Audit of the Citizenship Program

3.0 Observations and Recommendations

3.1 Governance

3.1.1  Governance and Strategic Direction

It was expected that operating objectives and priorities would exist for all key Citizenship Program activities and that they would be documented, linked to strategic objectives and priorities, effectively communicated throughout the organization, and reviewed periodically to ensure continued relevance. It was also expected that processes would be in place to integrate human resources and business planning, budgeting, monitoring and performance management for the Citizenship Program.

The OMC Branch has the responsibility for coordinating all the domestic and international operational activities of the Department. The Citizenship Program Delivery and Promotion (CPDP) Division in OMC manages and coordinates Citizenship Program delivery, which includes application processing, language and knowledge testing and, ceremonial events.

The processing of all applications for Canadian citizenship grants is initially performed at CPC-S and completed, when required, at the local offices level where actual testing and ceremonies occur. Proof applications are processed exclusively at CPC-S.

The audit found that operating objectives and priorities for the Citizenship Program were in place and were communicated at the corporate level through a number of reporting instruments: the Departmental Strategic Plan, the Integrated Corporate Plan and the Report on Plans and Priorities. These documents outline key Citizenship Program activities as well as initiatives to improve the program. Those activities are linked to the Department’s strategic objectives with a strengthened commitment to citizenship. Planned achievements to support strategic objectives are included in the CAP, which provides a series of initiatives that are being developed for all Canadians. It was also noted that monthly results are monitored at each level of the organization involved with the program.

However, the audit revealed that the estimated citizenship grant and proof applications to be processed within a year had not been reviewed since 2004, when permanent (A-base) funding reference levels were determined. Despite rising application levels, changing environmental context conditions and the introduction of further procedures to enhance program integrity, application processing estimates have remained at 170,000 grants and 38,000 proofs respectively. In 2004, a percentage was established for file distribution to local offices. Since then, CPC-S has continued to use that same ratio as a basis for sending files to local offices, without considering yearly changes in application intake from different regions of the country.

Regional offices set operational objectives and have specific goals for local office processing. Files sent by CPC-S to the local offices are not consistent with the objectives set at the local offices. Therefore, the communication of objectives between CPC-S and local and regional offices needs to be improved. The non-alignment of objectives has resulted in the creation of inventory at some locations and insufficient workflow at others, affecting resource capacity and utilization.

The OMC, although informed through monthly reporting, has not taken the lead to jointly determine achievable annual objectives, taking into consideration internal and external factors facing the Citizenship Program. Factors to be considered, to name a few, are continuum of programs, increasing demand (intake), change in business lines, changing environmental factors and risk assessments.

The audit concluded that strategic objectives and priorities for the Citizenship Program were in place, aligned with outcomes and communicated through corporate documents. They generally met expectations at the senior management level, with the exception of the review and clear communication of the expected results in terms of the number of citizenship grant and proof applications to be processed yearly at each level of the organization involved in the Citizenship Program.

3.1.2  Accountability

It was expected that processes existed to ensure that accountabilities and responsibilities were clearly delegated, communicated and adequately discharged, and that the necessary training and tools were provided to employees to discharge their responsibilities. Given the structure of the program and the involvement of the Citizenship Commission, it was also expected that the roles, responsibilities and accountabilities of CIC and the Citizenship Commission were clearly outlined in documents that govern the relationship between the Department and the Commission for the Citizenship Program.

The OMC Branch is responsible for developing the Citizenship Policy Manual and operational guidelines on the Citizenship Program to support employees in adequately discharging their responsibilities. The audit revealed that local procedures and tools had also been developed locally to provide guidance to employees at specific locations or in a specific region. Although further guidance could be welcome locally, some issues were found which will be explained in section 3.3 – Internal Controls.

The Citizenship Policy Manual indicates that the OMC Branch is responsible for the overall management and coordination of the Citizenship Program delivery. However, interviews indicated that the OMC actually shares the management of the Citizenship Program delivery with various divisions and branches at NHQ and in the regions. For instance, CPC-S and regional directors general do not administratively report to the OMC but share regional management and delivery of the program.

This being the case, there are unclear accountabilities that are due to a variety of factors, including shared management of program delivery; different guidance provided to employees locally, resulting in different practices for processing grant files at the regional level; and a different understanding of outcome expectations.

Therefore, the audit concluded that although processes were in place, responsibility was delegated within the program and training and tools were provided to employees. In addition, the accountabilities, roles and responsibilities for the management of the program need to be clearly defined and communicated to CIC staff, the registrar, NHQ branches and the regions.

Relations with the Citizenship Commission

At the NHQ level, regular meetings occur between departmental officials, including the registrar, and the senior citizenship judge. Although regular meetings take place between departmental staff and the Citizenship Commission to keep both informed of roles and responsibilities, there is no formal agreement in place to clarify accountabilities, roles and responsibilities in decision making related to the approval and granting of citizenship, leading to confusion in roles and responsibilities for staff of both parties. Therefore, the roles and responsibilities of CIC officers and judges of the Citizenship Commission need to be clearly delineated so that both parties can better coordinate their duties and prevent any unnecessary part of the process, duplication of work or confusion.

3.1.3  Results and Performance

It was expected that:

  • achievable and measurable planned results were identified, in place and linked to operating objectives;
  • performance measures were in place and reviewed on a periodic basis, updated as required and linked to planned results;
  • responsibility for monitoring and updating performance measures was clear and communicated; and
  • results of performance measurement were documented, reported to the appropriate levels and factored into decision making.

As mentioned in section 3.1.1, the annual estimated application processing capacity for the Citizenship Program has remained at 170,000 grants and 38,000 proofs. Table 1 (see Background section) provides the results of outcome achieved per line of business over three years. Although planned results were measurable and linked to operating objectives, the expected outcome for grants was not achieved for 2009 and 2010 and was exceeded for proofs. In the current context of new initiatives and changes affecting many aspects of the Citizenship Program, the audit could not find any evidence of monitoring and analysis to see if the current planned results are achievable. Interviews indicated that written agreements were in place between CPC-S and local offices to support expected outcomes. However, at the time of the audit, management was unable to provide copies of those agreements.

It was noted that the Department has developed a performance measurement framework for the Citizenship Program. That framework includes a logic model linking the program activities to expected outcomes. Performance indicators have also been developed to measure the expected results. To complete the framework, CIC is also developing a performance measurement report containing detailed statistics and data that will be helpful for decision making, once fully implemented.

From the observations made above and the unclear accountabilities discussed in the preceding section, the responsibility for monitoring and updating performance measures and their communication was not clear at the time of the audit.

The audit confirmed that the actual results of performance of the Citizenship Program were documented and reported at the corporate level for decision making.

The audit concludes that the Department needs to revisit the basis of allocation to local offices to ensure that local, regional and departmental objectives can be achieved in a consistent manner.

Recommendation 1

The OMC Branch, in consultation with the CPR, should clarify and communicate accountability, roles and responsibilities for the overall management of the Citizenship Program business lines.

Management Response

Agreed. OMC will lead a process to strengthen the understanding of the overall roles and responsibilities within the Citizenship Program, especially as it relates to centralized and risk based decision making, and will clarify these where appropriate.  

To do so, a working group led by OMC, with the participation of regional directors, CPR, Citizenship and Multiculturalism Branch, Case Management Branch, OPMB, and International Region will be created. The Citizenship Commission will also be consulted. To ensure that all those who are responsible for the delivery of the Citizenship Program are familiar with the governance structure, the working group will also develop a communications strategy.

Once developed, a clarified roles and responsibilities document and communications strategy will be presented to the ADM and Senior Judge’s Steering Committee on Citizenship Modernization for approval.

These measures will be completed by March 31, 2012.

Recommendation 2

The Assistant Deputy Minister of Operations, in consultation with the Assistant Deputy Minister of Strategic and Program Policy and the Senior Citizenship Judge, should clearly articulate and communicate the accountability, roles and responsibilities of CIC and the Citizenship Commission as they relate to the delivery of the Citizenship Program in order to formalize the governance process between the two parties.

Management Response

Agreed. As per the recommendation, and incorporating the outcomes of the Citizenship Operational Review Exercise (CORE), and the Organisational Readiness Assessment, CIC and the Citizenship Commission will explore mechanisms to clarify the roles and responsibilities of CIC and the Citizenship Commission. CIC and the Citizenship Commission will also examine the relationship and communications linkages between local CIC staff and citizenship judges, and develop clear guidelines and processes in order to enhance this working relationship. A recommended approach will be submitted to the ADM of Operations, the ADM of Strategic and Program Policy and the Senior Citizenship Judge by the end of the fiscal year.

As Recommendation 1 and 2 are linked, the same working group that will be established in response to Recommendation 1 will support the resolution of Recommendation 2. The working group will review the CORE report and the Organisational Readiness Assessment and will prepare an issue paper outlining where clarification is needed with regards to the roles and responsibilities of CIC staff and the Citizenship Commission.

These measures will be completed by April 30, 2012.

Recommendation 3

The OMC Branch, in consultation with the CPR and the regions, should analyse, review and update periodically the basis for the allocation of applications to local offices to ensure that production expectations are consistent with the regional capacity and support the outcome of the Citizenship Program. Additionally, responsibility for monitoring should be clarified.

Management Response

Agreed. A review of the allocation of citizenship applications across the regions and local offices will be conducted.

To achieve the above, a sub-committee of the Production and Capacity Working Group (led at the director level) will be created to develop ways to establish updated citizenship output targets and monitoring mechanisms. This sub-working group will be co-led by OMC and OPMB and will include participants from Citizenship Modernization, the regions, and CPR.

Analysis will incorporate an understanding of how historic and recent PR landing trends link to citizenship intake as well as existing realities in CPC Sydney and local offices affecting output, including the overall complement of citizenship judges. A reassessment will also take place in reference to links between allocated files and regional target setting, including integrating program integrity goals into targets. This also forms part of the citizenship modernization roadmap.

The first report will be on optimal distribution of citizenship grant files from CPC-S to the regions and local offices. Recommendations will be presented to the DG Steering Committee on Production and Capacity and to the ADM Production Oversight Committee by March 2012, with results monitored on a periodic basis by OMC, OPMB, the regions, CPR and CPC Sydney and reported annually to the DG Steering Committee on Production Capacity.

Short term action may also be taken to address immediate operational needs.

These measures will be completed by March 31, 2012.

3.2 Risk Management

It was expected that:

  • Processes were in place to identify and assess risks that may preclude the achievement of objectives;
  • The potential for risk related to fraud would be explicitly considered when assessing risks;
  • Processes were in place to mitigate and monitor risks that may preclude the achievement of objectives; and
  • Management appropriately communicated risk and risk management strategies to key stakeholders.

For a number of years, CIC has been taking important steps in moving risk management practices forward at the strategic level, including the development of its Corporate Risk Profile for 2010–2013. The risk profile provides an entity-wide perspective and is related to strategic outcomes. The audit revealed that at the program level, there was no formal and systematic process in place documenting the operational risks which the Citizenship Program faces. However, the regions have considered some risks related to the Citizenship Program delivery in relation with expected results, resources, processing time and residency determination.

We noted that applications were processed in the same manner without considering risks or trends for a given application, and therefore, mitigation strategies have not been developed specifically at the program delivery level. For example, based on known risks or trends, we would have expected to see additional interviews to validate applicants’ information for cases presenting risks or additional steps to reduce identified risks. The audit did not reveal that such practices were in place to mitigate those risks. In their day-to-day work, officers may identify risks or trends that could result in the management of these risks. However, a risk management strategy for the Citizenship Program delivery has not been formalized and communicated.

A QA process is in place and will be discussed in the Internal Controls section of this report. The audit noted that the QA exercise performed throughout the regions is not based on risk. QA value could be improved by including risk factors identified for the Citizenship Program.

Program integrity is currently one of the corporate and program priorities. With the creation of the Citizenship Unit within the PID, risks related to fraud information have been communicated to CIC employees. Furthermore, a Citizenship Fraud Action Plan was developed and the Division is currently developing fraud risk indicators. In February 2011, the National Citizenship Fraud Conference was organized to advance the Citizenship Fraud Action Plan by bringing together staff involved in the delivery of the Citizenship Program, providing anti-fraud tools and training, discussing fraud in the program and cooperation with partners such as the Royal Canadian Mounted Police, the Canadian Border Services Agency and Passport Canada.

The audit concluded that fraud was explicitly considered when assessing risks, and that there was no formal process in place to capture risks at the program and office levels and to communicate them to key stakeholders. With the development of a formal blueprint for each line of business for the Citizenship Program, CIC could more proactively identify potential problems early enough to implement actions to mitigate risk in a timely manner. As a result, at the program delivery level, mitigation strategies have not been developed.

In response to previous audits and recommendations related to risk management, the Department committed to developing a risk blueprint for all business lines incorporating risks specific to each program. For the Citizenship Program, management should consider developing a risk register also at the office level, given the specific issues faced by each region and office. To drill down to the local office level, risk would need to be incorporated into key elements of processing and associated tools and training would need to be provided.

3.3  Internal Controls

It was expected that:

  • Decisions were adequately documented, and required supporting documentation was maintained;
  • Delegated authorities for decisions were appropriate and in compliance with departmental policy;
  • QA processes were in place to ensure that the delivery of the program was performed as intended within the appropriate framework; and
  • Procedures related to grants were implemented consistently across the regions and these procedures ensured operational efficiency.

3.3.1 Quality of File Documentation

According to the Citizenship Policy Manual, “a duly completed form is a signed application form,which is submitted with the requisite fee and mandatory documents.” This general rule applies to both business lines: grants and proofs. At the time of the audit, CPC-S did not return to the applicant a signed and dated application when the fees were paid, and when some of the required documents were missing. Consequently, applications with missing supporting documents were accepted and processed. As a result, processing times and application inventory increased as officers needed to obtain additional information from the applicant. Since April 2011, management has put in place a more formal approach to return to applicants applications that are either incomplete or that have missing supporting documents.

The audit examined a sample of grant and proof files as indicated in the Audit Methodology section of this report (section 1.6).

Grants – Adults

For each adult grant file reviewed, the audit looked at the completeness of the application form, signature and date; the evidence on file for proof of payment of the appropriate fees; the required supporting documents; the data entries in the Global Case Management System (GCMS); the residence assessment and supporting documents; valid clearances; evidence of tests passed; referral to judges; documents supporting the grant decision; copies of documents related to ceremonies (oath form, media consent, approved and granted before the oath); and revocation of the permanent resident card at the ceremony. The audit also examined each file to ensure that only the required documents remained on file.

Overall, the file review of adult grants indicated that most files were generally found to be compliant with the above requirements. The exceptions related to information to be retained in files are as follows.

  • The Citizenship RegulationsFootnote 3 require that all applications for adult grants be accompanied by material such as a birth certificate or other evidence that establishes the date and place of birth of the applicant; any document that has been or may be created by the Canadian immigration authorities, or other evidence, that establishes the date on which the applicant was lawfully admitted to Canada for permanent residence; two photographs of the applicant of the size and type shown on a form prescribed under section 28 of the Citizenship Act; and residency evidence. In addition, the Citizenship Policy Manual requires two pieces of personal identification, such as a driver’s licence, a provincial or territorial health insurance card or a foreign passport, to mention a few, one of which should contain the applicant’s signature and photograph. The file review revealed that 76 files out of 405 (19%) did not retain all the required documents listed above.
  • One of the criteria for granting citizenship to adults is assessing residence in Canada as provided for by the Citizenship ActFootnote 4. The Citizenship RegulationsFootnote 5 require that an application be filed with “evidence” that the applicant has accumulated at least three years of residence within the four years preceding the date of the application. Therefore, applicants are required to declare absences from Canada within that period and provide the information with their application. Applicants should be able to provide evidence to support their assessment of residency.

The audit found for fiscal year 2010–2011 that applications submitted with the adult grant at CPC-S did not include sufficient support for declared absences from Canada.

Although the Citizenship Policy Manual indicates that a copy of the passport or travel document used to enter Canada and any passport issued after entering Canada may be required, the audit revealed that for fiscal year 2010–2011, in order to support their residency assessment, all applicants were asked to bring their passport or travel documents at their local office when they attended an interview during the test stage, which includes testing their knowledge of one of the official languages of Canada and testing adequate knowledge of Canada and the responsibilities and privileges of citizenship. Therefore, the test-stage interviews have become a significant control point in the process.

Since passports were requested, the Citizenship Policy Manual indicates that applicants are required to provide a copy of all pages (including blank pages) of passports, whether current or previously issued, relevant to the four-year period. These, therefore, become relevant documents for decision making and should be retained on file. If the document is not retained by the local office, the Citizenship Policy Manual requires that the information be entered in GCMS. Therefore, all files should contain passport information within GCMS if a copy is not retained in the paper file.

Neither most files reviewed nor the departmental information system contained any information on which passport or documents were presented as evidence and for which period, as required by the Citizenship Policy Manual. Instead, a checklist was used indicating that one of the two types of documents was reviewed during the process. In our view, a checklist is not a sufficient piece of “evidence” that would satisfy the policy manual requirements to support decision making and for verification and monitoring purposes. The Citizenship Policy Manual provides a list of relevant documents that must be maintained on file in order for a citizenship judge or an officer to come to a decision.

Without the proper documents on file, it becomes difficult to demonstrate the basis on which a decision was arrived at.

Grants – Minors

For each minor grant file reviewed, the audit looked at the completeness of the application form, signature and date; whether the applicant was a minor at the time of the application; the evidence that a parent was a Canadian citizen or was applying concurrently; the evidence on file for proof of payment of the appropriate fees; the required supporting documents; the data entries in GCMS; valid clearances; approval decision; documents supporting the grant decision; copies of documents related to ceremonies when applicable (oath form, media consent, approved and granted before the oath); and revocation of the permanent resident card.

In that category, the main criterion for granting citizenship to minors is to ensure that one of the parents was a Canadian citizen at the time the applicant was born.Footnote 6 With regard to the points mentioned above, the files for minor grants were generally found to be satisfactory.

Grants – Refused

The review of refused cases revealed that evidence on file supporting the decision was adequate in all cases reviewed and complied with policy and procedures.

Proofs

For each proof file reviewed, the audit ensured the completeness of the application form, the signature and the date; that for applicants under 14 years of age, parents had countersigned the application form or there was evidence on file that the parents were informed of the applicant’s request; that there was evidence on file that the appropriate fees were paid; that first application cases contained originals or certified copies; that the required documents establishing citizenship were on file, including appropriate identification and photographs; that for replaced certificates, evidence was on file that previous certificates issued were accounted for; that there was evidence on file that citizenship status was not lost; that there was evidence on file that the information provided was verified and that it matched records; that the decision maker had delegated authority; and that the recorded information in GCMS was accurate.

The audit revealed that most proof applications for citizenship were generally satisfactory. However, the audit noted that one location set local guidelines that contradicted the Citizenship Policy Manual requirements concerning the identification documents required to support an application for proof of citizenship. These guidelines indicated that applications filed at Canadian posts abroad did not require identification documents while the Policy Manual – Consular Manual Chapter, indicated that “in addition to the documents required for an application, applicants must also provide at least two other documents to establish identity.” Consequently, the audit found that some of the files sent from abroad did not contain all the required documents to support the decision for approval. Missing identification documents preclude applicants from proving that they are who they say they are, which is an essential part of the decision making.

The audit concludes that the documentary evidence retained on file did not meet expectations. Improvements need to be made to the information retained on file that supports the decision made with respect to approved grants and proofs.

Recommendation 4

The OMC Branch, in consultation with the CPR and the regions as required, should clearly establish which documentary evidence is required to be kept in grant files (to establish residency, etc.) and in proof files in order to demonstrate compliance with legislative and policy requirements.

Management Response

Agreed. The Department recognizes the need to review the information that is requested of applicants upfront to meet legislative and regulatory requirements, how information on requirements is presented to citizenship judges via the File Readiness Checklist, as well as what information is kept on a retired file.

In the short term, existing policies and procedures regarding the preparation of grant files for citizenship judges, as well as on documents to be retained on finalized grant and proof applications, will be reinforced to citizenship staff.  

As indicated by the ADM - Operations and the Senior Judge in the response to the Change Readiness Assessment report, a commitment has already been made to review policies on how officers should prepare files to support judges in their decision-making role for effectiveness. Mechanisms will be implemented to ensure policies are being adequately followed.

The Program Integrity Division (PI Division) has already begun work on developing risk indicators of citizenship fraud and analysis on documents that should be requested in support of an adult citizenship grant application in order to establish whether an applicant meets the residence requirement of the Citizenship Act. A working group, led by OMC CPDP and with the support of the Program Integrity Division, Citizenship and Multiculturalism Branch, CPR and the regions will be established to review and propose changes to the types of documents to be included with citizenship grant and proof applications, as well as documents which must be presented to the citizenship judge for decision (grants only). The Citizenship Commission will be consulted regarding the documents to be presented to Judges. A review of file document requirements at other stages of the process (such as after decision, grant, ceremony, etc), will also take place.

The working group will ensure that any change to citizenship file requirements fully utilizes the potential of GCMS as the electronic method of record keeping.

These measures will be completed by June 30, 2012.

3.3.2  Delegation of Authority

The registrar is responsible for delegating authority to citizenship officers for granting citizenship or for delivering a certificate for proof of citizenship.

Pursuant to legislative amendments to the Citizenship Act, in order to have the delegated authority for granting, an individual must occupy the position of a citizenship officer. Officers must also follow the appropriate training and pass an examination. Officers lose their delegation upon leaving their positions, and must request it again from the registrar if they return. However, they would not necessarily have to take the course and examination again.

A comparison between the lists of delegations of authority maintained by the registrar for grants and proofs and the lists of delegated officers at each location visited during the audit indicated that the registrar’s lists were incomplete and inaccurate for both lines of business. Some decision makers did not appear on the registrar’s lists, despite having delegation. In addition, some employees who no longer worked for the Citizenship Program, or even the Department, remained listed.

The audit concludes that although delegated authority was in place for the Citizenship Program, improvements are required to clarify procedures and controls of that instrument and ensure compliance with departmental policy. The Department is at risk because of ambiguity in the delegation provided for granting citizenship.

Recommendation 5

The OMC Branch, in consultation with the CPR and the regions, should review the policy and update the delegation of authority instrument to ensure that it is accurate and complete and to ensure compliance with departmental policy.

Management Response

Agreed. With the support of CPR, IR and the regions, OMC will lead changes and updates regarding delegation on three fronts:

Firstly, action has already been undertaken to review and update the list of delegated citizenship officers. NHQ, CPR, and the regions have agreed that the list of individuals with grant delegation will be updated quarterly in order to ensure its ongoing accuracy. In the long term, a GCMS solution will be explored to maintain this list through system generated reports of grantors.

Second, the existing Delegation Instrument which was signed by the Minister on May 4, 2010, will be posted on the CIC intranet to ensure it is available for all citizenship staff. Citizenship staff will be notified once this document is available.

Finally, OMC has already begun working on a revised delegation policy for the grants (including adoption grants) and proofs lines of business. A draft of the delegation policy will be circulated shortly for comments to the Citizenship Operational Committee members. This revised policy addresses issues such as the duration of delegations, and the process to reacquire delegation once it has expired.  The regions, other NHQ partners, as well as IR will all be consulted before this document is finalized. The revised policy will be presented to the Business Operations Committee for approval. A copy of final version of the delegation policy will included in the CP manual to ensure all citizenship staff are aware of the Department’s policy regarding delegation.

Given that work has already begun on this front, a new delegation policy will be finalized by October 30, 2011.

These measures will be completed by December 15, 2011.

3.3.3 Quality Assurance (QA)

The OMC Branch is responsible for the management of the national QA program for citizenship. The program was put in place to monitor and report on the Citizenship Program. The QA program has two components: Quality of Decision Making and Reliability of Client Information. The program is designed as a high-level national monitoring exercise for each of the sub lines of business: adult grants, minor grants and proofs. The monitoring activities are performed in the regions and at CPC-Sydney. Quarterly, semi-annual and annual reports, including recommendations, are normally prepared and sent to senior management at NHQ and in the regions.

The audit noticed that there had been no Reliability of Client Information report produced in the last two fiscal years and that the last report on the Quality of Decision Making was produced for the fourth quarter of 2009–2010. There was no specific lead indicated in the reports for recommendations and no action plan provided. According to local interviews and documents, it is the responsibility of regional offices to ensure that recommendations are implemented. Only one region provided evidence that a work plan and oversight were done following these monitoring exercises.

There was limited monitoring of the citizenship delivery process, which is reported through the Quality of Decision Making report. The coverage of monitoring activities was minimal (e.g., 0.35% of expected adult grants). The audit noticed that the last QA that was performed did not include a review of the delegation of authority and the data that should be recorded in the Department’s database, except for information on the application and official forms. At the time of the audit, the recommendations provided did not identify a specific position responsible for implementation. There was no action plan to bring the appropriate corrections to the process in place.

The Program Integrity Framework recently developed by the PID describes two types of QA monitoring activities for CIC programs: Quality of Decision Making similar to the current exercise, and Procedural Compliance Review, which would assess the accuracy, consistency and timeliness of the steps taken in processing an application. The Department intends to incorporate risk assessment and validation within its future program integrity exercises, which will be used to assess the need to update and review procedures to account for risk while ensuring efficiencies in the program.

The audit concludes that the current QA processes and monitoring in place do not ensure that the delivery of the program is performed as intended. During the course of our work, management acknowledged that current QA processes in place were inadequate and have undertaken to modernize QA processes and reporting for the Citizenship Program.

3.3.4 Procedures in Place

Policies and procedures are a key part of a management control framework. They outline senior management’s expectations of how the organization should conduct its operations, including the roles and responsibilities of the different sections of the organization. CIC has a Citizenship Policy Manual that provides background information on the legislation relevant to citizenship, current policies, and guidelines for the administration of the Citizenship Act and Citizenship Regulations. In addition, operational bulletins provide updated information and procedures in effect that have not been incorporated into the Citizenship Policy Manual.

During the local site visits, it was observed in three locations that day-to-day procedures or guidelines had been developed to facilitate the delivery of the program.

Although such initiative may be welcome to ensure clear understanding of the processes in place, they create a risk that the required procedures are not implemented consistently across the regions and do not ensure operational efficiency. In fact, they could become confusing or not in line with the policy manual, as found in the audit in one location.

The audit revealed that different practices existed for managing the Citizenship Program at the regional level. It was also observed that within the same region, procedures could vary from one office to another. Some regions have developed good practices that could be shared with others. For example, the use of a coordinator between CIC and the Citizenship Commission facilitated file processing.

All offices visited interviewed every applicant. The audit also noticed that there was limited departmental guidance on interview tools and techniques for interviews performed at the knowledge-testing stage. As a result, the interviews were conducted inconsistently across offices.

The audit concludes that management should review all tools developed locally to ensure that they are in line with the Citizenship Policy Manual and seek an opportunity for improvement of the Citizenship Policy Manual. Management should also review local practices to develop a consistent approach throughout the regions, to ensure adequate delivery of the Citizenship Program, and to facilitate monitoring activities.

At the time of the audit, management, through the CORE, was conducting a horizontal analysis of current challenges facing the Citizenship Program at the operational level, which will include a review of the procedures used. The Internal Audit and Accountability Branch acknowledges management’s efforts in the modernization of the Citizenship Program.

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