Audit of the Citizenship Program

1.0 Introduction

CIC’s Internal Audit and Accountability Branch RBAP for 2010–2013, identifies audit and advisory engagements to be undertaken during that period by weighing a combination of departmental priorities and risks. The RBAP identified the need for an audit of the Citizenship Program. This audit focused on the governance, risk management, and internal control processes and procedures in place over application processing for the Citizenship Program. The examination phase was conducted between December 2010 and April 2011.

1.1 Background

CIC builds a stronger Canada by helping immigrants and refugees settle and fully integrate into Canadian society and the economy, and by encouraging and facilitating Canadian citizenship. Citizenship is fundamentally a legal status that can be obtained by birth in Canada, birth outside Canada to a Canadian parent or naturalization. A certificate proving citizenship can be requested by any Canadian citizen (proof) or granted to persons who are not Canadians by birth (grant). Other types of applications include applications to voluntarily renounce (renunciations) one’s legal status as a Canadian or to resume (resumptions) citizenship, or a request for a search of citizenship records.

Prior to the introduction of the first Canadian Citizenship Act in 1947, there was legally no such thing as Canadian citizenship. Both native-born and naturalized citizens were British subjects. The 1947 Canadian Citizenship Act recognized Canadian citizenship for the first time. The Act defined the provisions regarding nationality, which are still in place today. On February 15, 1977, the Citizenship Act replaced the 1947 Act, making extensive changes in granting citizenship to eligible permanent residents. The effect was to make citizenship more widely available. The Citizenship Regulations were revised and the new regulations came into force on that date. The Act basically remained the same until 2007.

Since 2007, the government has passed two legislative reforms to amend the Citizenship Act: Bill-C14 and Bill C-37. Bill C-14 addressed adoption inequalities by allowing for the granting of citizenship to non-Canadian children adopted abroad by Canadian parents, without requiring that such children first become permanent residents. Bill C-37 restored citizenship to many people who had lost it under previous legislation, recognized other individuals as citizens for the first time, and introduced a limit to citizenship by birth abroad to a Canadian parent to one generation born outside of Canada. To support effective implementation and client service, CIC developed supporting regulations, information systems changes, application kits and forms, training materials, communication products, and policy and program manual updates.

In 2010, the Department undertook the Citizenship Operations Review Exercise which provided a horizontal analysis of current challenges facing the Citizenship Program from an operational perspective. The CORE examined the current state of the Citizenship Program and provided recommendations for consideration by management in its modernization of the program.

At the beginning of 2011, a diagnostic assessment of the Citizenship Program’s organizational readiness for change was performed. The assessment provided useful insight into the Citizenship Program’s readiness for change as well as some key areas on which to focus change management strategies in the current modernization of the program.

In addition, the PID of the Operational Management and Coordination (OMC) Branch led a conference on fraud at which participating regional and national representatives of the Citizenship Program specifically addressed residence fraud.

The CIC Citizenship Program has contributed to a diverse society that promotes multiculturalism and social cohesion. This is achieved through its current sub-activities, such as:

• Citizenship policy and program development
• Citizenship processing
• Citizenship promotion
• Multiculturalism: engagement and inclusion

1.1.1 Citizenship Lines of Business

The two main business lines of the Citizenship Program are the granting of Canadian citizenship and the issuance of proof of citizenship.

Granting of citizenship. Grants of Citizenship are obtained by persons who are not Canadian citizens or who were Canadian citizens but have lost or renounced their citizenship. A foreign-born person adopted by a Canadian citizen can apply for citizenship through the adoption provisions of the Citizenship Act. People who lost or renounced their Canadian citizenship may apply to resume (regain) citizenship.

Granting requirements are different depending on whether the person is an adult or a minor. The Citizenship Regulations^{Note de bas de page 1} provide the requirements for applications made by an adult to be granted citizenship in accordance with the Citizenship Act^{Note de bas de page 2} . One requirement is evidence that establishes that the applicant has, within the four years immediately preceding the date of his or her application, accumulated at least three years of residence in Canada. Once granted citizenship, the applicant is required to take the oath of citizenship. Legal status as citizen takes effect the same date the oath was administered. People who are not required to take the oath, such as minors under 14 years of age, as per regulatory requirements, become Canadians on the day of the grant. All people granted citizenship are issued a certificate of Canadian citizenship.

Proof of citizenship. People who are already Canadian citizens and who require a document certifying their citizenship status can apply for proof of citizenship. In general, for people born in Canada, a provincial or territorial birth certificate or a certificate of citizenship is accepted as proof of citizenship. For people born outside Canada to a Canadian parent, proof of citizenship is a certificate of citizenship, or a certificate of registration of birth abroad in the case of persons born between 1947 and 1977. For people who acquired citizenship through naturalization, a certificate of naturalization or a certificate of citizenship is accepted as proof of citizenship.

People who acquired citizenship by fraudulent means may have their citizenship revoked by the Government of Canada.

1.1.2 Citizenship Program Delivery

The Citizenship Program is delivered through many points of service. These include:

• Centralized Processing Region (CPR)
  • Call Centre in Montreal
  • Case Processing Centre in Sydney
• Regional Offices
  • Local CIC offices
• International Region
  • Missions overseas
• Operational Management and Coordination Branch
• Case Management Branch
• Citizenship and Multiculturalism Branch
• Information Management and Technologies Branch / GCMS
• Citizenship Commission

The roles and responsibilities associated with the Citizenship Program delivery are described in Appendix B.

All applications concerning Canadian citizenship must be sent to CPC-S which ensures that the applications are completed and signed and that all required documents and fees are included in the submission.

Applications for citizenship grants are mostly forwarded to local offices in the region closest to where the applicant lives. Some files that do not require administering the oath of citizenship (minors under 14) may be processed at CPC-S if a parent is already a Canadian citizen.

The local CIC office reviews applications for granting Canadian citizenship to determine if the applicant meets the age, residency, criminality and security requirements. In addition, the office administers language assessments and knowledge tests of Canada and the rights and responsibilities of Canadian citizenship and, when necessary, arranges hearings with a citizenship judge. Once all clearances and verifications have been completed and, once the tests have been administered, the citizenship judge reviews the application and the test results to determine whether the applicant meets the requirements for citizenship. If the judge does not approve the application, the applicant is told, in writing, that the application has been non-approved, and given the reasons for non-approval. If the judge approves citizenship, the citizenship officer grants citizenship and the applicant is invited to attend a citizenship ceremony where the applicant takes the oath of citizenship and receives the Certificate of Canadian Citizenship. The citizenship officer can also recommend that the Minister appeal a judge’s decision.

Applications for proof of citizenship are processed exclusively by CPC-S.

Consular missions provide general information to clients on how to apply for a proof of citizenship, renunciation, or a request for a search of records. Missions accept these applications on behalf of CIC and forward them to CPC-S.

Table 1 provides an overview of the volume of applications processed within Canada and the inventory for the two lines of business.

Source: Book of Basics, CIC Operations Sector.

1.1.3 Environmental Context

The granting of Citizenship is a multi-stage process that involves the Case Processing Centre in Sydney and local offices across Canada and resulted in approximately 143,000 individuals becoming Canadian citizens in 2010. CIC is also responsible for issuing citizenship certificates to existing Canadian citizens. In 2010, approximately 69,000 citizenship certificates (also known as proofs) were issued to such individuals.

The demand for services has been increasing and new program integrity measures are being implemented. As a result, the number of applications has outpaced the Department’s processing capacity and available resources, resulting in significant inventories. Between 2008 and 2010, the Department received on average 228,000 grant applications a year.

Throughout 2010-2011, CIC continued to implement its Citizenship Action Plan (CAP).  Initiated in 2009, the CAP consists of a co-ordinated set of initiatives that aim to make citizenship a key pillar in an integrated society.  Addressed to both newcomers and established Canadians, the goal of the CAP is to strengthen the value and meaning of Canadian citizenship by promoting increased civic knowledge, civic participation, and sense of belonging to Canada.  Improving the integrity of the Citizenship Program is also a key objective of the CAP.  As part of the CAP, CIC developed a new citizenship test study guide entitled Discover Canada: the Rights and Responsibilities of Citizenship, which was originally introduced in November 2009.  An updated version of Discover Canada was released in March 2011, with even further strengthened content on common Canadian values such as freedom, democracy, human rights, the rule of law, and the equality of men and women.

In October 2010, and as a result of the new study guide, the Citizenship Regulations were amended respecting citizenship knowledge requirements to provide greater flexibility in the ability to test applicants consistently on a range of knowledge of the characteristics of Canada, and on the responsibilities and privileges of citizenship.

The knowledge test also continues to be one of the tools for assessing language proficiency.  Applicants are required to interact with CIC staff and in some cases be interviewed by a citizenship judge to assess their ability to communicate in either English or French.  To assist officers and citizenship judges in fulfilling this role language assessment tools were revised and standardized to ensure a consistent approach for determining language proficiency.

In 2010, some key initiatives had an impact on processing, including the implementation of program integrity measures, the introduction of the language assessment tool (which required training of all citizenship officers and judges), increased time requirements to conduct hearings, and the temporary policy to allow applicants who failed the citizenship test on their first attempt to rewrite the test. The program also faces pressure from a growing inventory of applicants who require a hearing with a citizenship judge.

In recognition of the importance of strengthening program integrity, improving client service, and increasing processing efficiency, the Department undertook a number of modernization initiatives in 2010 including:

• Further implementation of the citizenship fraud action plan, such as the development of high and medium risk indicators to assist officials in identifying which applications must or should be reviewed with residence in mind.
• Citizenship Operations Review Exercise: Which examined the current processes in the citizenship program, identified concerns, and made several recommendations.
• Change Readiness Assessment for the Citizenship Program
• Review of the Citizenship Program’s Quality Assurance exercises

As a result of these reviews and the Citizenship Audit, the Department has a better understanding of some of the key challenges facing the Citizenship Program and issues which need to be addressed. In recognition, a Citizenship Modernization Steering Committee co-chaired by the Assistant Deputy Minister (ADM) Operations and the Senior Judge has been launched to develop and implement a Citizenship Modernization roadmap to ensure the program is able to meet expectations and make changes where necessary.

1.2 Audit Risk Assessment

An audit risk assessment was conducted during the planning phase. The assessment was based on interviews, document reviews and analysis and took into account the applicable elements of the Management Accountability Framework. The key risks are identified below.

Governance

• The CAP comprises various initiatives to enhance the meaning of Canadian citizenship and the integrity of the Citizenship Program in accordance with the Department’s strategic objectives. The wide variety of initiatives is managed by different groups that in some cases report to different sectors. There is a risk that governance practices may not support the achievement of the Citizenship Program strategic objectives due to accountabilities not being clearly defined.
• There are ongoing funding issues affecting the Citizenship Program. CPC-S was allocated a certain amount of money for the processing of 170,000 grants and 38,000 proofs based on permanent (A-base) funding, and the program has relied on temporary (B-base) funding to process additional cases in recent years, which has required the preparation of business cases. There is a risk that the performance measures in place may not be sufficient to provide information on results for decision making and for the integration of human resources and business plans.

Risk Management

• Risks to the achievement of objectives (including processing levels) and associated mitigation strategies may be identified in regional or local plans. However, there is a risk that management may not have a formal process to identify, assess and manage issues and risks related to the overall delivery of the Citizenship Program.

Internal Control

• Planning interviews and documentation identified program integrity as a risk area. In particular, QA activities were not occurring on a regular basis in all regions.

1.3 Audit Objectives

The objective of this audit was to assess the adequacy of the governance framework, risk management practices and internal control framework over the delivery of the Citizenship Program.

1.4 Audit Criteria

Criteria are the benchmarks against which audit engagement objectives are assessed. The source of the criteria for the governance framework and risk management practices lines of enquiry was the Core Management Controls developed by the Internal Audit Sector of the Office of the Comptroller General. The criteria used to determine the adequacy of internal controls were based on relevant Treasury Board and CIC legislation, policies and directives.

The detailed criteria for the audit are presented in Appendix A and were provided to management at the outset of this engagement.

1.5 Audit Scope

The audit covered the management and delivery of the Citizenship Program with regard to applications processed in Canada. It involved activities at national headquarters (NHQ), including the Citizenship Commission and CPR, CPC-S, regional headquarters and local offices.

Scope exclusions. The processes in place at missions abroad were excluded from the scope of the audit since the applications received there, which are mostly adoptions, are forwarded to CPC-S. Renunciations and revocations were also excluded due in part to low volumes and to changes under way with respect to the revocation process.

1.6 Audit Methodology

The planning phase began in the second quarter of fiscal year 2010–2011 and included preliminary interviews in each area of NHQ involved in the Citizenship Program; interviews with regional management and staff of two locations; and a review of legislation, regulations, policies and procedures. Site visits to CPC-S, a regional office and a local office provided an overview of delivery processes in place. The information obtained was used in the development of a preliminary risk assessment and audit criteria. The audit plan, including the audit criteria, was distributed to the OMC Branch, the Citizenship and Multiculturalism Branch, the CPR, regional headquarters, the International Region and the Case Management Branch. A detailed audit program was developed at the conclusion of the planning phase.

The examination phase included local office visits, file reviews, an interview with the Senior Citizenship Judge, and interviews with management and staff involved in the delivery of the Citizenship Program. During site visits to local offices, the auditors observed and documented the processes in place, and reviewed a sample of applications, relevant documents and controls in place.

Sampling methodology

Granting of citizenship

A random sample of grant files was selected from citizenship ceremonies conducted in December 2010, January 2011 and February 2011. The sample size for grants was 50 files per location (40 adults and 10 minors, with the exception of one location where it was 45 adults and five minors due to limited minor cases) for a total of 500 reviewed grant cases. Ten locations were visited covering all regions. The sample was determined judgmentally and provided sufficient coverage. In addition, up to five refused files per location were reviewed depending on  availability to assess the evidence on file in support of the refusal decision.

Proof of citizenship

A sample size for proofs was calculated according to a statistical sampling formula which yielded a sample of 42 processed files selected randomly within the month of November 2010. The files were reviewed at CPC-S.

In reviewing the files, and for both lines of business, the audit team assessed whether the applications on file were processed in accordance with the citizenship legislation and CIC policies and procedures.

The audit was conducted in accordance with the Internal Auditing Standards for the Government of Canada and the International Standards for the Professional Practice of Internal Auditing.

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