ESDC Management Action Plan: Audit of Canada Pension Plan Disability

General Comment

Employment and Social Development Canada is committed to ensuring the Canada Pension Plan Disability (CPPD) program continues to be responsive to the needs of Canadians. To accomplish this, CPPD program renewal is included in the Canada Pension Plan Service Improvement Strategy (CPP SIS) being developed as part of a broader agenda to modernize the delivery of its employment and pensions benefit programs. The CPP SIS is a comprehensive, phased plan, being developed with partners that will transform program delivery to ensure it is adaptable, innovative and cost-effective.

The CPP SIS will begin with a renewal of the CPPD program, using as fundamental principles: quality and consistency of decisions, efficiency, and service excellence for Canadians. To achieve successful renewal of the CPPD program, the Department will launch an integrated project plan with specific initiatives phased over the short-, medium- and long-term with clear governance mechanisms. Short-term foundational improvements to the CPPD program will enable longer term transformation projects intended to produce a well-functioning, high quality, e-accessible program that meets the needs of Canadians. By March 2018, the Department will identify, develop and begin to implement improvements to the CPPD program through consultations with partners and in-depth assessment of options, tools, and business processes.

The long-term approach of the CPP SIS is one of continuous improvement and maximizing the use of technology, with an emphasis on electronic services and automation to simplify processes and increase efficiency. As the Department pursues its modernization agenda, it will incorporate the recommendations of the Auditor General’s report to ensure that the objectives of the Government and the expectations of Canadians are achieved.

Recommendations

Paragraph 6.33

Employment and Social Development Canada should assess ways to streamline and simplify the initial application process for the Canada Pension Plan Disability program.

Management Response

Agreed. Employment and Social Development Canada is committed to ensuring that the Canada Pension Plan Disability (CPPD) program continues to be responsive to the needs of Canadians. To accomplish this, the Department is developing a Canada Pension Plan Service Improvement Strategy, which will include the CPPD program, as part of a broader agenda to modernize its employment and pensions benefit programs. The strategy is a comprehensive, phased plan, being developed with partners that will transform program delivery to ensure it is adaptable, innovative and cost-effective. The long-term vision of the strategy is one of continuous improvement and of maximizing the use of technology, with emphasis on electronic services and automation to simplify processes and increase efficiency. As the Department pursues this modernization agenda, it will incorporate the recommendations of this report to ensure the objectives of the Government and the expectations of Canadians are achieved.

Through the strategy, the Department will assess ways to leverage new system functionalities to streamline and simplify the application process for the CPPD program, including the potential to offer online access to components of the application process. The Department will complete this assessment by June 2016.

Action Plan

Processing and Payment Services Branch (PPSB), in consultation with Income Security and Social Development Branch (ISSDB) will examine options to streamline and simplify the application process for the CPPD pension, which will include:

• leveraging systems functionalities of the My CPP Retirement application and the My Service Canada Account, to provide a fillable electronic form that could be submitted online;
• pre-screening applications for eligibility based on earnings and contributions before requesting medical reports; and
• allowing applicants and third parties to provide documentation to the department electronically.

Target Date

June 2016

Paragraph 6.34

Employment and Social Development Canada should regularly seek feedback from applicants and beneficiaries to identify ways to improve access to the Canada Pension Plan Disability program.

Management Response

Agreed. Employment and Social Development Canada recognizes the importance of regularly consulting with applicants and beneficiaries to identify ways to improve the Canada Pension Plan Disability (CPPD) program. The client experience is a fundamental consideration for all program improvements, and the Department is committed to ensuring that Canadians are able to access the program in an easy, secure, timely and efficient manner. The Department established the CPPD Client Roundtable in 2001. Since its creation, the roundtable has served as a forum for discussion with individuals from the community who have direct experience with the program. Building on our experiences with the roundtable, the Department will reassess the best manner to regularly engage applicants and beneficiaries to identify ways to improve access to the program. The Department will complete this reassessment by March 2016 and implement enhancements by December 2016.

Action Plan

ISSDB and PPSB will collect information regarding stakeholder engagement by:

• Assessing and revitalizing the CPPD Client Roundtable to determine if it can be leveraged as a means of gathering applicant and beneficiary feedback with the purpose of informing policy and program development;
• Establishing an internal working group to identify and explore possible ways that information can be collected, collated and analyzed to develop measures for improving program access;
• Conducting a literature review of comparable provincial, federal and international programs with a focus on how applicant and beneficiary feedback on program access issues is gathered and integrated.
• Based on the information gathered, ISSDB and PPSB will develop and implement enhancements to measures for seeking feedback from CPPD beneficiaries and applicants, by December 2016.

Target Date

March 2016 and December 2016

Paragraph 6.51

Employment and Social Development Canada should review its Canada Pension Plan Disability service standards for initial and reconsideration decisions to determine whether they are appropriate.

Management Response

Agreed. As part of ongoing efforts to manage the delivery of its pension programs, Employment and Social Development Canada is undertaking a review of its service standards, including all elements related to the delivery of the Canada Pension Plan Disability program. The Department will complete the review and develop an implementation plan by March 2016.

Action Plan

PPSB, in consultation with ISSDB will complete the review of its pensions related service standards, by March 2016. The review will include:

• a review of current processing maps to identify opportunities to improve effectiveness and efficiency of program delivery that would have a corresponding impact on service standards;
• creating reports that track overall operational performance against service standards;
• analysing comparable published service standards in other jurisdictions / countries to inform ESDC’s review.
• Building on the results of the review, PPSB will develop a plan for the implementation of any changes to its service standards.

Implementation will begin in 2016-2017 for any changes that do not require changes to Information Technology (IT) systems. Timing of changes to service standards that require changes to IT systems will be aligned to systems changes required for CPP SIS implementation.

Target Date

March 2016

Paragraph 6.55

Employment and Social Development Canada should establish specific service standards for processing Canada Pension Plan Disability applications from applicants with terminal illnesses or grave conditions. The Department should also measure and report on its performance in meeting the standards.

Management Response

Agreed. The review of pension programs service standards will include the identification of options for service standards for applications made by applicants with terminal illnesses or grave conditions. Employment and Social Development Canada will complete the review of the service standards and develop an implementation plan, which will include mechanisms for monitoring and reporting on these standards by March 2016.

Action Plan

PPSB in consultation with ISSDB will complete the review of its pensions related service standards as outlined in response to paragraph 6.51 and develop an implementation plan, which will include mechanisms for monitoring and reporting on standards that will be established for applications from individuals with grave conditions and terminal illnesses.

Target Date

March 2016

Paragraph 6.57

Employment and Social Development Canada and the Social Security Tribunal of Canada, supported by the Administrative Tribunals Support Service of Canada, should collect and accurately capture robust data to allow better monitoring of the Canada Pension Plan Disability program and accurate reporting of results.

Management Response

Agreed. Employment and Social Development Canada will continue ongoing efforts to improve the quality of its data. As part of the Canada Pension Plan Service Improvement Strategy, the Department will identify and analyze data issues, and develop a plan to implement solutions. The plan to improve Canada Pension Plan Disability (CPPD) data quality will detail specific measures and system enhancements that will be pursued in order to provide timely, reliable and comprehensive data to support the CPPD program. The Department will develop this plan by June 2016.

Action Plan

PPSB, in consultation with ISSDB will improve business process and workload management capabilities to support the CPP program overall, including CPPD. These improvements will enhance overall program data, as well as the ability to analyze and report on program results.

In addition, options will be developed to maximize the use of existing internal tools to improve collection, management and monitoring of data.

Target Date

June 2016

Paragraph 6.69

Employment and Social Development Canada should implement a formal quality assurance framework for the Canada Pension Plan Disability program to review whether its medical adjudications are appropriate and consistent. This framework should include a process to inform medical adjudicators of the reasons why their decisions were overturned, and to support Department officials’ efforts to improve processing procedures and provide training to adjudicators.

Management Response

Agreed. Employment and Social Development Canada considers high quality program delivery a priority. Building on work undertaken to date, the Department will continue to develop and implement a robust Canada Pension Plan Disability (CPPD) Quality Assurance Framework to support continuous improvement and consistency in decision-making. This framework will guide the integration of quality into all aspects of program delivery and policy development and will include mechanisms to identify opportunities to enhance business processes and develop clear guidance and training. It will also include an effective feedback mechanism for medical adjudicators to understand why their decisions were overturned or upheld by decision-makers at reconsideration or appeal. The Department will finalize the CPPD Quality Assurance Framework by March 2016 and begin its phased implementation in April 2016.

Action Plan

PPSB and ISSDB will continue to develop the CPPD Quality Assurance Framework to ensure it is comprehensive and supports co;ntinuous improvement of CPPD decisions using the findings of the triage review and other business intelligence to strengthen and fine-tune the framework.

In addition, PPSB and ISSDB will further refine the framework to align with the broader quality assurance approach currently being developed for all core statutory programs and benefits ESDC is responsible for delivering. Improvements will be examined for:

• business processes, to ensure sufficient information is on file for sound decision-making;
• training, including initial and follow-up;
• tools for decision-making, such as guidance documents on certain medical conditions;
• the systematic use of business intelligence, including providing information on appeals decisions to initial decision makers to help them improve their decisions; and
• quality performance monitoring, such as the creation of new quality programs and business intelligence.

An implementation plan will be developed by March 2016, to bring into effect the CPPD Quality Assurance Framework. ISSDB and PPSB will begin its phased implementation in April 2016.

Target Date

March 2016 and April 2016

Paragraph 6.112

Employment and Social Development Canada (the Department) should analyze the results of its triage review to identify ways to modify its policies and processes to ensure that the benefit is granted earlier to eligible applicants. The Department should also consider the lessons learned in developing a quality assurance framework, to ensure that its decisions are appropriate and consistent.

Management Response

Agreed. Employment and Social Development Canada has already initiated analysis of the triage review findings. Based on the results of this analysis, the Department will develop a strategy to leverage the findings to determine greater efficiencies and enhance policies and processes. In addition, as part of this strategy, the Department will consider the lessons learned from the triage review when developing its Canada Pension Plan Disability (CPPD) Quality Assurance Framework. The Department will complete the analysis of the triage review findings in order to support the development of the CPPD Quality Assurance Framework by March 2016.

Action Plan

Based on the analysis already underway, ISSDB and PPSB will develop a strategy to leverage the triage review findings to determine greater efficiencies and enhance policies and processes. This strategy will involve departmental partners, including Regions, working closely together to analyze findings from the triage review to ensure triage findings form part of the business intelligence sharing across the processing network and inform development of the CPPD Quality Assurance Framework. Triage review findings will also be used:

• as part of the analysis for reviewing and updating the Adjudication Framework;
• to improve and enhance other decision-making support tools such as medical reference sheets;
• to assist in the development of a revised standard template for adjudication;
• as a source of information for the CPP Service Improvement Strategy.

By March 2016, ISSDB and PPSB will have completed the analysis of the triage review findings and integrated the lessons learned into the

Target Date

March 2016