Audit of Indigenous Intervention Centres March 1, 2024

List of acronyms

List of acronyms
A4D
Assessment for Decisions
ACCOP
Assistant Commissioner, Correctional Operations and Programs
CCRA
Corrections and Conditional Release Act
CCRR
Corrections and Conditional Release Regulations
CD
Commissioner's Directive
CSC
Correctional Service Canada
DCIC
Deputy Commissioner of Indigenous Corrections
ETA
Escorted Temporary Absence
ICAF
Indigenous Corrections Accountability Framework
ICDO
Indigenous Community Development Officers
IIC
Indigenous Intervention Centres
IICPM
Indigenous Integrated Correctional Program Model
IIS
Indigenous Initiatives Sector
ISH
Indigenous Social History
KPI
Key performance indicators
OCI
Office of the Correctional Investigator
OMS
Offender Management System
NHQ
National Headquarters
NIP
National Indigenous Plan
OAG
Office of the Auditor General
RHQ
Regional Headquarters

Alternative format

Background

Indigenous offenders

The introduction of the Corrections and Conditional Release Act (CCRA) in 1992 redefined the relationship between CSC and Indigenous peoples.

According to the 2021 Canadian census, the Indigenous population, represents 5% of the Canadian population. Indigenous people continue to be overrepresented in CSC’s institutions, as of July 2023 they represent 32% of CSC’s incarcerated population.

One of CSC's corporate priorities is to address the overrepresentation of Indigenous offenders by providing effective culturally appropriate interventions and reintegration support for First Nations, Metis and Inuit offenders. 

 

Offenders in Correctional Service Canada custody (2023)
Region Number of inmates at CSC institutions Number of Indigenous inmates at CSC institutions Percentage of Indigenous inmates at CSC institutions Number of Indigenous Intervention Centre flagged offenders at CSC institutions Percentage of Indigenous offenders who are flagged IIC
Atlantic 1,271 260 20% 32 12%
Quebec 2,941 462 16% 23 5%
Ontario 3,762 776 21% 143 18%
Prairies 3,853 2,176 56% 470 22%
Pacific 1,688 655 39% 65 10%
Grand total 13,515 4,329 32% 733 17%

Source: PRIME-RADAR (extracted July 2023)

National Indigenous Plan

Office of the Auditor General report

In 2016, the Office of the Auditor General (OAG) published an audit on Preparing Indigenous Offenders for Release, identifying a number of areas for improvement and recommendations for CSC.

Key areas of concern noted:

The National Indigenous Plan

In response to the 2016 OAG report, CSC developed the National Indigenous Plan (NIP) which incorporates many actions identified in the report, as well as the advice and guidance from the National Indigenous Advisory Committee (Annex D).

The NIP provides a national framework to transform Indigenous case management and corrections with an Indigenous first approach through enhancing various policies, operations and practices to better meet the needs of Indigenous offenders.

The NIP includes streamlining existing Indigenous resources and services to ensure that Indigenous offenders have earlier access to parole and Indigenous interventions. Key components of the NIP include:

The 2022 OAG Systemic Barriers's report included many areas from their 2016 audit and revealed that many areas for concern are still relevant 5 years later. 

Indigenous Intervention Centre (IIC)

What is an IIC

An IIC is an intake assessment and intervention centre. IIC’s are available in 12 institutions (Annex B), including 4 of the 5 women sites and is being implemented in the last women’s site.

IIC objectives

The NIP defines the IIC objectives as: to better coordinate and utilize the limited Indigenous resources that exist, while at the same time ensuring access to Indigenous programs during the intake process to not delay program completion, ensuring access to section 84 release planning, where an offender is released into an Indigenous community, and reintegration options earlier in their sentence, with the support of the community.

Ultimately, IICs will maximize existing resources, will create case management teams with specialized training, and will lead to increased transfers to lower security and conditional release.

IIC criteria

An offender must meet the following criteria in order to participate in the Indigenous Intervention Centres:

If an offender meets the IIC criteria and wants to participate in the IIC then there is a flag that is activated in their file in the Offender Management System (OMS). Only 17% of indigenous offenders are currently flagged as IICFootnote 1 .

Audit objectives and scope

Audit objectives

Objective 1

To provide assurance that a management framework is in place and supports the effective and efficient management of the Indigenous Intervention Centres.

Objective 2

To provide assurance that CSC is complying with key areas identified as being required for IIC offenders to successfully reintegrate earlier in their sentence.

Objective 3

To provide an assessment on CSC’s progress made on previous commitments applicable to the IICs.

Scope

The audit is national in scope and includes sites in all 5 regions, as well as Regional Headquarters and National Headquarters.

Approach

Interviews

158 interviews were conducted with management and staff who are involved with IICs at national, regional and site levels, as well as parole offices.

Review of documentation

A review of relevant documentation, such as:

File review and testing

121 offender files were reviewed from fiscal years 2020 to 2023 to provide assurance that CSC is in compliance with policies and guidelines applicable to the IICs.

Audit observations

Governance and guidance to support IICs

In order to allow for the consistent implementation of IICs across the country, the audit team expected to find that CSC has defined and communicated strategic objectives, an IIC framework, as well as policy direction and guidance material specific to IICs and oversight.

Finding

Although strategic objectives for IICs and an IIC framework have been defined and training has been developed to support this, there is a need to increase staff awareness and understanding to support the consistent implementation of IICs across the country, as well as the oversight and daily operations of IICs.

Strategic objectives

Strategic objectives for IICs are defined in the NIP and have been communicated to staff through a variety of mechanisms, such as the national IIC training and through informal communication. As a result, CSC staff have a general understanding of the IIC objectives.

Guidance material

IICs are managed through existing CDs and guidelines, however, current CSC policies do not reference the IIC approach to case management. It is not clear to regions and sites that this is the expectation. Guidance specific to IICs has been incorporated into the NIP, an Offender Management System (OMS) bulletin, and national IIC training. CSC has developed IIC eligibility criteria contained in the OMS bulletin which key stakeholders generally feel are clear and understood. However, concerns were raised with not being allowed to remove the IIC flag in OMS once activated (as directed in OMS bulletin) and criteria being too restrictive with the level of programming.

Oversight

Direction on how existing case management processes can be utilized to support the consistent establishment, implementation, management and oversight of IICs has not been sufficiently developed and communicated to meet regional and site needs. As a result, it is unclear to regions and sites who is to provide the oversight function. This has led to the inconsistent implementation and management of IICs across all regions.

These inconsistencies include:

There is limited evidence found demonstrating that IIC performance indicators are being discussed within senior management committees.

IIC framework

The IIC framework has been defined at a high level through the NIP and the national IIC training.

IIC plans were created within each region, however regional and site staff are not aware of these plans. Therefore, there is an inconsistent understanding of what exactly the IIC framework is and how it functions.

IIC plans are plans to implement the IIC concept in the regions for the centralization of Indigenous intake assessment and programming (including Indigenous specific interventions and resources realignment) in order to ensure timely pre-release case preparation for Indigenous offenders.

Impact

Due to the confusion around the policy and guidance framework to support IICs, IIC sites across the regions vary in their implementation, management and daily operations of IICs. Furthermore, 1 designated IIC site was not yet operating as an IIC site.

Roles and responsibilities related to IIC

The audit team expected to find that roles and responsibilities for staff supporting and overseeing IICs, as well as working with IIC flagged offenders are defined, documented, communicated and understood.

Finding

While roles and responsibilities are defined for case management staff involved with IICs, they are not clearly communicated, and understood for all key internal stakeholders involved in the operations, management, and oversight of IICs leading to the inconsistent implementation of IICs.

National IIC training

Roles and responsibilities for staff working in the IICs and/or supporting IIC flagged offenders are primarily defined in the national IIC training. However, most of the roles and responsibilities in the IIC training relate to Indigenous offenders as a whole and are not specific to IICs. Roles and responsibilities for key positions related to the establishment, oversight, and management of IICs are not defined, nor are the roles and responsibilities for key activities, such as reviews against the IIC criteria and IIC flag activation in OMS which are not clearly assigned to a position.

As of May 2023, 84% of CSC staff (at NHQ, RHQ, and site levels) have completed the training, however 79% of interviewees felt that the training was insufficient to complete their roles and responsibilities related to IICs. In addition, not all staff working in an IIC and/or supporting IIC flagged offenders are required to take the IIC training, for example: Correctional Program Officer and Indigenous Community Engagement Coordinator amongst others.

Overall, interviewees indicated that their roles and responsibilities do not differ whether they are working with an IIC offender or an Indigenous offender.

IIC coordinator

The IIC Coordinator is the only position that is consistently dedicated to the IICs across all regions. There is an IIC Coordinator in all regions. At the time of the audit, work descriptions for IIC coordinators have been developed in all 5 regions however, they are still in draft form and have not been communicated to the IIC Coordinators.

Impact

A lack of communication and awareness amongst staff that existing case management policies remain applicable for the roles and responsibilities of key IIC positions has led to inconsistent implementation and management of IICs, including 1 designated IIC site not yet operating as an IIC site, differences in prioritization of programs and resources dedicated to IICs; as well as an inability to determine if IICs are meeting all objectives.

Performance measurement strategy for IICs

The audit team expected to find that CSC has a performance measurement strategy in place to monitor and report on the IICs to inform decision making.

Finding

Performance Indicators have been established for IICs, however there is room for improvement in how strategic and operational performance indicators are established, communicated and used.

Performance measurement strategy

Key performance indicators (KPIs) that guide the assessment of results for IICs have been established and are documented in the NIP and additional IIC data is available through other sources. However, not all staff working with IIC flagged offenders or supporting IICs (at regional and site levels) are aware of the KPIs for IICs and limited evidence of those KPIs being discussed at the senior level was found.

Nationally

At a national level, data on IICs is gathered through the NIP Reporting Tool, Performance Direct and RADAR Prime. Monitoring information related to IICs is analyzed and reported, as part of the NIP’s performance measurement strategy, through the annual Indigenous Corrections Accountability Framework (ICAF) report, which is presented at the EXCom Sub-Committee on Indigenous Corrections (Annex D). However, the following challenges exist with the ICAF report:

Regionally

Monitoring of IIC flagged offenders at the regional level varies between regions and is completed on an ad hoc or periodic basis. However, the Regional Administrators at only 2 of the 5 regions indicated that monitoring information is being used to inform decision-making, but none of the IIC Coordinators shared this opinion.

Site level

Only 4 of 11 IIC sites selected for this audit are monitoring IIC flagged offenders in various manners.

Impact

While elements of a performance measurement strategy exist, due to the concerns listed above and the inconsistent utilization of the performance indicators, senior management's ability to monitor IICs objective achievement and make informed decisions on the management of IICs could be improved.

Resourcing for IICs

The audit team expected to find that infrastructure, financial, and human resources are in place to assist in the successful implementation and operation of the IICs.

Finding

A full analysis has not been completed on resources (infrastructure, human and financial) required to implement and operate IICs across all regions, nor the impact IICs may have on the workload of certain positions and capacity to deliver other programs.  There are concerns with the sufficiency of resources in place to support the IICs.

Financial

Based on an EXCom decision, IICs were not to receive any additional funding but rather regions were to use existing Indigenous funding to fund IICs. As a result, there is no dedicated funding for IICs. Due to the lack of a project code specific to IICs, CSC is unable to easily complete an analysis of the amount of funding used for IICs and whether this funding is sufficient.

Infrastructure

Four out of 5 regions did not provide an analysis on infrastructure needs for IICs, however 7/11 of the IICs selected stated that they have the physical space they require for IICs.

Human resources

An analysis of human resource requirements at the national and regional levels was not completed; this is primarily due to a lack of clear understanding as to who is responsible for HR planning for IICs.

Seven out of 11 IIC sites raised concerns around the sufficiency of resources in place to support the IICs. Ten out of 11 IIC sites selected do not have the full complement of Indigenous resources (Elders, Elder helpers, Indigenous Liaison Officers, and Correctional Program Officers) that they are resourced for. Furthermore, the majority of IIC sites do not have staff dedicated to IICs.

Impact on workload and delivering programs

No analysis was found on the impact IICs may have on CSC’s capacity to deliver other programs or on staff workloads.

Impact

While the program was originally intended to be cost neutral, the lack of an infrastructure, human resources, and financial analysis limits the information available to support strategic decision making for IICs and increases the risk that sites may not be able to provide the required level of services to help ensure the achievement of IIC objectives.

Past recommendations from the OAG and Office of the Correctional Investigator (OCI)

OAG recommendations

CSC has fully implemented 8 of the 9 action items related to IICs, included in the Management Action Plan in place to respond to the recommendations in the 2016 OAG report.

This outstanding action item is related to Indigenous Community Development Officers (ICDO), where the deliverables are:

OCI recommendations

OCI related recommendations led to 2 IIC action items for CSC.

Internal Audit performance results

Time to first program

Of the 259 IIC offenders who enrolled in moderate or hybrid programs during fiscal year 2022 to 2023, IIC offenders waited almost 5 months, on average, to start a moderate and/or hybrid program after admission to a federal institution.

Access to culturally-specific programs

Of the 259 IIC offenders who enrolled in moderate or hybrid programs during fiscal year 2022 to 2023, 88% took an Indigenous moderate or hybrid program.

Program completion prior to first parole eligibility date

The audit team found that 29% (33/114) of all IIC flagged offenders in fiscal year 2022 to 2023 who required correctional programs completed a main program prior to their first parole eligibility date.

The IIC offenders at the men sites were approximately half as likely than that of the women sites to have completed a main program prior to their first parole eligibility date.

Security reclassification within 30 days of program completion

The audit team reviewed a sample of 36 IIC offenders' files from January 2020 to August 2023 and found that the offenders had a security reclassification review on file, however, 61% of these files had their security reclassification review completed within the required timeframe of 30 days after the program report date.

Release documents prepared prior to first parole eligibility date

The audit team reviewed a sample of 28 IIC offender files from fiscal year 2022 to 2023 and found that 54% had their conditional release documents prepared prior to their first parole eligibility date.

Indigenous Social History (ISH)

All of the Assessment for Decisions (A4D) reviewed in relation to IIC offender’s release plans had ISH taken into consideration.

The ISH was taken into consideration to some extent in security reclassification decisions in all of the files, however, 53% of these files included ISH in all 3 areas of the A4D (Institutional Adjustment, Public Safety Risk, and Overall Assessment) as required by policy.

Audit results
see text description below
Text description

This chart depicts the following audit results discussed earlier:

  • Program completed prior to first parole eligibility date (FY 2022 to 2023) - 29%
  • Access to cultural programs (FY 2022 to 2023) - 88%
  • Release documents prepared prior to first parole eligibility date (FY 2022 to 2023) - 54%
  • Security reclassification review within 30 days of program completion (Jan 2020 to Aug 2023) - 61%

COVID-19 impact on IICs

Finding

COVID-19 has had an impact on the implementation of IICs, as well as several areas related to IICs.

Impact on IICs

COVID-19 had profound impacts on the ability of CSC to provide services in the institutions. Therefore, as much as possible the audit team tried to move away from the COVID-19 timeframe, however, it was not always possible. The data for the project includes our sample timeframe for clarity. As a result, the auditors were able to collect some information and provide some observations with regard to the impact COVID-19 had on IICs.

According to interviewees, COVID-19 has had an impact on the implementation of IICs, as well as in areas related to IICs such as cultural activities (including ETAs, ceremonies, etc.) being suspended, limited access to Indigenous staff/resources and challenges with the availability of Indigenous staff/resources, delays in program delivery due to restrictions and decrease in classroom sizes, and limited community outreach.

Communicating with Indigenous communities was difficult, communities were worried about inmates being released and spreading COVID, some communities were completely isolated or shut down and would not let offenders into their community.

ICDOs in all regions expressed challenges with engaging with the community during COVID.

Audit conclusion

CSC has implemented parts of a management framework for IICs, however, there are still areas that need to be addressed in order for IICs to be fully implemented and consistently established within CSC institutions. Such areas include clearly setting and communicating direction on how existing case management practices can incorporate IICs, oversight accountability, roles and responsibilities, monitoring and reporting of key performance indicators as well as completing a resource requirement analysis.

CSC is currently unable to fully assess whether IICs are achieving their objectives to their full potential due to the gaps in the management framework.

Although CSC has made progress for IIC flagged offenders on the areas of concern raised by the OAG, IIC offenders represent only 17% of the total incarcerated Indigenous population, while Indigenous offenders continue to be overrepresented in CSC institutions.

Recommendations and management response

Recommendation 1

The Deputy Commissioner of Indigenous Corrections should review the IIC performance to ensure that IICs are having an impact on addressing the overrepresentation of Indigenous offenders and identify risks and best practices to improve overall results. This review should identify areas of improvement (training, communication, reporting etc.) and the development of a plan for implementation.

Management response

We agree with this recommendation. The DCIC will integrate IIC performance reporting in the Indigenous Initiatives Sector (IIS) Quarterly Results Report and will begin reporting with IIC indicators in the first Quarterly Report for Fiscal Year 2024 to 2025 scheduled for July 2024. Upon completion of 1 full Fiscal Year (2024 to 2025) of data:

  1. A review will be completed and identification of areas of improvement will be conducted
  2. A plan of action to address areas of improvement will be completed in collaboration with ACCOP

Recommendation 2

The Deputy Commissioner of Indigenous Corrections should ensure that guidance material, key information related to IICs, such as the IIC process, roles and responsibilities, accountability, and oversight are clearly communicated with an updated communication strategy and stored in a way that is easily accessible to all staff.

Management response

We agree with this recommendation. By December 2024 the DCIC and ACCOP will finalize and communicate an updated IIC National Handbook.

  1. A communication strategy will be developed for sharing key information related to IIC initiative
  2. Updated information will be developed to ensure clear understanding of roles and responsibilities, accountability and oversight
  3. Information will be made available to all staff through posting on the HUB

Recommendation 3

The Deputy Commissioner of Indigenous Corrections should complete an analysis of resources needed to support implementation and ongoing delivery of IICs at the site level, including human resources, operational funding and infrastructure.

Management response

We agree with the intent of this recommendation. By December 2025, the DCIC will have completed the following actions in close collaboration with ACCOP:

  1. Outline the resource structure needed to support the IIC model and include this in the National IIC Handbook
  2. Work closely with ACCOP to ensure the IIC model is appropriately resourced as per initial EXCOM direction to reallocate existing resources
  3. RDC’s will report back to the DCIC and ACCOP to attest that resource requirements needed to support the IIC model are in place
  4. Tech Services will conduct a review of all dedicated indoor and outdoor spaces for Elders in consultation with the RDCs, to ensure appropriate infrastructure is in place to support the IIC model

Recommendation 4

The Deputy Commissioner of Indigenous Corrections should ensure that the performance measurement strategy measures the progress of IIC offenders in comparison to other populations, using relevant performance indicators and addresses concerns raised in previous OAG audits.

Management response

We agree with this recommendation and the actions identified in Recommendation 1 will address these areas. The Indigenous Corrections Accountability Framework (ICAF) is also measuring these results on a yearly basis and the report is publicly available.

Annexes

Annex A: Audit objective and audit criteria

Objective 1

To provide assurance that a management framework is in place and supports the effective and efficient management of the Indigenous Intervention Centres.

Criteria (Objective 1)

1.1 CSC has defined and communicated strategic objectives and has a framework is in place for the IICs.

Audit assessment partially met.

1.2 Commissioner’s Directives, guidelines and manuals are clear, support the management of IICs and comply with applicable legislation.

Audit assessment partially met.

1.3 Roles and responsibilities are defined, documented, communicated and understood. Audit assessment partially met.

1.4 CSC has a performance measurement strategy in place to monitor and report on the IICs.

Audit assessment partially met.

1.5 Infrastructure, financial and human resources are in place to assist in the successful implementation of the IICs.

Audit assessment not met.

Objective 2

To provide assurance that CSC is complying with key areas identified as being required for IIC offenders to successfully reintegrate earlier in their sentence.

Criteria (Objective 2)

2.1 CSC is in compliance with policies and directives for the IIC admission criteria.

Audit assessment met with exceptions.

2.2 IIC offenders are being prioritized in the assignment of programs and are having their cases reviewed within the established timeframes following the completion of their program.

Audit assessment partially met.

2.3 CSC is preparing IIC offenders for release in accordance with relevant policies and guidelines.

Audit assessment partially met.

2.4 CSC is in compliance with relevant policies requiring that an offender's Indigenous Social History be taken into consideration for decisions taking place while an offender is part of the IIC.

Audit assessment partially met.

Objective 3

To provide an assessment on CSC’s progress made on previous commitments applicable to the IICs.

Criteria (Objective 3)

3.1 CSC has implemented their commitments related to the IICs, in response to the recommendations within the Office of the Auditor General 2016 Audit of Preparing Indigenous Offenders for Release and various Office of the Correctional Investigator reports.

Audit assessment partially met.

Annex B: Sites selected for the audit

Atlantic region

Sites

Quebec region

Sites

Ontario region

Sites

Prairies region

Sites

Pacific region

Sites

* Bolded sites are designated IIC sites.

Annex C: Legislation and policy framework

Although, there are no legislative or policy requirements specific to the IICs or IIC flagged offenders, there are sections of the Corrections and Conditional Release Act (CCRA), Corrections and Conditional Release Regulations (CCRR) and Criminal Code of Canada which are applicable, such as:

CSC policy framework

CSC does not have a specific policy for the IICs, however, a number of CD’s and Interim Policy Bulletins contain requirements that are applicable to Indigenous offenders who would be part of the IIC as the IICs cover an offender throughout most of their sentence.

Annex D: CSC’s national committees related to IICs

Committee: Sub-Committee on Indigenous Corrections

Purpose

The Sub-committee on Indigenous Corrections provides strategic analysis, horizontal advice, and recommendations to EXCOM on issues relating to effective, culturally appropriate interventions and reintegration support for First Nations, Métis and Inuit offenders. The Sub-committee will guide and monitor the strategic direction for Indigenous Corrections, and will ensure EXCOM is informed and engaged on Indigenous priorities and issues, as well as national and regional performance results.

Chaired by

Senior Deputy Commissioner.

Membership

Key Senior Managers:

Frequency of Meetings

Bi-monthly.

Committee: National Indigenous Advisory Committee

Purpose

To further reconciliation between Indigenous peoples and the Correctional Service of Canada, the Committee will provide a forum for providing advice and recommendations to the Commissioner on the provision of correctional services to Indigenous offenders.

Chaired by

Commissioner.

Membership

The Committee shall consist of Indigenous community leaders, selected by the Commissioner, who combined, provide a balanced community perspective on Indigenous corrections.

Frequency of Meetings

Minimum 2 meetings per year.

Annex E: Statement of conformance

This internal audit engagement was conducted in conformance with the International Standards for the Professional Practice of Internal Auditing, the Treasury Board of Canada Policy on Internal Audit, and the Treasury Board of Canada Directive on Internal Audit, as supported by the results of the Quality Assurance and Improvement Program of Correctional Service Canada.

Daniel Giroux, CIA

Chief Audit and Evaluation Executive

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