Follow-Up of the Office of the Auditor General of Canada’s Audit of Providing Relocation Services
Table of Contents
- Acronyms and Abbreviations
- Statement of Conformance
- Why the Follow-Up Occurred?
- Going Forward – New Contract
- CFIRP Management within DND/CAF
- Strong, Secure, Engaged - Impact on CFIRP
- What is the CFIRP?
- What does the CFIRP offer?
- Follow-Up Objective, Scope & Methodology
- Follow-Up Criteria
- Management Action Plan Implementation Assessment Summary
- Finding - FAA S.34 Compliance and Sampling Methodology
- Findings - Performance Measures & Accountabilities
- Overall Conclusion
- Recommendations
- Management Action Plan
- Annex A – Detailed Action Plan for OAG Report Recommendations
- Annex B – Move Type Definitions
- Annex C – MAP Assessment Criteria
- Annex D – Potential Data Analysis
Alternate Formats
Assistant Deputy Minister (Review Services)
- ADM(Fin/CFO)
- Assistant Deputy Minister(Finance/Chief Financial Officer)
- ADM(RS)
- Assistant Deputy Minister (Review Services)
- BGRS
- Brookfield Global Relocation Services
- CAF
- Canadian Armed Forces
- CFIRP
- Canadian Armed Forces Integrated Relocation Program
- DND
- Department of National Defence
- DRBM
- Director Relocation Business Management
- FAA
- Financial Administration Act
- FAM
- Financial Administration Manual
- FY
- Fiscal Year
- MAP
- Management Action Plan
- MILPERSCOM
- Military Personnel Command
- OAG
- Office of the Auditor General of Canada
- OCI
- Office of Collateral Interest
- OPI
- Office of Primary Interest
- RCMP
- Royal Canadian Mounted Police
- S.34
- Section 34 of the FAA
- SSE
- Canada’s defence policy: Strong, Secure, Engaged
- TPSP
- Third Party Service Providers
Figure 1 Details - Move Type and Cost (FY 2016/2017)
Figure 2 Details - Top 5 Transaction Categories (FY 2016/2017)
Figure 3 Details - Follow-Up Criteria
Table 1 Details - Management Action Plan Implementation Assessment Summary
Recommendation 1
Recommendation 2
Recommendation 3
Management Action Plan
ADM(RS) uses recommendation significance criteria as follows:
- Very High—Controls are not in place. Important issues have been identified and will have a significant negative impact on operations.
- High—Controls are inadequate. Important issues are identified that could negatively impact the achievement of program/operational objectives.
- Moderate—Controls are in place but are not being sufficiently complied with. Issues are identified that could negatively impact the efficiency and effectiveness of operations.
- Low—Controls are in place but the level of compliance varies.
- Very Low—Controls are in place with no level of variance.
ADM(RS) Recommendation 1 (Moderate Significance)
It is recommended that MILPERSCOM develop and implement an ADM(Fin)/CFO approved relocation transaction review methodology for daily and annual monitoring.
Management Actions
With regards to FAA S.34 adherence – DRBM has already engaged and will pursue/collaborate with Director of Financial Business Processes & Transformation to update the methodology regarding the account verification process for transactions reconciled under the Relocation Program. This will be included in DRBM's standard operating procedures and quality assurance program.
Target date: September 2019 (end of annual posting season)
In addition to the previously increased daily verifications from 15 to 30 transactions, the number of daily verifications will further be increased to 45 transactions. Improvements in the statistical data collection will also be pursed to provide better range for trend analysis.
Target date: April 2019
- 100 percent TPSPs are still reviewed to ensure rates are within the pre-negotiated rates.
- Annual review of 250 completed relocation files by analysts from previous FY.
- Ensure that each contracted expense categories are reviewed on a weekly basis (if expense transactions are available).
- DRBM will data mine statistical information and leverage the results to better identify and follow up on trend analysis.
Target date: September 2019 (end of Annual Posting Season)
* Analysis continues but would improve with the filling of the vacant AS-03 position – target: analytics focus.
OPI: MILPERSCOM
OCI: ADM(Fin)/CFO
Target Date: September 30, 2019
ADM(RS) Recommendation 2 (Moderate Significance)
It is recommended that MILPERSCOM identify performance metrics and leverage available relocation transaction information:
- for year over year CFIRP analysis and decision making;
- to measure the effectiveness of the CFIRP;
- to better indicate to BGRS which areas of the CFIRP members could benefit from improved communication, awareness and clarity; and
- to help ensure the consistent provision of benefits to all members in accordance with the policy.
Management Actions
Sample methodology is based on move type. The result of the data collection and analysis will be improved to ensure the consistent application of the Relocation Directive. DGCB/DRBM will utilize four complimentary methods of analysis and the results will identify where efforts are required to ensure consistent provision of service. Analysis will comprise:
- Daily monitoring of relocation transactions to identify potential observations/misapplication of benefits and track applicable observation trends;
- Annual monitoring of completed relocation files to identify potential observations, misapplication and/or underutilization of benefits for which the member may have been entitled;
- Data analytics to perform periodic trend analysis to track the utilization of various benefit categories and attempt to determine root causes of potential anomalies or outliers; and
- Review benefit linkages (e.g., home purchase and home inspection) to ensure members are aware of entitled benefits and will follow up and take action as required.
Target date: September 2019 (end of annual posting season)
DGCB/DRBM will ensure that the results from these monitoring mechanisms are incorporated into decision-making processes about the CFIRP and/or to improved communication to members, BGRS, Director Military Careers/Career Managers, and other relevant stakeholders.
OPI: MILPERSCOM
Target Date: September 30, 2019
ADM(RS) Recommendation 3 (Moderate Significance)
To help ensure the consistent provision of relocation benefits to CAF members, following the identification of the monitoring requirements (daily and annual), and the performance information/data analytics needed, it is recommended that MILPERSCOM conduct an analysis to determine its long-term resource and capacity needs.
Management Actions
Once account verification requirements and trend analysis processes have been completed, a resourcing strategy will be developed. This will include consideration of military, civilian, and/or temporary resources to meet operational needs. A plan will also be developed to ensure succession to account for normal turnover.
OPI: MILPERSCOM
Target Date: September 30, 2019
Annex A – Detailed Action Plan for OAG Report Recommendations
OAG Recommendation | DND Response | Description of Final Expected Outcome/Result |
---|---|---|
The CAF should improve its process to ensure that payments made under the CFIRP are appropriate and meet all the requirements of S.34 of the FAA. |
Agreed. MILPERSCOM staff will complete an examination of the management control framework governing the current process in place for the CFIRP to determine where improvements could be made to address all of the requirements of S.34 of the FAA. In particular, the suitability of the sampling plan in place will be examined. The requirements of DND financial policy will also be reviewed to ensure that it provides appropriate guidance with respect to relocation transactions |
The FAM has been updated indicating that for the purposes of the assessment of risk, relocation claims are deemed low-risk transactions which will allow account verification to be completed on a post payment basis. In support and in compliance with the Treasury Board Policy on Internal Control, the ADM(Fin)/CFO will work with MILPERSCOM to document and evaluate the design effectiveness of the internal controls over financial reporting in the relocation program, including manual, compliance, access and application controls. This work, to commence in FY 2015/16 by ADM(Fin)/CFO, will assist MILPERSCOM in assessing and improving the Department's financial controls and processes surrounding S.34 Account Verification and quality assurance in the CFIRP. |
The CAF should make better use of the results of its reviews so that there is a consistent provision of benefits to all members in accordance with the policy. |
Agreed. The results of the data collection and analysis will be further leveraged to ensure the |
The directorate responsible for the CFIRP has changed the methodology for tracking observed discrepancies in relocation files and post payment verifications so that issues can be analyzed by policy application. This will allow for increased oversight and prompt corrective action so as to ensure the consistent application of policy to all CAF members being relocated. Five additional civilian positions have been requested as the directorate is reorganized to address the additional oversight and analyses. |
Table A-1 Details - Action Plan for OAG Report Recommendations
Table A-1 Summary:
The OAG Recommendations are indicated in the left-hand column. For each recommendation read across the row to determine the DND Response and the Description of Final Expected Outcome/Result.
Annex B – Move Type Definitions
Posting: Regular Force members who are posted, and Reserve Force members who accept a period of Class "B" or "C" service employment, who are also authorized to move their Household Goods and Effects from one place of duty to another only when the new residence is at least 40 kilometres closer to the new place of duty than the current residence.
Release (Move to intended place of residence on release): The place at which a CAF member intends to reside following a release or transfer from the Regular Force. Eligibility of members is based on the period of continuous Regular Force service and the associated release reason. Benefits are generally the same as provided to postings.
Service Couples: Relocation of two spouses or two common-law partners, both of whom are CAF members and both of whom are posted. Benefit application is dependant on whether each member of the service couple is posted to the same geographical area.
Move from Place of Enrollment: Relocation entitlements, limitations and enhancements applicable to Regular Force members on their first authorized move from place of enrolment (after graduation from military or the CAF paid for civilian university/after successful completion of officer/trade/occupation training/qualification).
Imposed Restriction: Intended to be a short-term option to mitigate potential conflict between military service and family obligations. These moves provide an option for members who are posted to proceed unaccompanied to a new place of duty and constitute an approved delay in moving dependants, Household Goods and Effects for a specific period of time.
Other moves:
- Unaccompanied: When accommodations have not been secured or they are not available prior to Call On Strength or Report For Duty, CAF members, who intend to relocate their dependants and/or Household Goods and Effects to the new location, may proceed unaccompanied to the new place of duty on a restricted basis for a maximum period of six months.
- Isolated post: Members posted to isolated locations identified in Appendix A of the Isolated Post and Government Housing Directive (March 1, 2017).
- Local Move: a relocation of 40 kilometres or less, measured using the shortest normal route available to the public, from a person's current residence to their intended place of residence.
Annex C – MAP Assessment Criteria
Status
- Obsolete or Superseded. Audit recommendations that are deemed to be obsolete or have been superseded by another recommendation.
- No Progress or Insignificant Progress (0-24% complete). No action taken by management or insignificant progress. Actions such as striking a new committee, having meetings and generating informal plans are insignificant progress.
- Planning Stage (25-49% complete). Formal plans for organizational changes have been created and approved by the appropriate level of management (at a sufficiently senior level, usually at the Executive Committee level or equivalent) with appropriate resources and a reasonable timetable.
- Preparation for Implementation (50-74% complete). The entity has begun necessary preparation for implementation, such as hiring or training staff, or developing or acquiring the necessary resources to implement the recommendation.
- Substantial Implementation (75-99% complete). Structures and processes are in place and integrated in some parts of the organization, and some achieved results have been identified. The entity has a short-term plan and timetable for full implementation.
- Full Implementation (100% complete). Structures and processes are operating as intended and are implemented fully in all intended areas of the organization.
Annex D – Potential Data Analysis
Analysis of Departing and Destination Cities
The preliminary information shown could be analyzed further to:
- determine if there is equal application of benefits at various locations (i.e. if one location has limited use of a certain benefit it could be possible that the advisor responsible for that location is not aware/informing members of this benefit);
- identify those locations that have higher or lower than average relocation expenditures (further breakdown by type/code);
- determine if there are any "same city" moves and if so, are costs and circumstances reasonable.
Figure D-1 Details - Annual Average Number of Relocations (2010-2015)
Analysis of TPSP Expenditures with Pre-Negotiated Rates
The preliminary information shown could be analyzed further to:
- compare trends of these types of transactions on an annual basis and/or by location to determine if there are any anomalies (e.g., costs exceeding rate maximums) and their potential maximums;
- identify any potential benefits that may be over or under used for particular move types.
Figure D-2 Details - TPSP Benefit Expenditures with Pre-Negotiated Rates.
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