Management Response and Action Plan Follow-up Audit of Non-Insured Health Benefits Program - Medical Transportation December 2012

Follow-up Audit of Non-Insured Health Benefits Program
Recommendations Management Response and
 Planned Management Action
Deliverables Expected Completion Date Responsibility
Recommendation 1

It is recommended that the Assistant Deputy Ministers of the First Nations and Inuit Health Branch ensure that the Non-Insured Health Benefits Program establish additional medical transportation operational performance measures and monitor performance data to guide the progress of the medical transportation benefit towards its objectives.

Management agrees with the recommendation.

The Non-Insured Health Benefits Programs' current performance measures report on national and regional medical transportation usage and financial expenditures and are in-line with the First Nations and Inuit Health Branch's branch-wide requirements. Based on the Action Plan outlined in response to recommendation two, the Non-Insured Health Benefits Program will identify additional medical transportation performance measures.

1.1) Identification of additional Non-Insured Health Benefits Program medical transportation performance measures 1.1) March 31, 2014 1.1) First Nations and Inuit Health Branch - Non-Insured Health Benefits Directorate, First Nations and Inuit Health-Regional Operations
Recommendation 2

It is recommended that the Assistant Deputy Ministers of the First Nations and Inuit Health Branch, in collaboration with the Assistant Deputy Minister of the Corporate Services Branch and the Chief Financial Officer, work towards a strategy, with a budget and project timelines, to address the challenges in data collection for both operationally managed benefits and those delivered through contribution agreements, in order to improve the monitoring of performance.

Management agrees with the recommendation.

The assistant deputy ministers of the First Nations and Inuit Health Branch and the Corporate Services Branch, as well as the Chief Financial Officer, agree that challenges in the collection of data regarding the Non-Insured Health Benefit Program's medical transportation benefit exists. While progress has been made, the current structure of multiple systems, differing business processes, and governance should be examined with a view to develop a common vision for the future of medical transportation data and systems.

     
Specific deliverables The First Nations and Inuit Health Branch will reassess its medical transportation data collection priorities under contribution agreements in order to improve the monitoring of performance. 2.1a) Detailed report

Milestones:
i) Evaluate contribution agreement data elements and systems

ii) Identify and assess contribution agreement data collection challenges, risks and options

2.1a) March 31, 2014

i) March 31, 2013

ii) August 31, 2013

2.1a) First Nations and Inuit Health Branch
The First Nations and Inuit Health Branch, with the support of the Corporate Services Branch and the Chief Financial Officer Branch, will seek independent advice, including the assessment of an enterprise solution, on developing and implementing a common vision for the future of the electronic management of operating medical transportation data. 2.1b) Action plan including timelines

Milestones:
i) Seek independent advice and award a contract

ii) Final report due/contract end date

iii) Action plan - first draft

2.1b) March 31, 2014

i) April 1, 2013

ii) July 31, 2013

iii) December 31, 2013

2.1b) First Nations and Inuit Health Branch in collaboration with the Corporate Services Branch, and the Chief Financial Officer Branch
  Building on existing financial control process maps, the Non-Insured Health Benefits Program will work in collaboration with the Chief Financial Officer Branch to further standardize regional business practices in the processing of medical transportation requests for payment in order to standardize processes. 2.2) Review regional business practices in the processing and payment of medical transportation invoices 2.2) March 31, 2014 2.2) First Nations and Inuit Health Branch in collaboration with the Corporate Services Branch, and the Chief Financial Officer Branch
Recommendation 3

It is recommended that the Assistant Deputy Ministers of the First Nations and Inuit Health Branch, in collaboration with the Assistant Deputy Minister of the Corporate Services Branch and the Chief Financial Officer, assess the vulnerabilities of the Medical Transportation Records System and the Ontario Medical Transportation System as identified in this audit and develop appropriate measures to mitigate the risks associated with these vulnerabilities.

Management agrees with the recommendation.

The Non-Insured Health Benefits Program is committed to working in partnership with the Corporate Services Branch and the Chief Financial Officer Branch to bring enhancements to the Medical Transportation Records System to better support the administration / management of the program.  Based on a risk assessment of potential weaknesses, the Non-Insured Health Benefits Program working with the Corporate Services Branch and the Chief Financial Officer Branch, will take cost-effective corrective measures by upgrading the application.

Based on the observations in this audit report, the Non-Insured Health Benefits Program will review and revise current General Computer Controls, and Logical Access Controls in the Ontario Medical Transportation System and the Medical Transportation Records System.

3.1) Risk assessment of potential weaknesses with the Medical Transportation Records System 3.1) March 31, 2013 3.1) First Nations and Inuit Health Branch - Non-Insured Health Benefits Directorate in collaboration with the Corporate Services Branch, and the Chief Financial Officer Branch
3.2) Heightened security for the Medical Transportation Records System's flat file processing 3.2) March 31, 2013 3.2) First Nations and Inuit Health Branch - Non-Insured Health Benefits Directorate in collaboration with the Corporate Services Branch, and the Chief Financial Officer Branch
3.3) Improved audit functionality within the Medical Transportation Records System to track what was changed, what action was taken by whom and when 3.3) March 31, 2013 3.3) First Nations and Inuit Health Branch - Non-Insured Health Benefits Directorate, Corporate Services Branch
3.4) Development and maintenance of a list of individuals authorized to request additions/changes to user accounts for each region using the Medical Transportation Records System 3.4) March 31, 2013 3.4) First Nations and Inuit Health -Regional Operations, First Nations and Inuit Health Branch - Non-Insured Health Benefits Directorate
3.5) Documentation of Regional processes and segregation of duties matrix for regions using the Medical Transportation Records System and the Ontario Medical Transportation System 3.5) March 31, 2013 3.5) First Nations and Inuit Health -Regional Operations
Recommendation 4

It is recommended that the assistant deputy ministers of the First Nations and Inuit Health Branch ensure that the Ontario region implement a change management framework for the Ontario Medical Transportation System including a separate test environment, a framework for testing and system documentation.

Management agrees with the recommendation.

The assistant deputy ministers of the First Nations and Inuit Health Branch will ensure that the Ontario region addresses the change management framework challenges with the Ontario Medical Transportation System as identified in this audit report, and until such time as the deliverables in Recommendation 1 are complete.

4.1) New Ontario Medical Transportation System management framework 4.1) March 31, 2014 4.1) First Nations and Inuit Health -Regional Operations, Ontario Region
4.2) Separate Ontario Medical Transportation System test environment 4.2) March 31, 2014 4.2) First Nations and Inuit Health -Regional Operations, Ontario region
4.3) Framework for testing the Ontario Medical Transportation System 4.3) March 31, 2014 4.3) First Nations and Inuit Health -Regional Operations, Ontario region
4.4) Acquisition of Ontario Medical Transportation System documentation 4.4) March 31, 2015 4.4) First Nations and Inuit Health -Regional Operations, Ontario region
Recommendation 5

It is recommended that the assistant deputy ministers of the First Nations and Inuit Health Branch ensure that the Non-Insured Health Benefits Program revise the contribution agreement template(s) to require detailed annual financial reporting on medical transportation expenditures by cost category.

Management agrees with the recommendation.

The Non-Insured Health Benefits Program will revise the First Nations and Inuit Health Branch's contribution agreement template to require more detailed annual financial reporting on medical transportation expenditures.  However, Regional Operations First Nations and Inuit Health will maintain its authority to accept simplified financial reporting if a risk rationale can be justified and documented for the contribution agreement recipient.

5.1)  Revised First Nations and Inuit Health Branch contribution agreement template on medical transportation expenditures 5.1) June 30, 2014 5.1) First Nations and Inuit Health Branch - Non-Insured Health Benefits Directorate, First Nations and Inuit Health - Regional Operations
Recommendation 6

It is recommended that the assistant deputy ministers of the First Nations and Inuit Health Branch ensure that the Non-Insured Health Benefits Program officers formalize monitoring practices related to medical transportation benefits and use templates developed by Non-Insured Health Benefits headquarters, including site visit reports.

Management agrees with the recommendation.

The Non-Insured Health Benefits Program will formalize its contribution agreement monitoring practices and develop national templates to be used in the monitoring of the medical transportation benefit.

However, Regional Operations First Nations and Inuit Health will maintain the autonomy to adjust monitoring practices in cases of low risk, and national templates as long as they remain within the spirit of national practices.

6.1) Medical transportation contribution agreement monitoring guidelines 6.1) December 31, 2013 6.1) First Nations and Inuit Health Branch - Non-Insured Health Benefits Directorate, First Nations and Inuit Health - Regional Operations
6.2) Medical transportation contribution agreement site-visit templates 6.2) December 31, 2013 6.2) First Nations and Inuit Health Branch - Non-Insured Health Benefits Directorate, First Nations and Inuit Health - Regional Operations
Recommendation 7

It is recommended that the assistant deputy ministers of the First Nations and Inuit Health Branch ensure that a national guideline be developed to assist medical transportation program officers in determining and documenting funding levels for consistency in approach across Canada.

Management agrees with the recommendation.

The Program currently adheres to the First Nations and Inuit Health Branch's Knowledge in a Book: Business Processes for Managing First Nations and Inuit Health Branch Contribution Agreements, and the Non-Insured Health Benefits Medical Transportation Contribution Agreement Schedule Management Training manual.  The Non-Insured Health Benefits Program's management is committed to ensure national consistency in the management of the medical transportation benefit and will develop national guidelines specific to determining and documenting contribution agreement funding levels.

7.1) National medical transportation contribution agreement funding level guidelines 7.1) September 30, 2013 7.1) First Nations and Inuit Health Branch - Non-Insured Health Benefits Directorate, First Nations and Inuit Health - Regional Operations
Recommendation 8

It is recommended that the assistant deputy ministers of the First Nations and Inuit Health Branch ensure that the Non-Insured Health Benefits Program review transportation warrants making reference to terms and conditions on how services are to be provided by suppliers and paid for by Health Canada.

Management agrees with the recommendation.

The Program will consult with First Nations and Inuit Health Regions, Health Canada's Legal Services Unit and the Chief Financial Officer Branch's Material and Assets Management Division to amend the Non-Insured Health Benefits Program's medical transportation warrants to reflect appropriate Non-Insured Health Benefit Program terms and conditions.

8.1) Terms and conditions for Non-Insured Health Benefits Program's service providers on medical transportation warrants 8.1) June 30, 2013 8.1) First Nations and Inuit Health Branch - Non-Insured Health Benefits Directorate, First Nations and Inuit Health - Regional Operations
8.2) Implementation of amended medical transportation warrants 8.2) September 30, 2013 8.2) First Nations and Inuit Health - Regional Operations
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