Audit reports 2014-2015: 2 - Audit of Citizenship and Immigration Canada

Table of contents

• Audit of Citizenship and Immigration Canada
• Observations on the Appointment Framework
• Overall response by Citizenship and Immigration Canada
• Action taken by the Public Service Commission

Audit of Citizenship and Immigration Canada

2.1 The audit covers Citizenship and Immigration Canada’s (CIC) appointment framework for the period of April 1, 2013, to March 31, 2015. The objective of the audit was to determine whether CIC had an appropriate framework, practices and systems in place to manage its appointment activities.

2.2 CIC was established in 1994 and its mandate is to select foreign nationals as permanent and temporary residents and offer Canada’s protection to refugees. The department develops Canada’s admissibility policy, which sets the conditions for entering and remaining in Canada. It also conducts, in collaboration with its partners, the screening of potential permanent and temporary residents to protect the health, safety and security of Canadians. CIC operates 27 offices in Canada and 70 offices in 63 countries.

2.3 As of March 31, 2014, CIC had 5,886 full-time equivalents in its workforce, most of whom worked in the National Capital Region and were of indeterminate status. The organization carried out 3,676 staffing activities in 2013-2014. This included a significant increase in term appointments to the public service to increase CIC’s capacity to process temporary resident and citizenship applications.

2.4 CIC reported some challenges that had an impact on staffing in the organization. In July 2013, the primary responsibility for Passport Canada was transferred from the Department of Foreign Affairs, Trade and Development to CIC, with functions related to service delivery transferred to Service Canada. Consequently, CIC invoked Workforce Adjustment for 25 positions to eliminate duplication in internal services. In addition, CIC’s Human Resources (HR) Branch underwent significant organizational restructuring as part of Spending Review 2012. According to CIC, another challenge was the centralization of all their regional HR services, including staffing. CIC also stated that Budget 2013 provided additional funding for temporary staffing to meet departmental priorities.

2.5 CIC conducted a comprehensive monitoring exercise of 40 appointments for the period of April 1, 2011, to March 31, 2013. Given the comprehensive nature of this monitoring activity, we performed an analysis to determine whether an adequate basis for reliance existed. To this end, we examined whether the work carried out by CIC was relevant to and aligned with the Public Service Commission’s (PSC) audit objectives, criteria and scope and we assessed the independence and the objectivity of those responsible for the monitoring exercise. We also examined whether there was sufficient, reliable and relevant information to support the monitoring observations and conclusions. In addition, we assessed whether the monitoring exercise was appropriately documented and supervised. Finally, we examined whether the findings were communicated to senior management and corrective measures taken.

2.6 We found that an adequate basis for reliance on CIC’s monitoring exercise existed. Consequently, the PSC’s audit objective to determine the compliance of appointments and appointment processes was not required. Nevertheless, we examined whether CIC had implemented its action plan resulting from its monitoring exercise. In addition, we conducted interviews with HR professionals and analyzed relevant organizational documentation.

Observations on the Appointment Framework

Sub-delegation of appointment authorities

2.7 The Public Service Employment Act (PSEA) gives the PSC exclusive authority to make appointments to and within the public service. The PSC delegates many of its appointment and appointment-related authorities to deputy heads who, in turn, may sub-delegate the exercise of these authorities. The PSC expects deputy heads to have a sub-delegation instrument in place that is well managed and accessible across the organization.

2.8 During the period covered by the audit, the deputy head of CIC was subject to the Appointment Delegation and Accountability Instrument (ADAI) since its coming into force, granting the deputy head appointment and appointment-related authorities.

2.9 We found that the deputy head established an Instrument of Human Resources Signing Authorities that is well managed and included the conditions to be met prior to exercising appointment and appointment-related authorities. For example, sub-delegated managers must commit in writing to respect the conditions of sub-delegation by signing a letter entitled “Sub-delegation of Appointment Authorities Pursuant to the New PSEA” and must complete the mandatory training prior to being sub-delegated appointment and appointment-related authorities. The ADAI and the sub-delegation instrument were made accessible to employees on CIC’s intranet site.

2.10 In addition, we found that CIC established a Staffing Sub-delegation Conditions Approval Form to ensure that sub-delegated managers meet all conditions of sub-delegation. CIC also maintained a list of sub-delegated managers used by HR advisors to ensure that the offers of appointment were signed by a sub-delegated manager with the appropriate level of sub-delegation.

2.11 As part of our analysis of CIC’s monitoring activities, we found that CIC effectively monitored the exercise of sub-delegated appointment and appointment-related authorities. We noted that the monitoring checklists used to perform this monitoring activity included an element relating to whether the offer of appointment was signed by a manager with valid sub-delegation authorities.

Planning for staffing

2.12 Organizational staffing plans and related strategies describe organizational staffing priorities and how and when they will be achieved. The PSC expects deputy heads to establish staffing plans and related strategies that are measurable, approved and communicated to employees.

2.13 CIC developed an Integrated Corporate Plan (ICP) for 2013-2014, including an HR Plan and related strategies that were measurable, approved and communicated to employees on CIC’s intranet site. CIC updated its ICP for 2014 and developed an HR Plan for 2014-2015.

2.14 We found that CIC established measures to ensure the successful implementation of its staffing plans and related strategies such as quarterly reviews to allow for regular monitoring of commitments and milestones and progress reports to identify necessary adjustments.

2.15 We noted that CIC monitored the results of its staffing plans and related strategies. CIC also reported on the results of its analysis between planned and actual staffing activities to senior management, including the Departmental Management Committee, through various internal reports. In addition, we found that briefing notes were prepared for the deputy head’s approval of quarterly staffing monitoring reports that included key findings and recommendations.

Appointment policies

2.16 The PSC expects deputy heads to establish mandatory appointment policies for area of selection, corrective action and revocation, as well as criteria for the use of non-advertised processes. The PSC also expects the other appointment policies that organizations develop be compliant with the PSEA, any other applicable statutory and regulatory instruments and the PSC’s Appointment Framework.

2.17 We found that CIC established appointment policies and criteria for the use of non-advertised processes that are compliant. CIC reviewed and updated its organizational appointment policies in 2014 and 2015. We noted that CIC’s stakeholders, such as managers and bargaining agents, were consulted in the revision of its policies and criteria for the use of non-advertised processes.

2.18 We also found that CIC’s organizational policies and criteria for the use of non-advertised processes were communicated and accessible to all sub-delegated managers, employees and bargaining agents on CIC’s intranet site.

Capacity to deliver

2.19 The PSC expects deputy heads to ensure that those who have been assigned a role in appointment processes have been informed of their roles and responsibilities and have access to tools and the HR support to carry out this role.

2.20 We found that CIC’s Instrument of Human Resources Signing Authorities serves to inform those who have been assigned a role in appointment processes of their roles and responsibilities.

2.21 We also noted that sub-delegated managers have access to various staffing tools on CIC’s intranet site, such as a series of guides to support sub-delegated managers in making appointments and conducting appointment processes, including a guide to develop rating scales and Statement of Merit Criteria.

2.22 In addition, we found that sub-delegated managers had access to an HR advisor who had passed the PSC Appointment Framework Knowledge Test. This test is designed to evaluate knowledge of all parts of the PSC’s Appointment Framework (policy, delegation and accountability) and the legislative framework.

2.23 Although there is no PSC requirement to document the advice provided by HR advisors, we found that CIC had effective controls in place to monitor whether the advice provided was compliant with the PSC’s Appointment Framework and whether it was followed by the sub-delegated manager. We noted that the monitoring checklists used by CIC to perform its monitoring of staffing activities included an element to assess the quality of the HR advice and guidance provided.

Monitoring

2.24 Monitoring is an ongoing process that allows deputy heads to assess staffing management and performance related to appointments and appointment processes. Monitoring makes it possible to identify issues that should be corrected, to manage and minimize risk and to improve staffing performance. The PSC expects deputy heads to undertake the mandatory monitoring outlined in the PSC’s Appointment Framework, including the ADAI, and adjust practices accordingly.

2.25 CIC developed a multi-year Staffing Monitoring Framework for 2014-2017 that identifies the requirement to monitor and report on certain policy-based risk areas, such as acting appointments over 12 months and appointment of casual workers to term or indeterminate status through non-advertised processes. We found that CIC conducted the required monitoring accordingly for the period covered by our audit. Comprehensive reports on the results were reported to senior management and included proposed actions and next steps.

2.26 As previously mentioned, we noted that CIC conducted a monitoring exercise on 40 appointments for the period of April 1, 2011, to March 31, 2013. This exercise was based on a Self-Assessment of Staffing Activities Tool developed by CIC’s Internal Audit & Accountability Branch to assess its staffing framework and practices. The tool identified key compliance requirements and included similar audit objectives and criteria used by the PSC to perform organizational audits. For this monitoring exercise, CIC used an extraction from its HR database for sampling purposes. We conducted an electronic verification of CIC’s data and found that it provided reliable information on their appointments.

2.27 Following the completion of its monitoring of appointments, CIC prepared a report that included key monitoring observations on merit and assessment, consideration of persons with a priority entitlement, area of selection, notification, selection and appointment and the choice of non-advertised process. CIC also developed an action plan to address issues identified. Key issues found pertained to insufficient information to conclude that merit was met, rationales for the use of non-advertised appointment processes, errors in advertisements or notifications, area of selection used and consideration of persons with a priority entitlement.

2.28 As indicated previously, we concluded that an adequate basis for reliance existed on CIC’s monitoring exercise of 40 appointments and accepted the results as reported by the organization. During the course of our audit, we examined whether CIC had implemented the action plan resulting from its monitoring exercise. The following paragraphs provide a summary of our observations concerning the implementation of CIC’s action plan.

“Inform and advise HR advisors via the monthly staffing teleconference and information sessions.”

2.29 To inform and advise HR advisors on issues identified during its monitoring of appointments, CIC worked closely with the HR staffing community and sub-delegated managers to provide feedback using various mechanisms. For example, information sessions with the HR advisors and HR client service managers were held. In addition, information was provided during monthly staffing teleconference meetings on issues such as considering persons with a priority entitlement.

“Review CIC’s Policy on Non‐Advertised Appointments.”

2.30 To address issues found relating to the rationales for the use of non-advertised appointment processes, CIC revised its Policy on Non‐Advertised Appointments, effective April 1, 2014. The revised policy included an updated mandatory template to support managers in writing rationales for the use of non-advertised appointment processes and staffing-related definitions.

“Create tools for managers such as a one page document containing “Tips for managers on completing non‐advertised rationales” and examples of acceptable non‐advertised rationales management can use as a guide for future processes.”

2.31 We found that CIC developed several tools to support sub-delegated managers in preparing rationales for the use of non-advertised appointment processes, such as frequently asked questions and tips to writing a rationale for non-advertised processes. These tools were formally communicated to CIC employees through HR Bulletins. CIC indicated that some of these tools are currently being updated, based on feedback received from senior management.

“Monitor each non‐advertised rationale.”

2.32 We found that CIC monitored the rationales for the use of non-advertised appointment processes through its bi-annual monitoring activity, as identified in its Staffing Monitoring Framework. CIC also indicated that a targeted monitoring exercise will be conducted in early 2015-2016 to review a sample of rationales for the use of non-advertised appointment processes completed in 2014-2015.

“Review CIC’s Policy and Guidelines on Area of Selection.”

2.33 To address issues relating to area of selection, CIC revised its Policy on Area of Selection, effective April 1, 2014. The revised policy included information to assist managers in determining the appropriate area of selection, such as a template for the area of selection justification and related definitions.

“Create guidelines and examples to help HR advisors and managers decide which area of selection best meets their needs and is compliant with policy.”

2.34 We found that CIC incorporated a guideline and examples in their revised Policy on Area of Selection to assist HR advisors and sub-delegated managers determine the appropriate area of selection.

“Create a new Guide on Communication in the Appointment Process which will provide detailed information on how and when to post advertisements.”

2.35 To address inconsistencies found in some of the advertisements and notifications, CIC developed a Guideline on Communication in an Appointment Process that took effect April 1, 2014. This guideline was established to ensure compliance with PSC policies and related guidance.

“Monitor closely the advertisement of job opportunities, notifications and information regarding acting appointments posted at CIC on Publiservice and jobs.gc.ca to ensure compliance.”

2.36 We found that CIC conducted two monitoring activities that included the monitoring of advertisements, notifications and information regarding acting appointments to ensure compliance with their Policy on Area of Selection and the PSC’s Policy on Area of Selection. These monitoring activities also included a review of areas of selection and Statements of Merit Criteria to ensure consistency in both official languages.

“Proceed with a follow up internal monitoring of staffing files exercise.”

2.37 To determine if issues identified in the initial monitoring exercise persisted, CIC conducted a follow-up monitoring of appointments exercise that was completed in May 2014. Key observations were included in a report that was shared with management. The report did not include additional recommendations further to the first report. According to CIC, notable improvements were observed during this subsequent monitoring exercise. It was therefore recommended to pursue those follow-up activities outlined in the initial internal monitoring exercise.

2.38 Based on our findings, we concluded that CIC had appropriately implemented the action plan resulting from this monitoring activity.

Overall response by Citizenship and Immigration Canada

Action taken by the Public Service Commission

Citizenship and Immigration Canada (CIC) conducted a noteworthy and comprehensive monitoring of appointments exercise that the Public Service Commission (PSC) was able to rely upon and accept the results as reported by the organization. The PSC found that CIC had adequately implemented the recommendations from its action plan to address issues identified through its monitoring exercise, illustrating its commitment to ensuring continuous improvement of its staffing framework.

The PSC systematically reviews audit information and the organization’s management response to determine whether any action should be taken by the PSC. This review confirmed to the PSC that CIC has put in place the key elements of a sound staffing management system and that the organization is committed to continue to build upon this solid foundation in the future, as evidenced in its management response.

The PSC commends CIC for its ongoing engagement in support of a strong staffing regime.