconsistent with the initial program officer recommendation.

As the 2012 CFP was the first CIC national call process, it is reasonable to expect that intake and assessment controls will mature over time. Nonetheless, sufficient and appropriate documentation is required to support fair and transparent decision-making.

Recommendation 2 – Medium Risk

The Department should ensure that all funding recommendations and decisions are supported by sufficient and appropriate documentation.

2.2 Recipient Monitoring

Once a funding decision is made, CIC will enter into an agreement with the recipient. Recipients may be subject to monitoring of a financial (financial monitors) and non-financial (activity monitors) nature to ensure that the obligations and performance objectives of the funding agreement are met.

The Directive on Transfer Payments states that all recipient monitoring activities should be informed by risk. Therefore, the audit expected that monitoring of recipient agreements would reflect an assessment of the risks specific to the program, the value of the funding in relation to administrative costs, and the risk profile of the recipients.

Recipient monitoring was not always aligned with a risk-based monitoring approach

Functional authorities within CIC have developed a risk-based monitoring framework, the Funding Risk Assessment Model (FRAM), to enable risk assessments of contribution agreements. The FRAM is a tool to assist staff in identifying risk elements associated with contribution agreements and provides guidance on risk mitigation measures, such as the number of monitoring activities to be performed by program officers. Most of the files reviewed had activity and financial monitors performed that did not follow the guidance resulting from the FRAM risk assessment.

Although the FRAM serves as a tool to be used in conjunction with the program officer’s judgment of the file, a rationale for deviating from the FRAM guidance was not documented and the risk elements considered by the program officer were not captured. As a result, necessary information to assess if adjustments are needed to the FRAM or if other corrective action is required to ensure that the FRAM is implemented as intended is not maintained.

In addition, monitoring guidance for the RAP-IS suggests that 10 percent of the caseload be monitored. However, there was only one instance of monitoring identified in the 88 RAP-IS files reviewed. Also, the monitoring guidance is not risk-based and there is no established process to collect the monitoring results and take corrective actions as required.

In accordance with the Policy on Transfer Payments there is no requirement to monitor grants. For the Multiculturalism program, discussions with the program functional authority indicated that, given the low materiality and risk inherent in the majority of multicultural grants (i.e. events) funded by CIC, there is no requirement to monitor these events. The review of multiculturalism event files indicated that roughly 25 percent had a monitoring exercise performed. Monitoring decisions are based on the judgment of the program officer with approval from their supervisor. The rationale and/or approval for the monitoring activity were often not documented and there was an inconsistent approach undertaken across regional offices.

Furthermore, CIC does not conduct periodic quality reviews of its grants and contributions monitoring activities to ensure that they are in line with guidance and are being performed as expected. A periodic review of the risk-based monitoring strategy would allow the program to make any necessary adjustments to the risk approach.

Recommendation 3 – Medium Risk

The Department should assess the current recipient monitoring strategy for all grants and contribution programs, which should include a review mechanism to ensure the effectiveness of monitoring activities.

2.3 Financial Management Controls

2.3.1 Program Forecasting

Financial management is an important part of delivering grant and contribution programs and exercising stewardship over resources. Core activities include: planning and budgeting of initial allocations of the overall budget; reporting and forecasting; control and oversight; and decision support and advice. Financial forecasting is an on-going process whereby planned spending and resource allocations are adjusted if needed.

The audit expected that there would have a process in place to support appropriate resource allocations and that program forecasts would be monitored on a regular basis to ensure funds are managed as planned.

Departmental forecasting processes did not adequately support appropriate resource allocations in 2013-14

The Department has a standardized and controlled process for forecasting grant and contribution expenditures. However, forecasts for contribution expenditures were consistently overstated during the 2013-14 fiscal- year. Interim departmental reports showed surpluses which averaged only $15.6M for the year, but the actual or year-end surplus was $30M; making 2013-14 the fourth consecutive year of overall program surpluses. The review of contribution files identified deficiencies related to the performance of financial management activities such as financial monitoring, critical reviews of cash-flow statements, accurate coding of claim categories, and when to modify existing funding commitments. This led to unreliable forecasting information which lessened the opportunity to make timely adjustments and for appropriate reallocation of program funds.

Recommendation 4 – Medium Risk

The Department should strengthen forecasting procedures to ensure the collection of accurate financial information.

2.3.2 Effectiveness of Financial Controls

Internal financial controls are important for ensuring the sound stewardship of public resources. Requirements for the financial management of transfer payments are defined in the Financial Administration Act (FAA) and related CIC financial policies. The audit expected that payments to recipients would be compliant to these legal and policy requirements.

Expenditure approval procedures were not always followed

Expenditure Initiation is the first step in the approval process and represents approval of the proposal, prior to negotiation of an agreement with the recipient or a major amendment to an agreement. This should be followed by the FAA S.32 certification which confirms that there are sufficient funds available to enter an agreement. Next, the transaction authority is exercised when the department official signs the agreement after the recipient has signed. Collectively, these three steps represent Spending Authority.

Files assessed for Spending Authority compliance for all programs, excluding RAP-IS, were compliant in 58 percent (143 of 247) of files reviewed. Examples of compliance errors included no record of expenditure initiation, agreements signed before expenditure initiation was approved, delegated authorities for FAA S.32 not in place, and funding agreements signed prior to S.32 certification being performed.

For the RAP-IS program, Spending Authority compliance was observed in 38 percent (33 of 88) of files assessed. Examples of compliance errors included: insufficient documentation to support the calculation of payments; inaccurate commitment amounts recorded in the financial system resulting in adjustments ranging from 6 to 50 percent; and, no evidence of certification under FAA S.32. Limited standardization of financial administration procedures and tools was a key factor and led to inconsistency in exercising financial responsibilities. These findings are similar to those identified in the 2010 Internal Audit of the Administration of the Resettlement Assistance Program.

Payment approvals did not always occur with the appropriate performance certification

Certification Authority (FAA S.34) is approval of the payment request after ensuring the claim or advance request is accurate and in accordance with the terms and conditions of the agreement.

For all programs, excluding RAP-IS, compliance with S.34 procedures was observed in 76 percent of files assessed. Examples of compliance errors included payments certified in the absence of required supporting documentation and no segregation of duties between the individual who performed the transaction authority and S.34 payments certification. In addition, 56 percent of files assessed, lacked sufficient supporting detail for the audit team to conclude whether expenses claimed by recipients were eligible.

In the case of RAP-IS, S.34 compliance was observed in 21% of the files as either documentation was lacking to support S.34 certification or the audit team was unable to assess original payment request forms certifying FAA S.34 and S.33, as the files could not be located by operational staff.

Holdbacks and funded capital assets are not managed as per CIC policy requirements

One method of ensuring that agreement obligations are fulfilled by recipients is for program officers to use a holdback whereby a portion of the total funding stipulated in the contribution agreement is withheld. The file review identified that holdback were not performed in accordance with CIC procedures. Examples include holdback documentation not on file, inaccurate holdback calculations or the memo approving the release of the holdback was either missing or was signed after the release of the final payment.

Program officers are also required to establish the method for disposition of capital assets funded by the Department. In CIC’s standard contribution agreement template, a number of disposition options are identified and the final disposition of assets is to be determined at the conclusion of the agreement. The audit reviewed 38 closed files with CIC funded capital assets. None of these files documented the method used for the disposition of project capital assets.

While internal financial controls have been established, they have not been adequately implemented to support full compliance to spending and payment approval procedures. Factors that contributed to this include program officers and managers not taking all mandatory training, for example, participation in financial management courses such as Managing Payments was low. Also, there is no refresher training and manuals for the Settlement, Resettlement and Multiculturalism programs are outdated.

Recommendation 5 – High Risk

The Department should:

1. Assess the financial administration of transfer payments in regions to ensure policy and process requirements are fully understood, through sufficient training, guidance and monitoring for financial policy compliance.
2. Implement a formal process and procedures that addresses the unique requirements of the RAP-IS payment cycle.

Audit Conclusion

Overall, the Department is generally compliant with the Treasury Board Policy on Transfer Payments. CIC has made significant progress towards modernization and standardization of its transfer payment programs. However, the Department needs to improve to ensure full and consistent compliance to the FAA and departmental financial policies in the administration of its grant and contribution programs. Further work is also needed to document and standardize decision-making related to application assessments and to strengthen recipient monitoring activities.

Appendix A – Grants & Contribution Programs at CIC in 2013-14

Program: Resettlement Assistance Program (RAP)
Expenditures ($000s): 51,163
Number of Recipients: 4,535
Number of Agreements: 4,593
Program Objective: To provide direct financial support and fund the provision of immediate and essential services to eligible recipients (e.g., government-assisted refugees (GARs) who lack the resources to provide for their basic needs and the needs of their dependants.

Program: Settlement Program
Expenditures ($000s): 572,212
Number of Recipients: 475
Number of Agreements: 686
Program Objective: To provide services that make a difference in the lives of newcomers. These services include: language training; information and referrals; assistance matching employment with newcomers’ skills and education; and help with establishing networks and contacts in their communities.

Program: Multiculturalism Program
Expenditures ($000s): 6,582
Number of Recipients: 190
Number of Agreements: 205
Program Objective: To promote equal opportunity for individuals of all origins. It works to foster intercultural understanding, citizenship, civic memory and pride, and respect for core democratic values grounded in our history.

Program: Migration Policy Development Program (MPDP)
Expenditures ($000s): 349
Number of Recipients: 4
Number of Agreements: 8
Program Objective: To provide funding to organizations active in international migration policy development and research; promote research and the exchange of information on migration issues; and support Canadian positions on managed migration and international protection.

Program: Canada-Québec Accord
Expenditures ($000s): 319,967
Number of Recipients: 1
Number of Agreements: 1
Program Objective: Quebec receives an annual grant from the federal government for providing reception and integration services to all immigrants in Quebec, including all refugees.

Program: Assessed Contribution to the International Organization for Migration (IOM) -Membership
Expenditures ($000s): 1,717
Number of Recipients: 1
Number of Agreements: 1
Program Objective: To provide for annual membership in the IOM, this allows Canada to participate in the governance and decision-making mechanisms of the IOM.

Program: Institute for Canadian Citizenship (ICC)
Expenditures ($000s): 1,059
Number of Recipients: 1
Number of Agreements: 1
Program Objective: The ICC is an independent charitable organization that was established to raise awareness of and to generate discussion about Canadian citizenship. It focuses on grassroots organizations, and encourages national dialogue on citizenship to help identify and build national networks with the aim of increasing social cohesion.

Program: Global Assistance to Irregular Migrants (GAIM)
Expenditures ($000s): 3,086
Number of Recipients: 1
Number of Agreements: 1
Program Objective: To provide funding to trusted international, intergovernmental and non-governmental organizations who provide activities and support to intercepted migrants such as basic needs, medical care and return and reintegration in the country of origin. The program also includes activities related to awareness and outreach in the context of consequence management.

Program: Assessed Contribution to the International Holocaust Remembrance Alliance (IHRA)
Expenditures ($000s): 45
Number of Recipients: 1
Number of Agreements: 1
Program Objective: Annual membership in the IHRA (ITF) supports the multiculturalism objective of actively engaging in discussions on multiculturalism and diversity at the international level.

Appendix B – Management Action Plan

Recommendation 1– Medium Risk

The Department should ensure that intake procedures and processes are established and adhered to for all applications, including unsolicited proposals.

Management response statement:

Management agrees with the recommendation.  Since 2013-14, the application process for both solicited and unsolicited proposals has been improved and standardized.  Guidance on unsolicited proposals was issued in 2014 and regional calls for proposals were consolidated into one national call.  These efforts have been supported by the implementation of the new Grants and Contribution System (GCS) for the National Call for Proposals in 2015.

Intake procedures and processes will be standardized and automated.  Also, funding guidelines will be revised and an oversight assessment committee will be established.

OPI: Associate ADM, Operations
Due Date: November 30, 2015

Recommendation 2 – Medium Risk

The Department should ensure that all funding recommendations and decisions are supported by sufficient and appropriate documentation.

Management response statement:

Management agrees with the recommendation. Management commissioned an independent review of processes, practices and tools after the 2012 Call For Proposal and is in the process of implementing new procedures to ensure funding recommendations and decisions are supported by sufficient and appropriate documentation.  With the implementation of the new GCS, the Department will be able to ensure all pertinent decision making documents are captured to support funding recommendations.

A review of the existing funding recommendation practices and tools will be undertaken in order to ensure that all funding recommendations are supported by sufficient and appropriate documentation.  Any identified gaps will be addressed in an action plan to improve the standardized processes in GCS.

OPI: Associate ADM, Operations
Due date: January 31, 2016

Recommendation 3 – Medium Risk

The Department should assess the current recipient monitoring strategy for all grants and contribution programs, including a review mechanism to ensure the effectiveness of monitoring activities.

Management response statement:

Management agrees with the recommendation. A formal risk-based monitoring approach was implemented in conjunction with the release of the Funding Risk Assessment Model (FRAM) in November 2012 for all contribution agreements to organizations. The design of the FRAM was reviewed and management implemented seven of the eight recommendations in November 2014. Since 2014-15, management has addressed the variation in monitoring and has demonstrated a 94-96 percent compliance with the FRAM.  Management will continue to monitor the FRAM and perform a quality assurance (QA) exercise to assess the FRAM implementation. Also, management has standardized and issued guidance on financial monitors and included them in the GCS. Further actions include:

1. Develop a risk-based monitoring framework for RAP-IS, mitigation strategies and follow-up actions.
   OPI: Associate ADM, Operations
   Due Date: December 31, 2015

2. Develop standardized activity monitoring guidelines for all contribution programs.
   OPI: Associate ADM, Operations
   Due date: May 30, 2016

3. Perform a QA exercise on the implementation of the FRAM and report on findings and recommendations.
   OPI: Associate ADM, Operations
   Due date: March 31, 2017

4. Complete the QA pilot on financial monitors and develop recommendations based on QA results.
   OPI: ADM, CFO
   Due date: March 31, 2016

5. Develop national framework for QA on financial monitors.
   OPI: ADM, CFO
   Due date: March 31, 2017

Recommendation 4 – Medium Risk

The Department should strengthen forecasting procedures to ensure the collection of accurate financial information.

Management response statement:

Forecasting

Management agrees with the recommendation. The department has taken steps to improve the rigour, tools and challenge function for its departmental forecasting process.  These changes were supported by significant regional training delivered by Finance in 2014-15. Since 2013-14, a comprehensive suite of tools, guides and training were developed to address the gaps in the financial management of Gs & Cs on financial monitoring, forecasting, coding and commitments. Also, in 2014-15, new tools and rigor were implemented in the forecasting process that reduced the lapse in Settlement. Further actions include:

1. Training material has been developed on the use and functionality of the forecast template and tools.  All regions have been trained on the financial forecasting tools and templates and ongoing refresher training is offered.
   OPI: ADM, CFO
   Completed June 2014

2. Provide additional support for the P8 forecast exercise by identifying commitments/CAs that are higher risk for under-spending as part of the financial information package provided to clients.
   OPI: ADM, CFO
   Due date: December 30, 2015

3. Develop and deliver training on Overpayment Recovery Guideline (Guideline has been completed).
   OPI: ADM, CFO
   Due date: March 31, 2016

Recommendation 5 – High Risk

The Department should:

1. Assess the financial administration of transfer payments in regions to ensure financial policy and process requirements are fully understood, through sufficient training and guidance, and monitored for financial policy compliance.
2. Implement a formal process and procedures that address the unique requirements of the RAP-IS payment cycle.

Management response statement:

a) Financial Administration of Transfer Payments

Management agrees with the recommendation. Training courses have been designed and delivered which cover the needs related to financial administration of transfer payments. Standardized tools, policies, guidelines and training with respect to compliance with the delegation process and other key areas of the financial management of Gs & Cs have been developed. Training needs and priorities around this program area will be included in the data collection and needs analysis for Gs & Cs. A request for approval form was created in 2014-15 to formally track EI and the implementation of major and minor amendments. This form was included in GCS and is now a mandatory part of the amendment process. Further actions include:

1. Review, revise and implement mandatory financial procedures and forms related to the approval and payment process. This will also include developing and delivering training on the delegation of financial signing authority process.
   OPI: ADM, CFO
   Due date: Sept 30, 2016

   Develop and implement a methodology to monitor compliance for the sequence of EI to transaction authority, including segregation of duty.
   OPI: ADM, CFO
   Due date: Mar. 31, 2017

2. Review and implement improvements to operational procedures.  Also, update manuals and guidelines as operational guidance for officers managing Gs & Cs. The Regions will develop a strategy for ensuring completion of all mandatory training. Close-out procedures, including the disposition of capital assets will be updated in conjunction with the completion of the Gs & Cs manual and included in GCS.
   OPI: Associate ADM, Operations
   Due Date: June 1, 2016

   Launch payment module in GCS, which is contingent on funding received for the full scale implementation of GCS.
   OPI: Associate ADM, Operations
   Due date: April 1, 2017

3. Data collection and analysis of Gs & Cs learning needs is currently underway to review the existing training curriculum and identify training needs and gaps.  The process will include learning needs for supervisors and managers and mandatory training.
   OPI: ADM, Corporate
   Due date: March 31, 2016

b) Formal Processes and Procedures for RAP-IS

Management agrees with the recommendation. Management will implement formal processes and procedures that address the unique requirements of the RAP-IS payment cycle. RAP-IS processing is currently a manual process and support of an IT solution would facilitate standardization and enable program integrity.  Further actions include:

1. Develop training material for RAP-IS for the delegation of financial signing authority process as part of the training suite developed for all other programs.
   OPI: ADM, CFO
   Due date: September 30, 2016

2. Streamline RAP-IS process and include in GCS, contingent on resources.
   OPI: Associate ADM, Operations
   Due Date: April 1, 2017

Appendix C – Applicable Government of Canada Legislation, Policies & Directives

• Policy on Transfer Payments
• Directive on Transfer Payments
• Financial Administration Act
• Policy on Internal Control
• Policy Framework for Financial Management
• Policy on Financial Management Governance
• Policy on Information Management
• Policy on Management, Resources and Results Structures
• Directive on Delegation of Financial Authorities for Disbursement