Internal Audit of the Immigration Program at the Canadian Mission in Beirut

Internal Audit & Accountability Branch
December 2014

Table of Contents

• Executive Summary
  • Objective and Scope
  • Why This Is Important
  • Key Findings
  • Conclusion
• Statement of Assurance
• Background
  • Introduction
  • Mission Environmental Context
• Findings and Detailed Recommendations
  • Governance
  • Risk Management and Quality Assurance
  • Control
• Appendix A – Control Summary
• Appendix B – Beirut Application Processing 2010–2013
• Appendix C – Management Action Plan

Executive Summary

Objective and Scope

The objectives of the audit were to assess the Beirut mission’s:

• governance framework for administering the Immigration Program;
• risk management and quality assurance practices to support the delivery of the Immigration Program; and
• internal controls over administrative, financial and operational activities related to the Immigration Program.

The scope of the audit included the roles and responsibilities of the Operations Sector at Citizenship and Immigration Canada (CIC) National Headquarters to support delivery of the Immigration Program at missions. The time period covered by the audit was from November 1, 2012 to October 31, 2013, with the exception of an inventory count and reconciliation performed during the on-site examination in March 2014.

Why This Is Important

The Immigration and Refugee Protection Act is the legal federal framework for immigration and protection of refugees in Canada. Through implementation of this legislation worldwide, CIC employees manage access to Canada through the receipt and processing of applications for permanent and temporary residence.

The operating environment in which overseas immigration staff members conduct their duties can be challenging. Sound governance, risk management and quality assurance practices, and internal controls must be in place to ensure compliance with core legislative, policy, and operational requirements, as well as stewardship of funds and safeguarding of key assets.

Key Findings

To add context to the key findings, it is important to note that the personnel at the mission are operating under difficult circumstances, arising from regional instability, local conflicts and adaptations required to maintain adequate security. Despite the environmental challenges, application processing continues to be performed in accordance with standard departmental controls.

We found that some improvements were required for the governance framework in place at the Beirut mission. As a result of operational and organizational changes, roles and responsibilities require clarification. Sufficient and appropriate training for local staff and officers within the mission, and at National Headquarters to prepare officers for postings, is needed to ensure that mission immigration employees have the information and skills required to carry out their duties. Mission immigration staff members have a strong understanding of values and ethics and conflict of interest obligations.

Risk management mechanisms were in place at the mission. Improvements are required to ensure that formal quality assurance activities are conducted on application processing at the mission. Quality assurance and oversight of Visa Application Centre services were in place.

The internal control framework requires improvements to ensure that systems access, cost recovery and forms management controls are implemented at the mission in line with departmental expectations. Improvements are required by the CIC Finance and Operations Sectors to ensure network-wide awareness of financial delegation obligations, in particular the documentation of pre-approvals required by the Financial Administration Act.

Conclusion

The governance framework for administering the Immigration Program requires improvement at the Beirut mission. The mission’s risk management practices were adequate; improvements are recommended to ensure that a quality assurance regime is implemented for all of the mission’s business lines. The control framework needs to be strengthened to ensure that standard procedures for systems access, cost recovery activities, forms management and administrative expenditures are properly implemented.

Management has accepted the audit findings and developed an action plan to address the audit recommendations.^{Footnote 1}

Statement of Assurance

The conduct of this engagement conforms with the Internal Auditing Standards for the Government of Canada, as supported by the results of the quality assurance and improvement program. We examined sufficient, relevant evidence to support the conclusions reached.

Background

Introduction

The delivery of Canada’s Immigration Program abroad is the responsibility of CIC’s Operations Sector at National Headquarters and occurs in 60 points of service at missions abroad. The International Region (IR) manages an overseas workforce of 1,300 immigration employees comprised of public servants and locally engaged staff (LES) who screen and process applicants for admission to Canada. Application types include permanent resident visas (for family class and economic class immigrants, refugees and protected persons); temporary resident visas (for foreign students, visitors and temporary workers); and other immigration documents such as permanent resident travel documents, temporary resident permits and authorizations to return to Canada (for individuals previously subject to a removal order).

The IR also contributes to the advancement of CIC’s international agenda by liaising with foreign governments and program delivery partners, and contributing to the protection of refugees worldwide, the international migration agenda, and the realization of Canada as a destination of choice for foreign students and international youth.^{Footnote 2}

In addition, the IR is responsible for non-Immigration Program activities, such as resource management administration, and performance analysis and reporting. Other branches within CIC’s Operations Sector are responsible for the development of policy and procedures, program integrity activities, and information technology systems. Administrative services in missions abroad are provided by the Department of Foreign Affairs, Trade and Development (DFATD) under the terms of a Memorandum of Understanding.

This audit focused on the Immigration Program activities conducted at the Canadian mission located in Beirut, Lebanon, as well as the guidance provided by the Operations Sector at CIC’s National Headquarters. Please see Appendix A for a list of criteria used for the audit.

Mission Environmental Context

The mission is operating within an area of regional instability, which elevates the hardship levels at the mission.

The visa office at the Beirut mission became a full-service centre in January 2012, serving a population of approximately 27 million individuals originating from Lebanon and Syria. As of March 2013, the immigration section employed 15 indeterminate employees: four Canada-Based Officers (CBOs) and 11 LES. The mission operational expenditures for 2012-13 totaled $119,139 and the 2013-14 budget allocation was $165,000.

In 2013, the Beirut mission issued 160% more permanent resident visas than in 2012. The main contributors to this increase were the mission’s new refugee line of business and a large number of case files transferred to Beirut when the Damascus visa office in Syria was closed. Comparatively, the temporary resident business line remained relatively stable throughout the audit period. Appendix B presents a summary of the Beirut mission’s processing data for 2010-13 and a comparison with CIC’s overseas network.

The Beirut mission experienced a number of challenges during the period covered by the audit. Following the closure of the Damascus visa office, the Beirut office developed a new permanent resident business line, including refugee files, and transitioned into a full-service office. A significant number of temporary resources – LES, CBOs and temporary duty (TD) officers – were required to address the increased volume of files and other associated work. Concerns about regional stability and a possible evacuation affected staffing at the mission. One of the CBO positions was covered by a series of TD officers from summer 2012 until September 2013. This reduced the number of CBOs available to sustain processing and ongoing oversight duties.

In response to the instability in the region stemming from the ongoing conflict in neighbouring Syria, the mission completed a major business continuity planning exercise in 2013. A major renovation and construction project also commenced at the Beirut mission, continuing through the summer of 2014. A new visa application centre (VAC) opened in Beirut in June of 2013; as of December 2013, biometric data collection at the VAC became mandatory for temporary resident applicants. In the fall of 2013, the Beirut Immigration Program implemented a new organizational structure to better align its staff against current business lines. In December 2013, CIC’s legacy Computer-Assisted Immigration Processing System (CAIPS) was decommissioned and all cases were transferred into the Global Case Management System (GCMS).

Findings and Detailed Recommendations

Governance

The objective was to assess the Beirut mission’s governance framework for administering the Immigration Program.

We expected to find that roles, responsibilities and accountabilities for the Immigration Program were clearly defined and communicated, that financial and human resources were planned and managed to support program delivery, and that public service values and ethics are promoted, documented and communicated within the mission. Clear roles and responsibilities, management of resources, and the promotion of public service values help to foster and maintain an organization with the people, work environment and capacity to achieve organizational objectives.

The audit observed that relationships with other programs (e.g. DFATD) in the mission are collaborative. The immigration CBOs actively participate in the governance of the mission and mission-wide activities such as business continuity planning. LES knowledge and application of values and ethics and conflict of interest measures were strong at the mission. Further, LES have developed a common approach to dealing with conflict of interest and pressures outside the workplace; the audit noted this common approach as a good practice.

The audit observed that controls such as planning, budgeting and monitoring of financial and human resources were in place to support delivery of the Immigration Program and allocation of resources to achieve targets. The mission requests funding through the annual International Region Integrated Management Planning exercise and when additional resources are made available to missions following budget revisions. The immigration program manager (IPM) meets with the finance officer on a monthly basis to review the budget prior to submitting reports and updates to the Operations Sector, as required. The audit did note that significant temporary emergency LES (ELES) and Canada-based TD officers continue to be required to meet the increased application volume following the transition to a full-service office. Although the mission is given priority for these temporary resources, new resources need to be trained, and frequent blitz activities are required to keep up with the demand and to prevent backlogs. Human resourcing methods and allocations from National Headquarters are outside the scope of this audit; however, the continued need for significant temporary assistance indicates that there may be a need for more sustainable, forward-looking resource planning from National Headquarters.

In the fall of 2013, the Beirut immigration program undertook a reorganization of its staff in order to better align the staff complement to business lines and functional responsibilities, and to implement a structure akin to that of similar-sized offices. Additional emergency resources, originally provided for the transition, were removed in 2013 in order to reduce staffing levels to those of comparable-sized missions. Staff members were informed verbally and in writing of the changes and new responsibilities at the time of implementation. Following the audit period, the IPM also met with each employee to seek feedback regarding the new structure and where improvements could be made. At the time of the audit site-visit, the transition was still ongoing.

Work objectives and training needs were not identified for all staff members because individual performance agreements and learning plans were not completed during the audit period. Cross-training for rotational duties had commenced at the time of the site-visit but was outside the audit period.

There were gaps in knowledge and training of individuals performing cost-recovery duties at the mission, which resulted in control weaknesses, as noted in Finding 4. Acknowledgement in writing of Cost Recovery Instructions and Undertakings was also incomplete. The cause of this finding is a lack of training on cost recovery for single assignment officers; these are individuals who are posted on temporary assignment to a mission but who are not employees in the Foreign Service group. Training is provided to single assignment officers going on assignment, but the focus is on application processing duties.

Identifying work objectives and addressing training needs helps to ensure that staff members have the skills necessary to carry out their duties, helps identify resource and control gaps, and supports the achievement of organizational objectives.

Recommendation 1 (Medium): The mission should formally identify and address work objectives and training needs for mission immigration staff. The mission should also ensure that individuals with cost recovery duties sign an acknowledgement of having read the Cost Recovery Instructions and Undertakings.

Recommendation 2 (Medium): The Operations Sector should ensure that single assignment officers receive sufficient training to perform functional responsibilities, such as cost recovery and forms control, at the mission.

Risk Management and Quality Assurance

The objective was to assess the mission’s risk management and quality assurance practices to support delivery of the Immigration Program.

We expected to find that mechanisms were in place to identify, mitigate and monitor risks to the Immigration Program, and that resource allocation was informed by these mechanisms. We also expected to find that the mission immigration staff conducts quality assurance exercises for its activities and for those of third parties, such as the VAC, and uses the results of these reviews to improve operations. Formal risk management and monitoring practices assist in operational decision-making, allocation of resources and identification of internal and external factors that may preclude the achievement of organizational objectives.

The mission had completed the annual Managerial Checklist, which is a mandatory assessment against a standard list of risk indicators as determined by the International Region at National Headquarters. The IPM periodically discusses risks with the International Region at National Headquarters through emails and other communications. The Report on the Audit of the Immigration Program in Warsaw has recommended that a greater consolidation of mission-specific risk information at National Headquarters would help missions reduce gaps in local knowledge when officers rotate between assignments. It would also ensure that reliable information is available for decision-making and for allocation of financial and human resources across the network of processing offices (in-Canada and overseas). The Beirut mission would also benefit from this consolidation of risk information.

The implementation of a quality assurance regime allows an organization to ensure that processes are effective and working as designed. A quality assurance regime helps to detect, monitor and resolve issues before they materialize into risks. The risk of non-compliance with applicable laws, regulations and departmental procedures is reduced by testing and identifying whether gaps in controls exist. These exercises are also helpful in identifying inefficiencies or areas where additional resources are required to reduce the risk of operational objectives not being achieved.

The Beirut mission performed quality assurance activities over VAC operations and sent monthly reports to National Headquarters, as required; the detail provided in these reports was recognized by National Headquarters as a good practice.

The mission committed to executing two quality assurance activities for application processing during the audit period as part of the International Region Integrated Management Plan (IRIMP), the annual planning exercise. The mission did participate in one regional anti-fraud exercise during the audit period but did not complete its two exercises as planned. However, occasional informal quality assurance was done by the IPM on individual files at the request for visa stage during officer absences.

Due to competing priorities - transitioning the office to full-service, ongoing construction, and participating in business continuity planning exercises - there were insufficient resources available for the implementation of formal quality assurance activities. These findings are consistent with those of previous mission audits: quality assurance activities are frequently set aside when competing priorities arise or when additional pressures are placed on the mission. Further work and assistance from National Headquarters is required to ensure that an effective quality assurance regime is in place across the entire network of visa offices, regardless of whether a certain mission is undergoing significant transition.

Recommendation 3 (High): The Beirut mission should implement formal quality assurance mechanisms.

Recommendation 4 (High): The Operations Sector should provide assistance to all missions for the planning and resourcing of an effective quality assurance program.

Control

We expected to find that controls over administrative, financial and operational activities, including access to the immigration work space and systems, application processing, controlled documents, cost recovery, and administrative expenditures, were in place at the mission to ensure compliance with legal, policy and operational requirements.

In a mission context, strong internal controls help to ensure that the Immigration Program is delivered in compliance with applicable guidance, assets and revenues are managed and safeguarded, and expenditures are made in compliance with key financial policies. Controlling access to immigration systems and work space helps to ensure that information and assets are available only to individuals who require them to perform their duties and support delivery of the immigration program.

Improvements are required to ensure that access is limited to the software used to conduct program activities and that maintenance is performed.

Some GCMS accounts for a few former ELES and TD officers were still active at the time of the audit site-visit but were deactivated immediately following the visit. The list of user profiles and access rights to the POS+ system, used for the recording of revenues, requires updating to ensure access is given only to individuals who require them to perform their duties. Regular maintenance activities should also be performed on the POS+ system to ensure it functions properly.

Access to the immigration work space and records is limited to the extent possible, given ongoing issues with construction.

The applications sampled as part of the audit were processed in line with standardized departmental procedures; however, three areas of weakness were identified. Firstly, the paper copy of refusal letters, required under current retention guidelines in the event of an appeal, were not on file for the temporary resident applications sampled; however, electronic copies of the refusal letters were found in GCMS. As the Department moves increasingly toward the implementation of electronic submission of applications for clients as well as electronic processing software, it will become necessary to revisit retention policies to ensure they are aligned with CIC’s business processes.

Secondly, solemn declarations for permanent resident applications were also not signed by applicants following an interview; the lack of this declaration could expose the Government of Canada to risk if the applicant were to appeal, as the evidence obtained in the interview could make the applicant inadmissible. This issue was raised in the Audit of the Immigration Program at the Canadian Mission in Nairobi, and an operational reminder was sent to staff at the end of the audit period for Beirut; therefore, no recommendation will be made in this report.

Thirdly, the refugee loan form used at the mission during the audit period did not require an officer to print his or her name, which allows for the level authority required for the loan to be assessed; however, all loans reviewed were granted within program terms and conditions and fell under the $10,000 threshold after which the IPM signature is required. Under the current memorandum of understanding with the International Organization for Migration, which administers the loans on CIC’s behalf, loan agreements cannot exceed $10,000. Therefore, CIC’s guidance should be updated to reflect the agreement in place, and this threshold should be centrally monitored by Finance.

Weaknesses were observed in the application of controls over cost-recovery activities: there was minimal evidence of oversight and monitoring of the accuracy of payment information entered into POS+; official receipts for submission of cheques to DFATD were not kept in CIC's cost recovery files and cheques were not locked prior to submission to DFATD; although payments were entered daily into POS+ by the Cost Recovery Clerk, the reconciliation by the cost recovery officer was performed on a weekly basis rather than daily as is required; and the monthly certification of revenues for March 2013 was not completed, although all other months were certified by the IPM and the DFATD Management Consular Officer.

The cost recovery weaknesses identified were due to a lack of training and awareness of cost recovery responsibilities. Strong controls over cost recovery, including training, are needed to ensure that revenues are collected and are accurately recorded and accounted for, and to reduce the risk of exposure to malfeasance. The audit noted that assistance from the DFATD accounting section was valuable in ensuring some of these controls were in place. For example, the DFATD Finance Officer kept an ongoing monthly record of the reasonableness of CIC revenues recorded in POS+ and bi-weekly deposits to the DFATD main account.

Some weaknesses were noted in the application of controls over forms management: a sign-out/sign-in log was not used at the mission when forms were removed for printing and replaced in the working safe at the end of the day; and the mission’s electronic inventory records in the Controlled Key Forms Inventory Tracking System (CKFITS) were not up to date. Seals kept in the Official Residence for emergency purposes were not recorded in CKFITS at the time of the site-visit; these seals were subsequently added to the electronic inventory.

Strong controls are required for the management of controlled forms to ensure the safeguarding and accurate recording of valuable assets. Misplacement of these assets could pose a significant risk to Canadians if they were inappropriately used for entry to Canada.

Recommendation 5 (Medium): The Beirut mission should implement standard departmental procedures for cost recovery, forms control and systems access to ensure that effective controls are in place for delivery of the immigration program in line with departmental requirements.

In high-risk environments such as a mission, internal controls help to ensure that expenditures are made in compliance with key financial policies and acts.

The documentation of pre-approvals and certification for section 32 of the Financial Administration Act was absent in 25% of the travel files reviewed. Pre-approvals for overtime by CBOs were documented for some instances, but not on a consistent basis. These findings indicate non-compliance with the Financial Administration Act and departmental financial delegation instruments and authorities. Having these controls in place helps to ensure that expenditures are properly authorized and that resources are used appropriately and helps reduce the risk of budgets being exceeded.

These findings are consistent with those noted in previous audits of missions (2013 in Nairobi and Lagos and 2014 in Warsaw). A thorough review of administrative tools, combined with increased awareness sessions on financial delegation and certification requirements, are therefore necessary to ensure that this issue is resolved across the network of missions abroad.

Recommendation 6 (High): The CIC Finance and Operations Sectors should strengthen officers’ awareness of approval, verification and review of processes for operational expenditures to ensure compliance with the Financial Administration Act. The CIC Finance and Operations Sectors should ensure that these administrative tools are understood and should monitor their application.

Appendix A – Control Summary

The conclusions reached for each of the audit criteria used in the audit were developed according to the following definitions:

Well Controlled

Well managed, no material weaknesses noted; and effective.

Controlled

Well managed, but minor improvements are needed; and effective.

Moderate Issues

Has moderate issues requiring Management focus (at least one of the following two criteria need to be met):

• control weaknesses, exposure is limited because likelihood of risk occurring is not high;
• control weaknesses, exposure is limited because impact of the risk is not high.

Significant Improvements Required^{Footnote 3}

Requires significant improvements (at least one of the following three criteria need to be met):

• financial adjustments material to line item or area or to the department; or
• control deficiencies represent serious exposure; or
• major deficiencies in overall control structure.

Line of Enquiry: Governance

Audit Criteria 1.1

Roles, responsibilities and accountabilities for the Immigration Program are clearly defined and communicated.

Conclusion

Moderate Issues

Evidence

• A new organizational chart and reporting structure for the immigration program was established and communicated during the audit period; implementation of the new structure was ongoing at the time of the site-visit.
• Acknowledgment of Immigration Program cost recovery responsibilities had not been completed by staff performing cost recovery duties.
• Delegated financial authorities have been established and documented.
• Designated decision-making authorities are appropriate at the mission and commensurate with roles and responsibilities.
• Staff members are provided with training on the job in order to discharge their responsibilities; however, there were gaps in training for single assignment officers for functional duties, such as cost recovery.

Audit Criteria 1.2

Resources are planned and managed to support delivery of the Immigration Program.

Conclusion

Controlled

Evidence

• Processes are in place for budgeting and approval of program resource allocation. The mission follows the IRIMP process and uses the monthly budget revisions to review and update expenses. If allocations are not anticipated to be used during the fiscal year, e.g. hospitality or ELES funding, they are returned to National Headquarters.
• Program performance information from National Headquarters is used to support decision-making, resource allocation, service standards and achievement of targets. Individual units track cases and percentage of target achieved, which helps to identify pressures and priorities.
• Human resources are managed to meet program delivery requirements; however the mission continues to require significant emergency and additional resources to aid in the transition from a partial to a full-service office, resolve information management issues related to construction at the mission, and to stabilize operations. Resource planning from National Headquarters is outside the scope of the audit.

Audit Criteria 1.3

Public service values and ethics are promoted within the mission, documented, and clearly communicated.

Conclusion

Well controlled

Evidence

• Staff members were made aware of and acknowledge their obligations regarding values, ethics and conflict of interest.
• All letters of offer now include an obligation to read the code of conduct of the Government of Canada.
• Long-term LES participated in training sessions and completed a mandatory, online values and ethics survey in 2011.
• Immigration LES have developed a common approach to dealing with questions and potential conflicts of interest outside of the workplace.

Line of Enquiry: Risk Management and Quality Assurance

Audit Criteria 2.1

Risk management practices are integrated into mission operations and support the maintenance of program integrity.

Conclusion

Controlled

Evidence

• Mechanisms exist to assess controls in place at the mission, to identify, and to mitigate risks to the Immigration Program. The Managerial Checklist was completed, as required.
• Risks were periodically monitored throughout the year with the IR at National Headquarters.
• Risk informs operational and financial decision-making. Staff frequently participates in security exercises, and business continuity planning is a priority. Following the closure of Damascus, Head of Mission approval was requested to extend ELES beyond 90 days to help with the transition and increase in caseload.
• The travel and hospitality budget favours refugee partner meetings and exchanges; the refugee business line is a relatively new and high profile caseload for the mission.

Audit Criteria 2.2

Quality assurance measures, including oversight of third-party service providers, are in place at the mission level to support program integrity.

Conclusion

Moderate Issues

Evidence

• A formal quality assurance mechanism for application processing was not in place at the mission during the audit period; however, informal quality assurance is done by the IPM on individual files during officer absences. The mission also participated in one regional anti-fraud exercise during the audit period.
• Subsequent to the audit period, the mission developed a quality assurance plan for future activities.
• Quality assurance mechanisms over services provided by the Visa Application Centre (VAC) have been put in place at the mission. The mission performs unannounced visits to the VAC and submits monthly reporting, as required, which is noted as a good practice.

Line of Enquiry: Control

Audit Criteria 3.1

Controls are in place to ensure appropriate access and use of the mission’s Immigration Program systems and a secure work space. 

Conclusion

Moderate Issues

Evidence

• Access to GCMS is controlled within guidelines, authorities and position requirements. Some former ELES accounts were deactivated following the site-visit.
• A number of former employee POS+ profiles were still active at the time of the site-visit. System maintenance, such as archiving and compacting, is not routinely performed.
• Access to CKFITS is consistent with operational guidelines, designated authorities and position requirements at the mission.
• Access to the immigration work space and controlled information and records is managed to the extent possible, given the effects of construction at the mission and the security context.

Audit Criteria 3.2

Immigration applications are processed in accordance with standard departmental controls.

Conclusion

Controlled

Evidence

• Some mission-specific standard application processing procedures were documented at the mission and saved on the shared drive; however, procedures for all units had not been documented.
• Hard copy refusal letters were not kept in 14/34 visitor files reviewed, as required by document retention guidelines. Electronic copies of the refusal letters for all files reviewed are stored in GCMS.
• Solemn declarations were not signed by all permanent resident applicants who participated in interviews. This issue was also noted in the 2013 Report on the Audit of the Immigration Program at the Canadian Mission in Nairobi; consequently, an Operational Reminder was issued to missions.
• Key decisions were made in compliance with designated authorities.
• The refugee loan form used at the mission does not require an officer to print his or her name, which allows for the level authority required for the loan to be assessed; however, all loans reviewed were granted within program terms and conditions and fell under the $10,000 threshold after which the IPM signature is required. This issue was highlighted in the 2013 Report on the Audit of the Immigration Program at the Canadian Mission in Nairobi.

Audit Criteria 3.3

Cost recovery is performed in accordance with standard departmental controls.

Conclusion

Moderate Issues

Evidence

• Some standard procedures for cost recovery were not in place at the mission, including oversight and quality assurance of transactions, maintenance of POS+ system, filing of an official receipt provided from DFATD in exchange for financial instruments, and secure storage of financial instruments prior to providing to DFATD for deposit.
• Voids and refunds were generally processed according to standard procedures. The rate of exchange used for cost recovery transactions reviewed was appropriate during the audit period.
• Reconciliation in POS+ is performed weekly, as opposed to daily as required by the Cost Recovery Manual. An exemption from the daily requirement may be requested from National Headquarters; however, the mission has not made this request.
• Monthly certification of deposit of revenues is performed regularly; however, the month of March during the audit period was not completed.
• Reasonableness comparisons between the monthly POS+ records and bi-weekly bank deposits are maintained by DFATD.

Audit Criteria 3.4

Controls are in place to ensure the safeguarding and handling of controlled documents in accordance with the forms management program.

Conclusion

Moderate Issues

Evidence

• A sign-out and sign-in log is not maintained for the removal of counterfoils from the working safe for printing.
• Reconciliation of foils is done weekly in CKFITS, rather than daily.
• Inventory is generally managed; however, emergency inventory of 500 seals was not included in CKFITS at the time of the site visit and was subsequently added to the system.
• Quarterly inventory reporting was performed in a timely manner, as required.

Audit Criteria 3.5

Controls are in place to ensure administrative activities are conducted in compliance with applicable policies and regulations.

Conclusion

Moderate Issues

Evidence

• Certification per Section 34 of the Financial Administration Act for travel claims is often signed by an individual without authority to do so on CIC’s behalf.
• Hospitality expenditures were managed in compliance with legislation and policy.
• Documentation of pre-approvals for travel and overtime expenditures was inconsistent.
• Performance agreements were not completed for immigration staff during the audit period.
• All ELES extensions beyond 90 days were approved by the Head of Mission as required.

Source: Data from International Region (NHQ) records as at June 3, 2014.

Note: All data above is in persons rather than cases. A case consists of an application that may include multiple applicants (persons), for example a family.

Appendix C – Management Action Plan

Recommendation 1

The mission should formally identify and address work objectives and training needs for mission immigration staff. The mission should also ensure that individuals with cost recovery duties sign an acknowledgement of having read the Cost Recovery Instructions and Undertakings.

Management Response:

Accepted. At the time of the Immigration Program’s reorganization of business lines in the fall of 2013, staff members were informed verbally and in writing of the instituted changes. The IPM also met with each employee to address staff member concerns regarding the new structure and held an all-staff retreat on February 27, 2014, to discuss the themes of teamwork and change management. The Beirut mission established a generic job description for each LES member classification level and continues to work with staff members to address any concerns with the new structure.

In August 2014, a newly arrived CBO assumed responsibility for cost management. In advance of his arrival, he was informed that he would be taking on this role and was instructed to take all possible steps to inform himself of the responsibilities and core materials.

Action Plan:

• The mission completed the recent 2014-15 performance objective-setting exercise and formally reiterated the respective roles and responsibilities of each employee.
  • Risk Ranking: Medium
  • Responsibility: Beirut mission
  • Target Date: Q1 2014-15
• Prior to his arrival at the mission, the new Cost Recovery Officer received and reviewed the Cost Recovery Manual and additional guidance.
  • Risk Ranking: Medium
  • Responsibility: Beirut mission
  • Target Date: Q2 2014-15
• At the mission, the Cost Recovery Officer received guidance from the IPM and on-the-job training by the previous Cost Recovery Officer at the mission.
  • Risk Ranking: Medium
  • Responsibility: Beirut mission
  • Target Date: Q2 2014-15
• On August 22, 2014, at the conclusion of his first week in Beirut, the new Cost Recovery Officer signed all of the necessary undertakings and has confirmed that he clearly understands his duties and responsibilities.
  • Risk Ranking: Medium
  • Responsibility: Beirut mission
  • Target Date: Q2 2014-15
• The Beirut mission is providing opportunities for cross-training within and between the various teams at level.
  • Risk Ranking: Medium
  • Responsibility: Beirut mission
  • Target Date: Q3 2014-15

Recommendation 2

The Operations Sector should ensure that single assignment officers receive sufficient training to perform functional responsibilities, such as cost recovery and forms control, at the mission.

Management Response:

Accepted. Cost recovery and forms control responsibilities are not normally given to officers on a first posting at the FS01 level, which is the case for most single assignment officers. This role is usually given to a foreign service (FS) officer at the FS02 level. Beirut is an exception, as there are currently no FSs posted there.

The roles and responsibilities of forms control and cost recovery officers are clearly described in the forms control and cost recovery manual. The manuals specify that the IPM is responsible for ensuring that cost recovery / form controls officers understand their roles and responsibilities and follow procedures as described in the manuals.

The International Region Training team (RIRT) delivers modules on cost recovery and form controls to new FS officers during the 6-week training they receive. These topics are also covered during the annual course for IPMs.

RIRT gives a 2-week course to single assignment officers before they go on posting. There is no room to include a module on cost recovery / forms control; however, RIRT has posted the manuals and other relevant information on its Wiki.

Action Plan:

• RIRT will underline the IPM’s role during IPM and FS training sessions and by ensuring that cost recovery / forms control officers are adequately trained, especially if they are single assignment officers.
  • Risk Ranking: Medium
  • Responsibility: RI
  • Target Date: On-going
• Cost Recovery and Forms Control module material from the FS training will be available to future single assignment course participants, and we will insist on the importance of knowing and following the instructions, should cost recovery / forms control responsibilities be given to them.
  • Risk Ranking: Medium
  • Responsibility: IR
  • Target Date: On-going

Recommendation 3

The Beirut mission should implement formal quality assurance mechanisms.

Management Response:

Accepted. Program Integrity is part of the mission’s formal IRIMP for 2014-15. Within this, Beirut has participated in network-wide program integrity exercises, including a significant review of privately sponsored refugee (PSR) files in Q4 (2013-14). Moreover, anti-fraud verifications carried out as required have been maintained throughout the period, and records of these verifications were shared with the audit team.

Now that Beirut has its full complement of CBOs and there is a foreseeable end to the embassy renovations, the mission is in a position to proceed with two mission-specific program integrity (PI) activities that were planned for 2014-2015.

Action Plan:

• The first PI exercise regarding services provided by the VAC will be undertaken.
  • Risk Ranking: High
  • Responsibility: Beirut mission
  • Target Date: Q3 2014-15
• The Beirut mission will implement the second PI exercise relating to consistency in approach on admissibility for work-shared files (Bucharest/Beirut).
  • Risk Ranking: High
  • Responsibility: Beirut mission
  • Target Date: Q4 2014-15

Recommendation 4

The Operations Sector should provide assistance to all missions for the planning and resourcing of an effective quality assurance program.

Management Response:

Accepted. CIC’s Program Integrity Framework (PIF) provides CIC staff with guidance for incorporating risk management, quality assurance, and fraud detection and deterrence principles into their daily work. The Program Integrity Division (PID) developed various tools, e.g. online PI tool, the Program Integrity Exercise Guide and the Quick Start Guide, in support of the Operations Sector’s formal risk management practices. PID relies on the collaborative nature of the IR network to support the dissemination of functional guidance related to program integrity. PI publications, including Program Integrity Updates and tools, are available on Connexion.

Action Plan:

• PID will receive and monitor required submission of PI exercises (minimum 2 per year) by all missions.
  • Risk Ranking: High
  • Responsibility: PID
  • Target Date: Q4 2014-15
• PID will provide feedback to missions, using a standardized template, to improve quality and consistency of PI activities conducted by CIC staff and to contribute to network-wide improvements year to year.
  • Risk Ranking: High
  • Responsibility: PID
  • Target Date: Q4 2014-15
• PID has provided, and will continue to provide, training in person or via web conferencing on the use of PI tools to staff at National Headquarters, as well as in the domestic, centralized processing and international regions.
  • Risk Ranking: High
  • Responsibility: PID
  • Target Date: Q4 2014-15

Completed training in the IR includes:

1. Asia: Ankara – November 2013; Singapore, Hong Kong, Beijing – January 2014
   • Risk Ranking: High
2. Europe: London and Paris – January 2014
   • Risk Ranking: High
3. South America: Sao Paolo, Brazil – February 2014; Mexico City – March 2014
   • Risk Ranking: High
4. Caribbean: Kingston, Jamaica (with IPMs from other area missions) – February 2014
   • Risk Ranking: High

Planned training in IR includes:

5. South East Asia - October or November 2014 – New Delhi (with possibility of officers from Chandigarh and Bangalore participating)
   • Risk Ranking: High

• PID will work with the IR to ensure that missions are sending reports to PID on a regular basis. On a monthly basis, PID will update the PI Exercise Repository with information from Quality Assurance, Quality Control and Anti-Fraud activities conducted across the CIC network (in-Canada and abroad).
  • Risk Ranking: High
  • Responsibility: PID
  • Target Date: Q4 2014-15

Action Plan (IR):

• In the short-term, in order to free Beirut resources to perform more effective PI exercises, IR will continue to explore the possibility of sharing workloads with other missions and will continue to provide Beirut with TD officers as required to support processing.
  • Risk Ranking: High
  • Responsibility: IR
  • Target Date: Q4 2014-15
• Centralization of case processing formerly done abroad frees IR resources for FS to devote more time to quality PI exercises. IR also received additional resources of 8 CBO and 15 LES positions starting next year that are expected to focus on supporting increased PI as centralization increases.
  • Risk Ranking: High
  • Responsibility: IR
  • Target Date: Q4 2015-16

Recommendation 5

The Beirut mission should implement standard departmental procedures for cost recovery, forms control and systems access to ensure that effective controls are in place for delivery of the immigration program in line with departmental expectations.

Management Response:

Accepted.

Action Plan:

• Once the summer rotation is complete and all new staff are in place, Beirut will hold a Stewardship Retreat for CBOs to ensure that the Cost Management, Forms Control and GCMS officers are all completely aware of their responsibilities and able to fulfill their duties in these roles.
  • Risk Ranking: Medium
  • Responsibility: Beirut mission
  • Target Date: Q3 2014-15
• There will be regular quarterly CBO meetings to ensure that processes and account maintenance are current and on track.

Recommendation 6

The CIC Finance and Operations Sectors should strengthen officers’ awareness of approval, verification and review of processes for operational expenditures to ensure compliance with the Financial Administration Act. The CIC Finance and Operations Sectors should ensure that these administrative tools are understood and should monitor their application.

Management Response:

Accepted. IR Finance has developed a training session and package for IPMs, deputy IPMs and immigration officers on foreign posting. The training package contains information on key financial concepts. The training session is offered in Ottawa twice a year, in June prior to the posting period, and on the occasion of IPM meetings in Ottawa at calendar year end.

CIC Finance monitors the application of administrative tools by requesting a copy of the IPM’s budget report as part of the forecasting schedule. This ensures that the IPM reviews expenses incurred to date against the budget and ensures expenses are coded to correct cost elements. IR-Finance conducts a review of budget reports submitted by IPMs, ensuring that the report is signed by the IPM and that amounts add up correctly.

CIC also relies on DFATD accounting officers to perform monitoring as they review all payments approved by IPMs. CIC does not have copies of invoices at National Headquarters and therefore must rely on DFATD to perform this control.

Action Plan:

• All staff members at the Beirut mission with responsibilities in this regard have reviewed administrative procedures, as well as section 32 and section 34 requirements.
  • Risk Ranking: High
  • Responsibility: Beirut mission
  • Target Date: Q2 2014-15
• IR Finance sent the financial training package to the mission.
  • Risk Ranking: High
  • Responsibility: Beirut mission
  • Target Date: Q2 2014-15