Audit of Selected Advance Contract Award Notices - Final Report

Approved February 14, 2011

Table of Contents

• Executive Summary
• 1. Introduction
• 2. Background
  • 2.1 Rationale
• 3. Risks
• 4. Objective
• 5. Scope
• 6. Statement of Assurance
• 7. Methodology
• 8. Observations and recommendations
  • 8.1 Use of procurement instruments
  • 8.2 Advance Contract Award Notice Administration
  • 8.3 Governance
  • 8.4 Documentation - general
• 9. Conclusion
• Annex A - Management Control Framework over Procurement of Advance Contract Award Notifications
• Annex B - Glossary

Executive summary

Context

In the fall of 2009, the Public Service Commission (PSC) published four Advance Contract Award Notices (ACAN) to procure the services of four senior-level advisors to serve as external members of the PSC's Independent Audit Advisory Committee (IAAC). Each one-year contract was valued at $21,000, renewable up to three times. In the spring of 2010, a newspaper article and related media reports alleged that the PSC had breached government procurement policies.

Rationale

The President of the PSC directed the Internal Audit Directorate (IAD) to undertake an audit of the four ACANs to determine their compliance with Treasury Board (TB) and PSC policies and procedures. The planning phase for this audit started in April 2010.

Objective

The objective of this audit was to assess whether the PSC complied with TB and organizational policies and procedures for i) the selection of the ACAN as an instrument for the procurement of services of senior-level advisors for the PSC's IAAC and ii) the subsequent awarding of the four contracts.

Conclusion

Program management had a limited number of options for the procurement of executive-level advisory services for the IAAC. The auditors determined that rationale for the selection of an ACAN as the procurement instrument was based on the skill set for the different members of the committee; however, the exception used to support the use of the ACAN was not correct. Furthermore, although the procurement for the services requested was subject to the North American Free Trade Agreement, the audit found that it was not posted as such on the MERX system.

The publishing of the ACAN was transparent and its administration by Procurement Services was, overall, performed in compliance with PSC and TB policies and regulations. During the planning of the ACANs, the Statement of Work requirements were modified by program management, at the request of Procurement Services; these changes were to the benefit of all potential suppliers. Any communication prior to the publication of the ACAN was for administrative purposes and did not constitute an advantage to any potential supplier.

In order to ensure compliance with government and PSC contracting policies and regulations, some internal controls should be reviewed and enhanced to reduce potential risks and improve procurement processes. In planning for their procurement needs, program management should consider the existing contracting mechanisms and their constraints, including allowing the time necessary to execute the procurements properly. More thorough documentation of the procurement files would better support the corroboration and justification of decisions and ensure compliance with government and internal contracting procedures. Finally, the Contract Review Board's role could be reinforced to provide greater review of some contracts.

Management has accepted the audit findings and has provided action plans, which will address the weaknesses noted.

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1. Introduction

A newspaper article published in late March 2010, and other related media stories alleged that the Public Service Commission (PSC) breached government procurement policies. In order to provide an independent review of the extent to which the four contracts conform with government and corporate regulations, the PSC's Internal Audit Directorate conducted an internal audit. In the conduct of this audit, the auditors consulted with the Office of the Procurement Ombudsman.

2. Background

In the fall of 2009, the Public Service Commission (PSC) published four Advance Contract Award Notices (ACAN) to procure the services of four senior-level advisors to serve as external members of the PSC's Independent Audit Advisory Committee (IAAC). The primary role of the IAAC is to provide the President of the PSC with independent, objective advice, guidance and deliberation at the critical control points of the staffing-related external audits, evaluations, studies and other key activities carried out by the Audit and Data Services Branch. This ensures that, when the President takes a position on staffing oversight, she has considered the advice and views of a broad spectrum of other knowledgeable individuals. Unlike departmental audit committees with broad duties, as defined under the government's Policy on Internal Audit, the IAAC focuses solely on the Public Service Employment Act (PSEA).

The IAAC meets at least twice a year, is chaired by the President and can be comprised of up to six individuals from outside of the PSC. External committee members are selected on the basis of their skills, insights, relevant knowledge and experience and are leaders in their respective fields of expertise. As with many committees, individual members are each expected to bring unique perspectives, such that collectively all key aspects of required expertise are covered. Duties for each, however, are the same, e.g., reviewing briefing packages.

Subject to annual approval by the President, external members normally serve a term of four years, which is renewable once only. The four external members are not employed by the PSC; their services, rather, are retained through service contracts. They had been retained through sole-source contracts for similar services in the past.

An ACAN is a public notice indicating that an organization intends to award a contract to a pre-identified supplier, thereby allowing other suppliers to signal their interest in bidding by submitting a Statement of Capabilities. If no other supplier submits a Statement of Capabilities that meets the requirements set out in the ACAN, the process is deemed to be competitive and the organization may then proceed with awarding the contract to the pre-identified supplier.

Government policy, through the Treasury Board of Canada Secretariat (TBS), makes the ACAN process available to organizations to provide them with a procurement process that is efficient and cost effective, while respecting the contracting principles of fairness, openness and transparency.

In addition to the ACAN, management had the following procurement instruments available to them:

• Non-competitive contract - total value of the new requirement for services cannot exceed the $25,000 limit set for sole-source contracts;
• Request for Proposal – a draft invitation for suppliers had been developed by Procurement Services, but assembly of the collective skills needed would have been complex;
• Section 10 of the PSEA - this authority is not known to have ever been used by the Commission or by any other agencies with similar clauses in their enabling acts, and time to enable this was unknown; and
• Special authorities – these can be requested from TB and go beyond the authorities set in the Government Contracts Regulations to procure the services through a non-competitive process, and time to enable this was unknown.

The Office of the Procurement Ombudsman had also indicated an interest in this procurement and had offered some advice and assistance to the PSC, which the PSC accepted.

2.1 Rationale

The President of the Public Service Commission (PSC), accordingly, directed the Internal Audit Directorate to undertake an audit of the four Advance Contract Award Notices to determine their compliance with Treasury Board and PSC policies and procedures.

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3. Risks

The number and complexity of procurement rules and regulations and the pressures on management to deliver results can lead to regulatory, reputational or material risks. These rules specify the procurement instruments available and how each must be used. Many of these requirements also refer to other documents such as policies referring to trade agreement obligations. Some terms are open to interpretation, e.g., employer-employee, “discourage”. Failure to comply with procurement regulations or internal procedures can expose the Public Service Commission (PSC) to challenge, increased government inspection or inability to enforce contracts. Damage to the reputation of the Commission could result in loss of public confidence and, in extreme cases, in external intervention. Inadequate contract management could result in insurance claims, disputes, and, ultimately, litigation. Risks consequently arise from:

• Improperly invoked instruments;
• Non-compliance with trade agreements;
• Improper administration of contract awarding;
• Non-compliance with delegated authorities; and
• Inadequate documentation of the process.

4. Objective

The objective of this audit was to assess whether the Public Service Commission (PSC) complied with Treasury Board and organizational policies and procedures for i) the selection of the Advance Contract Award Notice as an instrument for the procurement of services of senior-level advisors for PSC's Independent Audit Advisory Committee and ii) the subsequent awarding of the four contracts.

5. Scope

The project examined whether the award of the four contracts to procure services of senior-level advisors for the Public Service Commission's (PSC) Independent Audit Advisory Committee (IAAC) was in compliance with:

• The Government Contracts Regulations and Treasury Board's (TB) Contracting Policy, including terms relating to trade agreements, particularly the North American Free Trade Agreement;
• The Conflict of Interest Act (Part 3, Post-employment);
• The Treasury Board of Canada Secretariat's (TBS) Guidelines on the Proactive Disclosure of Contracts; and
• The PSC's internal contract award procedures, including those relating to Advance Contract Award Notices.

The audit did not cover contract administration, nor did it review the PSC's practices relating to other contracts.

6. Statement of Assurance

In my capacity as Chief Audit Executive, I consider that the audit procedures followed and the evidence gathered are appropriate and sufficient to support the accuracy of the conclusions in this report. The conclusions are based on an examination of the situations identified in light of the established criteria. The Public Service Commission's Internal Audit Directorate is working toward full compliance with all applicable standards of the Institute of Internal Auditors and Treasury Board policies

7. Methodology

The Public Service Commission's (PSC) Standard Audit process includes three principal phases:

• The Planning Phase;
• The Detailed Examination Phase; and
• The Reporting Phase.

All deliverables were reviewed and signed off by the Director, Internal Audit. Briefings and validations of observations were ongoing during the course of the audit, with the Vice-Presidents of Corporate Management Branch (CMB) and Audit and Data Services Branch (ADSB), as well as their representatives, as part of the audit process. CMB and ADSB have provided all requested documents and access to employees.

The Planning Phase began in April 2010, during which time a summary risk assessment and review of documentation were used to identify lines of inquiry. In collaboration with the Office of the Procurement Ombudsman, the Internal Audit Directorate (IAD) developed draft criteria using the Government Contracts Regulations, Treasury Board's Contracting Policy and Guidelines on the Proactive Disclosure of Contracts, as well as dispositions from the North American Free Trade Agreement and other procurement-related regulations and procedures such as the Conflict of Interest Act.

Following the planning phase, the audit moved to Detailed Examination. Methodologies included interviews with management and staff and review and analysis of procurement files, documents and key processes related to the four Advance Contract Award Notices in question, including procurement-related data. The Detailed Examination Phase concluded in October 2010. Findings were developed and presented to the Administrative Services Division on October 20, 2010.

Finally, IAD completed the Reporting Phase by developing a report. As part of the PSC's quality assurance process, an independent quality review of the audit files and audit report were completed.

8. Observations and recommendations

• Control Objective No. 1 - The selection of the Advance Contract Award Notice (ACAN) as an instrument for the procurement of services of senior-level advisors for the Public Service Commission's (PSC) Independent Audit Advisory Committee (IAAC) was compliant with Treasury Board and organizational policies and procedures.

8.1 Use of procurement instruments

a. Decision to contract
The auditors expected that the contracting for services contributed to achieving corporate objectives, as required by the Treasury Board's Contracting Policy. The audit examined whether the procurement of advisory services supported the PSC in carrying out its mandate and was not a substitute for ongoing staffing requirements. Management stated it was seeking to secure services through means other than the existing sole-source contracts to avoid the appearance of contract splitting. The IAAC Terms of Reference (ToR) define the Committee's purpose, mandate, membership, authority and frequency of meetings, among other things. In establishing the ToR, the PSC considered the appropriate professional composition, knowledge, experience and independence. According to the ToR and IAAC documentation, the members provide the President of the PSC with expert advice on matters related to the activities carried out by the Audit and Data Services Branch and assist her in fulfilling her mandate.

Given that the Committee normally meets twice a year, and members have defined tasks, service contracts for its members offered the PSC more independence and efficiency than employment contracts. Accordingly, the procurement requirement was in line with corporate objectives.

b. Advance Contract Award Notice instrument properly invoked
The auditors expected that the selection of the ACAN instrument for procurement would meet the exception invoked under section 6 of the Government Contracts Regulations (GCR).

The auditors found that, early in the process, management had considered a number of procurement instruments. In a February 2009 meeting, in preparation for the procurement of the services required for the composition of the IAAC, PSC's Procurement Services presented two procurement options to senior management. The first option consisted of a draft Request for Proposal, (RFP) developed by a consulting firm for Procurement Services for executive-level advisory services, and the second option was section 10 of the Public Service Employment Act (PSEA). This disposition of the PSEA allows the President to retain the services of “experts or other persons having technical or special knowledge”, on a temporary basis, conditional to the approval of their remuneration by Treasury Board (TB). Procurement Services had not included the ACAN as a possible instrument as they questioned its appropriateness. The RFP proposed by Procurement Services and section 10 were both considered by management as not meeting their needs. Senior management then discussed how the ACAN was a potential tool that could speed up the process of assembling a committee. In their view, this tool had been used in the past and had been a simple, fast, yet competitive process. Although the auditors found no written documentation of any decisions made, interviews indicate the discussions at this meeting led to the selection of the ACAN as the procurement instrument chosen for these services.

An ACAN can be invoked only in specific circumstances. According to the GCR, any of four exceptions allow a contracting authority to set aside the requirement to solicit bids. TB Contracting Policy sets conditions for the use of these exceptions and limits the discretion of departments and agencies in their use. The audit found that PSC management invoked exception d), with the view that only one person was able to perform the tasks of the respective members. The Policy specifies exception 6d) “is quite definitive and should be invoked only where patent or copyright requirements, or technical compatibility factors and technological expertise suggest that only one contractor exists. This exception should not be invoked simply because a proposed contractor is the only one known to management”. TB issued a policy notice in 2007 to all organizational procurement services that further defined this exception as being related to intellectual property and work related to technology or systems.

The auditors examined whether the exception invoked was properly used. The candidates' required capabilities included a broad spectrum of skills, combined with experience achieved at the national and international levels by scholars and by former senior public servants. Each of the four ACANs was different, reflecting the fact that each of the members brings a unique skill set to the Committee. However, no intellectual or technological property was required under the postings. Although no written justification was on file to support the use of exception d), we were informed that this was considered the best-suited exception to justify using the ACAN. This absence of justification was compounded by the fact that completion of the form required under Annex A of the contracting policy notice was not done since Procurement Services were not aware of this obligation. Thus, management did not justify use of the ACAN instrument, as required by policy.

Although different capabilities were required of candidates for each ACAN, the tasks to be performed were identical, e.g., reviewing pre-reading material and providing advice and counsel.

In summary, the selection by senior management of the ACAN as a procurement instrument was not correct since the exception used to support it was not justified. In planning for its procurement needs, it is incumbent on program management to select from permitted mechanisms and provide for sufficient resources, including time, to ensure the procurement process is carried out properly and in compliance with existing policies and procedures. Procurement Services had presented options to management for the procurement of executive-level advisory services, including the “collective fit” considerations tied to forming committees.

c. North American Free Trade Agreement
TB Contracting Policy recognizes that the terms of trade agreements, including the North American Free Trade Agreement (NAFTA), must be satisfied. Under NAFTA regulations, applicable taxes and optional years should be included in calculating the value of the services being procured when determining whether NAFTA applies.

The auditors examined whether the procurements were subject to NAFTA. The MERX abstract showed an estimated value of $50,000 to $100,000, indicating that the procurement for the advisory services fell under NAFTA. Nonetheless, examination revealed certain discrepancies related to NAFTA requirements in the documentation. For instance, Procurement Services' internal procedural checklist indicated the procurement of these services was subject to NAFTA. However, the ACAN published on the MERX system indicated that this procurement was not subject to any trade agreement and, in the same posting, the type of applicable agreement was not identified. Given the content of the published ACANs, potential suppliers could have been confused with regard to the applicability of any trade agreements. These actions and omissions constitute infractions within the meaning of the Agreement.

The risk of these procurement errors was increased due to lack of some internal oversight by the Contract Review Board (CRB). The CRB is charged with ensuring compliance of large contracts with procurement regulations, policies and procedures. Valuation of procurements to be approved by the CRB is based on the initial contract period rather than on the total potential value of the services, i.e., the initial contract period plus any optional period, as required by contracting regulations. Only if an amendment to a contract causes its total value to exceed thresholds set for non-competitive contracts or competitive contracts beyond the NAFTA threshold would the senior CRB member, the Director General of Finance and Administration, be required to review such a contract. This valuation method prevents the full Board from acting as an additional control level to ensure compliance with TB contracting and NAFTA requirements.

With regard to compliance with trade agreements, this procurement process was conducted as though NAFTA applied. However, the information posted regarding the requirements for compliance with trade agreements could have been confusing to users of that information.

Recommendation 1

1.1 To ensure program management properly justifies and communicates its selection of contracting instruments, Procurement Services should ensure management is counselled that:

1. All criteria for the selection of procurement instruments relating to advisory services and internal processes and controls are in compliance with the GCR and TB's Contracting Policy, including terms relating to trade agreements, particularly the NAFTA;
2. The PSC's internal controls are enhanced to ensure accuracy of contract-related postings.

1.2 The Finance and Administration Directorate should amend the Terms of Reference of the CRB to ensure that it processes contracts based on the total potential value of each contract, for compliance with TB's Contracting Policy and NAFTA.

Management response

1.1 a) All procurement staff have been reminded of the requirement to ensure that all exceptions invoked be fully justified by management, in writing, and put in the contracting file and exception 6d) "should be invoked only where patent or copyright requirements are involved rather than just the fact that the potential supplier is the only one known to management". The questions provided in the Annex A to Contracting Policy Notice 2007- 4 must be completed by the client and put in the contracting file. Furthermore, the requirement to complete this form will be included in the new Contracting and Procurement Guidelines that were to be published by the end of December 2010.

1.1 b) All solicitation information posted on MERX (which includes all requirements subject to trade agreements) is now being reviewed by the Chief of Procurement Services to ensure that no administration errors in publishing take place.

Responsibility: Chief, Procurement Services
Timeline: December 2010 and ongoing

1.2 The Finance and Administration Directorate will review the Terms of Reference (ToR) of the CRB to ensure that it processes contracts based on the total potential value of each contract.

Responsibility: Chief, Procurement Services
Timeline: April 30, 2011

Recommendation 2

2.1 PSC senior management should seek guidance from TBS on the procurement mechanisms to use for future similar advisory services, including possible use of contracting authorities under the PSEA.

2.2 Procurement Services should develop a procurement framework related to delegated authorities, based on the response provided by TBS.

Management response

2.1 The Vice-President of the PSC's Corporate Management Branch will consult with TBS procurement specialists on what appropriate mechanisms would be available for similar needs in the future. Section 10 of the PSEA will be among the topics to be discussed.

Responsibility: Vice-President, CMB
Timeline: by March 31, 2011

2.2 Procurement Services will take the necessary steps to enable the decisions made following discussions with TBS, by putting in place any additional or revised procedures, processes, authorities or instruments.

Responsibility: Chief, Procurement Services
Timeline: to be determined, once consultations with TBS are completed.

Control Objective No. 2 – The awarding of the four contracts for the procurement of services of senior-level advisors for the PSC's IAAC was compliant with TB and organizational policies and procedures.

8.2 Advance Contract Award Notice Administration

The Internal Audit Directorate expected procedures followed by Procurement Services in publishing the four Advance Contract Award Notices (ACAN) to be efficient, to provide potential suppliers with the opportunity to demonstrate that they satisfied the requirements set out in the ACANs and to respect the principles of government contracting by being open, transparent and fair.

Examination indicated that the information contained in the ACANs related to the requirements of the contract was complete, relevant and sufficient. Requirements were defined prior to publishing the ACANs and were derived from the Statement of Work and the IAAC ToR. The Statement of Work was based on tasks to be performed by contractors and reflected in the ToR. In compliance with procurement best practices, the published ACANs indicated the period of the proposed contract. Some changes were made to the Minimum Requirement for Experience, prior to the publishing of the ACANs, to make them broader. These modifications were made at the suggestion of Procurement Services to ensure the experience in question had not been obtained through any previous sole-source contract with PSC. This was not to the advantage of the proposed contractors as the modified requirement was more encompassing. The four ACANs were posted for fifteen calendar days on the government's electronic tendering service, the MERX system, in conformity with policy requirements and common practices.

The ACANs included procedures for potential suppliers to respond to this notice by submitting a Statement of Capabilities. The audit found that no such statement was submitted. Furthermore, there were no indications that the ACANs were structured to prevent or discourage submission of Statements of Capabilities from other potential suppliers.

The audit also noted that the proposed suppliers were contacted for administrative purposes and this communication did not result in changes to the ACAN requirements.

In reviewing the procurement files, the auditors noted a series of safeguards to prevent a contract from resulting in an employer-employee relationship.

Examination revealed that information posted on the PSC Web site, according to TB Guidelines on the Proactive Disclosure of Contracts, was complete and accurate for all four contracts. Although the value posted for one of the contracts differed from others by $1,000, this was due to an error in the contract. The contract was amended in March 2010. The disclosure information was corrected in July 2010, after the auditor requested information on this error. Management may want to consider putting in place a simple mechanism to review the information posted on the Internet to ensure it is complete and accurate and, if needed, corrected promptly.

8.3 Governance

It was expected that the respective contracts would be signed in accordance with PSC delegations of authority and TB Contracting Policy approval limits and would be in compliance with regulations concerning the preliminary phases of the contracting activities, including conflict of interest and post-employment. The Internal Audit Directorate (IAD) found that the nature of the services required was in line with the corresponding contracting limits and their value within the threshold established under the Policy.

In accordance with the existing PSC Delegation of Financial Authority, management has exercised its full contracting and financial authority. The commitment was established by the proper financial authority. Approval and confirmation of funds was given by the Vice-President via e-mail and financial authorization was exercised by the appropriate Director General on contract authorization and justification. Although this was done in compliance with the existing procedures, the auditors believe this control could be redesigned. Review of the delegation matrix indicates that procurement officers have no contracting authority. They exercise contracting authority on behalf of the responsibility centre once the request for service has been signed. This arrangement limits the capacity to challenge or influence the authorities exercised by program management. The approval of contract documents had been the object of a recommendation as part of a review of Procurement Services conducted in early 2009.

The auditors examined whether this procurement process allowed the PSC to achieve fair value and to conform with the post-employment dispositions of the Conflict of Interest Act. Each contract was valued at a $21,000 per annum ceiling, for a one-year period renewable up to three times. Based on the evidence, IAD believes that fair value was achieved since the financial value of the requirement was in line with the market rates and based on the level of effort involved in previous similar requirements. The procurement complied with regulations regarding conflict of interest and post-employment of former public servants. Evidence indicated that the potential suppliers in question had been retired for a period of more than one year.

8.4 Documentation - general

Although this is addressed implicitly in several audit criteria, during the review of the procurement files, the auditors expected to find justifications and documentation for decisions made during the various stages of the procurement process.

The key expectation was justification for the use of exception 6d) of the GCR as required by TB Contracting Policy Notice 2007-04. The policy notice was issued in 2007 to provide contracting personnel with additional guidance on the legal obligations associated with government procurement, more specifically when exceptions are raised. Procurement Services failed to request the client to complete Annex A of the Notice as part of this procurement process. This Annex consists of a questionnaire, which covers specifically directed contracts where exception 6d) is invoked and would have provided Procurement Services with a thorough assessment of its compliance with its contracting requirements.

Furthermore, for every service requirement, Procurement Services normally completes an internal checklist enumerating the various steps, considerations and requirements involved in the procurement process. At the end of this process, by signing the checklist, the procurement officer responsible for this activity certifies that all applicable items enclosed in this list have been verified and responded to. Review of the files indicated that the checklist for all four contracts had been filled out but only one had been signed. Partial application of a mechanism such as the checklist raises questions about its pertinence and effectiveness.

In most aspects, the process for the awarding of the ACAN was adequate and compliant with PSC and government policies and regulations. This includes conformity to PSC's delegation of authorities. Publishing of the four ACANs provided potential suppliers with an opportunity to demonstrate if they satisfied the requirements set out in the ACANs, and that these requirements were complete, relevant and sufficient. The auditors noted gaps in the documentation in the procurement files, with the result that corroboration or justification for certain decisions is absent.

Recommendation 3

Procurement Services should keep on file all necessary documents as a matter of record and reference to ensure that:

1. They are complete and compliant with TBS contracting requirements;
2. They provide justification for decisions; and
3. They support tracking of contracting activity.

Management response

Procurement Services staff have been reminded of the importance of keeping all necessary documents on file. Additionally, all important decisions and/or actions not evident in the documents on file will be described in a separate document, such as a note to file.

Responsibility: Chief, Procurement Services
Timeline: December 2010 and ongoing

9. Conclusion

Program management had a limited number of options for the procurement of executive-level advisory services for the Independent Audit Advisory Committee. The auditors determined that rationale for the selection of an Advance Contract Award Notification (ACAN) as the procurement instrument was based on the skill set for the different members of the committee; however, the exception used to support the use of the ACAN was not correct. Furthermore, although the procurement for the services requested was subject to the North American Free Trade Agreement, the audit found that it was not posted as such on the MERX system.

The publishing of the ACAN was transparent and its administration by Procurement Services was, overall, performed in compliance with Public Service Commission (PSC) and Treasury Board policies and regulations. During the planning of the ACANs, the Statement of Work was modified by program management at the request of Procurement Services; these changes were to the benefit of all potential suppliers. Any communication prior to the publication of the ACAN was for administrative purposes and did not constitute an advantage to any potential supplier.

In order to ensure compliance with government and PSC contracting policies and regulations, some internal controls should be reviewed and enhanced to reduce potential risks and improve procurement processes. In planning for their procurement needs, program management should consider the existing contracting mechanisms and their constraints, including allowing the time necessary to execute the procurements properly. More thorough documentation of the procurement files would better support the corroboration and justification of decisions and ensure compliance with government and internal contracting procedures. Finally, the Contract Review Board's role could be reinforced to provide greater review of some contracts.

Management has accepted the audit findings and has provided action plans, which will address the weaknesses noted.

Annex A – Management Control Framework over Procurement of Advance Contract Award Notifications

*M = Met
P = Partially met
N = Not met

Annex B - Glossary

ACAN

Advance Contract Award Notices

ADSB

Audit and Data Services Branch

CMB

Corporate Management Branch

CRB

Contract Review Board

GCR

Government Contracts Regulations

IAAC

Independent Audit Advisory Committee

IAD

Internal Audit Directorate

NAFTA

North American Free Trade Agreement

OPO

Office of the Procurement Ombudsman

PSC

Public Service Commission

RFP

Request for Proposal

TB

Treasury Board

TBS

Treasury Board of Canada Secretariat

ToR

Terms of Reference

PSEA

Public Service Employment Act