Audit of the Immigration Program at the Canadian Mission in Nairobi

Audit Report
Internal Audit and Accountability Branch
Citizenship and Immigration Canada
June 2013

Table of Contents

• Executive summary
  • Objective
  • Why this is important
  • Key findings
  • Conclusion
• Statement of conformance
• Introduction
• Environmental context of the mission
• Findings: Governance
• Findings: Risk Management and quality assurance
• Findings: Internal control framework
• Appendix A – Nairobi processing summary 2009-2012
• Appendix B – Detailed audit criteria
• Appendix C – Management action plan

Executive Summary

Objective

The three objectives of the audit were to assess the adequacy of:

1. the mission’s governance framework for administering the immigration program;
2. the mission’s risk management and quality assurance practices to support the delivery of the immigration program; and
3. the mission’s internal control framework over administrative, financial and operational activities related to the immigration program.

The scope of the audit includes the roles and responsibilities of the Citizenship and Immigration Canada (CIC) National Headquarters to support the delivery of the immigration program at missions. The time period covered by the audit is from September 1, 2011 to August 31, 2012, with the exception of an inventory count and reconciliation performed during the on-site examination in December 2012.

Why This Is Important

The 2002 Immigration and Refugee Protection Act (IRPA) is the legal federal framework for immigration and refugee protection in Canada. Through implementation of theIRPA in over 70 missions (embassies, consulates, High Commissions) worldwide, CIC employees manage access to Canada through receiving and processing applications for permanent and temporary residence.

The operating environment in which overseas immigration staff 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

We found that the governance framework in place at the Nairobi mission was sufficient. Some improvements are required to ensure that program roles, responsibilities and accountabilities are all clearly documented. Resources were planned and managed to support program delivery, and the importance of values and ethics was understood and promoted within the mission.

Risk management and quality assurance mechanisms were in place at the mission. Risk management practices could be strengthened by requiring documentation of mitigating strategies in the templates developed for missions by the Operations Sector.

Improvements to the internal control framework are required to ensure that manual cost recovery and forms management procedures comply with operational guidance, and that pre-approved administrative expenditures are consistently documented as required by the Financial Administration Act. Some improvements have already been initiated by the mission, but updates to guidance are also required from National Headquarters to ensure that procedures and expectations for missions are clear regarding applicant interviews, loans and management of controlled documents.

Conclusion

The governance framework at the Nairobi mission for administering the Immigration Program was adequate. The mission’s risk management and quality assurance practices were adequate. The mission’s internal control framework for administration, financial and operational activities related to the Immigration Program requires improvement.

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.

Gibby Armstrong
Chief Audit Executive
Citizenship and Immigration Canada

Introduction

Delivery of Canada’s Immigration Program abroad is the responsibility of the International Region (IR) in the Operations Sector at National Headquarters and its network of visa offices at missions abroad. IR manages an overseas workforce of 1,300 mission immigration employees consisting 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.

In addition to facilitating admission to Canada and providing operational support to mission staff, the IR is responsible for non-Immigration Program activities, such as resource management administration, performance analysis and reporting, liaising with foreign governments and program delivery partners. The IR is supported by other branches within CIC 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 and International Trade (DFAIT) under the terms of a Memorandum of Understanding.

Environmental Context of the Mission

The Nairobi mission is a full-service centre that provides immigration services to citizens of or persons legally admitted to Burundi, Comoros, Congo-Brazzaville, Congo-Kinshasa, Djibouti, Eritrea, Ethiopia, Kenya, Madagascar, Mauritius, Mayotte, Réunion, Rwanda, Seychelles, Somalia, South Sudan, Tanzania, Uganda and the French Southern Territories. The Nairobi mission also plays an oversight role for its two satellite offices, Kinshasa and Addis Ababa.

During the audit period of September 1, 2011, to August 31, 2012, the Nairobi mission employed 53 immigration full-time equivalents: 12 Canada-based Officers and 41 LES divided into temporary, permanent, refugee, registry and client service units. In addition, 67 temporary and Emergency Locally Engaged Staff (ELES) were employed by the mission for a term during the audit period.

The Nairobi mission received approximately 6,078 [1] permanent resident (PR) and 15,235 temporary resident (TR) applications and finalized 5,949 and 14,783 cases respectively during the audit period. The security situation in Kenya and neighbouring areas has contributed to a backlog in refugee application processing, as access to applicants in several refugee camps in the region continues to be restricted due to ongoing threats. Reliability of applicant information and documentation, particularly identity and family composition, is a consistent challenge for the Nairobi mission, which results in frequent referrals to the Migration Integrity Unit. Appendix A presents a summary of the Nairobi mission’s processing data for 2009–2012, and a comparison to CIC’s overseas network. 

For the purpose of application processing, the Global Case Management System (GCMS) has been implemented in the Nairobi mission, and the Computer-Assisted Immigration Processing System (CAIPS), still in use during the audit period, will be fully decommissioned in 2014. 

Findings: Governance

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 understood within the mission.

Roles, Responsibilities and Accountabilities

We expected to find that roles and responsibilities for all areas of the Immigration Program were clearly defined and communicated in the mission. We also expected to find that financial accountabilities for the Immigration Program and designated authorities for decision-making under the IRPA were appropriate within the mission.

We found that the Immigration Program’s organizational structure was clear and communicated, and that Immigration Program staff members actively participate in the governance of the mission through its various committees. Immigration Program roles and responsibilities were clear, although inconsistently documented. The roles and responsibilities of the PR unit were documented; however, the roles and responsibilities of the remaining units were developed after the audit period as part of the mission’s standard operating procedures.

Canada-based Officer roles for specific functions, such as Forms Control Officer, Cost Recovery Officer and CAIPS/GCMS Manager, as well as back-ups, had been determined. Although individuals assigned to cost recovery were aware of their responsibilities, they had not formally acknowledged them in writing as required by the CIC Cost Recovery Manual. Training for the discharge of duties was provided to staff as the need arose, either due to operational requirements or performance appraisals.

Accountabilities for decision-making were appropriate and delegated financial authorities were established and documented. CIC staff with delegated authority sign both a CIC and DFAIT signature specimen card. CIC signature specimens had not yet been updated to include Section 32 of the Financial Administration Act, in accordance with CIC’s most recent delegation of authority matrix introduced following the audit period. More clarity is required from National Headquarters whether multiple signature specimens are needed at the mission.

Recommendation 1 (Low Risk):

The Nairobi mission should ensure that all individuals assigned cost recovery duties read and acknowledge in writing the Cost Recovery Instructions and Undertaking for their respective roles.

Recommendation 2 (High Risk):

The CIC Operations Sector should clarify with DFAIT whether there is a need for multiple mission signature specimen cards and ensure that delegated authority under Section 32 of the Financial Administration Act is included on the CIC signature specimen cards.

Resource Management

We expected to see that processes were in place to ensure that financial and human resources were planned and managed to support program delivery and that program performance tracking informs decision-making and resource allocation.

Processes were in place for planning and managing financial resources to deliver the Immigration Program. The call letter from IR for the annual International Region Integrated Management Plan (IRIMP) is the catalyst for the mission’s budget planning. Budget requests are a combination of detailed estimates based on program delivery needs, such as travel, and estimates based on the previous year’s figures. Transfers between budget lines with caps, such as travel and training, were pre-approved by IR. Room rentals for interviews as part of area trips were requested and approved in the budget allocation as travel and subsequent transactions attributed to the travel General Ledger, which inflated the mission’s overall travel costs. Other expenditures, such as translation services—which are not travel but incurred as part of the trip—are currently coded separately by the mission. This same treatment should also be applied to room rentals to ensure operating expenditures are accurately reflected and to provide reliable information for establishing future budget requirements.

The mission planned and managed its human resources to meet program delivery requirements. The mission, as part of its resourcing strategy, deploys its TD officers into the field to perform resource-intensive activities, such as interviews for refugee cases. The Registry Unit rotates LES through responsibilities to provide staff with learning opportunities and to ensure that back-ups are trained and readily available for all positions. Program performance tracking, both in-mission and with IR statistics, reports and informs resource allocation; as needed, additional temporary or emergency resource funding may be requested or staff may be transferred from one unit to another to facilitate the achievement of targets. 

Recommendation 3 (Low Risk):

The CIC Operations Sector should ensure that travel budget requests and transactions are attributed to the appropriate General Ledger code to accurately reflect expenditures. 

Values and Ethics

We expected to see that the Immigration Program staff has been made aware of, and acknowledged in writing, their obligations regarding values, ethics and conflict of interest.

The requirements for values and ethics were in place at the mission. Signed codes of conduct were on file for all Immigration Program LES and ELES human resource files reviewed and values and ethics were communicated at the mission through staff meetings and emails.

Findings: Risk Management and Quality Assurance

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 this assessment. We also expected to find that the mission conducts quality assurance exercises and uses the results of these reviews to improve operations.

The mission provided a general overview of risks in its IRIMP and Managerial Checklist, a questionnaire designed by the CIC Operations Sector to help identify risks at missions, although missions are not required to identify mitigation strategies for these risks. Given the rotational nature of mission staffing, there is a risk that if these mitigation strategies remain undocumented, they will be lost or must be recreated in the event of staff turnover. The Migration Integrity Unit—comprised of Canada Border Services Agency staff working at the mission—identifies and documents risk indicators for application assessment by CIC, such as associations or high probability of fraudulent documentation. This risk information compiled by the Migration Integrity Unit has been used by the mission’s Immigration Program to request additional emergency and permanent resources for the unit.

The Immigration Program had completed its critical function sheets as required for business continuity planning purposes. The mission’s emergency plan, which includes mission-wide business continuity planning and is the responsibility of DFAIT to complete in consultation with its partners, was under development at the time of the audit.

The mission had conducted quality assurance exercises during the scope of the audit, including a mix of quality of decision making and processing accuracy. Some results of the exercises were used to identify training needs and improve operations, whereas the results of other exercises had not been reviewed for this purpose. The mission plans to develop a quality assurance framework to schedule regular annual exercises as opposed to ad-hoc reviews.

Measures are in place to ensure proper tracking of files received from and sent to Visa Application Centres (VACs), but no formal quality assurance is done on the services provided. Until procedures for missions for quality assurance over VACs are released by National Headquarters under the upcoming global contract, issues are dealt with by the mission’s VAC liaison.

Recommendation 4 (High Risk):

The CIC Operations Sector should update its risk management template requirements to include documented Immigration Program-wide risks and mitigating strategies. 

Findings: Internal Control Framework

We expected to find that controls for 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.

Systems and Work Space Access

We expected to find that access to and use of the mission’s Immigration Program systems were appropriate and that the work space was secure.

A review of the CAIPS accounts at the mission indicated that some accounts for previous Temporary Duty Officers, accounts created in error and unassigned accounts had not been deleted or disabled. We also found that system maintenance had not been performed and monitored since the GCMS had been rolled out at the mission due to a system error. The issue has since been rectified and all erroneous user accounts have been disabled or deleted by the CAIPS Manager. As CAIPS will be decommissioned at the mission by 2014, no recommendations will be made.  

Similar to CAIPS, some previous ELES and former TD Officers no longer at the mission still had active GCMS accounts. The mission hires many of the same ELES each year and does not request the removal of their accounts to reduce the administrative processes required when they return to work. In the May 2012 Audit of System Access Controls, a recommendation was made to address the issue of review procedures for the GCMS accounts and management identified an action plan item in that report. Further follow-up will be done with the GCMS Access Control Unit to ensure this information has been communicated to all Access Security Coordinators.

Access to the cost recovery Point of Sale system (POS+) and the forms management inventory system, the Controlled Key Forms Inventory Tracking System (CKFITS), was appropriate and consistent with operational guidelines, designated authorities and position requirements at the mission. There was no record of system maintenance, such as archiving, performed on POS+ during the audit period, which is required to keep the system functioning properly.

Access to the mission is limited to authorized individuals through the Intrusion Detection Access Control System (IDACS), key and codes, as required. The immigration section is located over two floors and the space is shared with DFAIT and CIDA. Restricting physical access to the immigration work space cannot currently be achieved due to the office layout, therefore non-immigration staff members have been asked not to enter the immigration section without a specific purpose. Access to the deep storage vault in the high-security zone is restricted through IDACS, overseen by mission security, and cell phone use is not permitted in the high-security zone, in accordance with DFAIT policy. All PR unit officers and TR unit officers have access to working storage safes, which hold the daily supply of counterfoils and seals.

Recommendation 5 (Medium Risk):

The Nairobi mission should perform regular maintenance on POS+, as required by operational procedures, to ensure proper functionality of the system per the POS+ system user guide. 

Application Processing

We expected to find that standard procedures were in place for processing TR and permanent resident travel document (PRTD) applications, that key decisions were made by the appropriate authority, that applications were complete, and that files were adequately documented.

Standard procedures were in place for processing PR applications and some procedures for Temporary Duty Officers assigned to the refugee unit had also been documented. TR and Registry unit procedures were completed after the scope of the audit period.

For all TR, PR, Refugee and PRTD files reviewed, eligibility, admissibility and final decisions were made by individuals with designated authority to do so and documentation on file and in case notes for most files was adequate to support compliance with relevant legislation, policies and procedures. Few solemn declarations on the applicant background information form (IMM5669 – Schedule A) were signed by PR applicants who had been interviewed, although the mission stated that the standard procedure was to have the declarations signed. It is unclear whether CIC requires this signature of all interviewees, as the form states only that the applicant may be required to sign, and current guidance for mission staff does not address the issue. In the event of a refusal, the lack of this declaration could expose the Government of Canada to risk if the applicant were to appeal, as evidence obtained in the interview could make the applicant inadmissible.

Loans and warrants reviewed were made in compliance with program terms and conditions. Determining whether the Immigration Loan Form (IMM-0500E) was authorized by the appropriate authority was difficult since there is no field on the form in which to include the signing officer’s name or the Immigration Program Manager’s name. Further, it is standard practice globally for an officer to authorize the loan or warrant with the amount blank and then forward it to the International Organization for Migration for costing, although an officer may only authorize up to $10,000, after which the Immigration Program Manager’s signature is required. Although no issues were observed in the audit, if there is no requirement to include the officer’s name on completed loan forms, it is difficult to determine whether loans were authorized by an individual with the appropriate authority.

Recommendation 6 (Medium Risk):

The CIC Operations Sector should clarify operational procedures and requirements for completion of the solemn declaration on the applicant background information form (IMM 5669 – Schedule A) to ensure that information supplied in the interview is accurate.

Recommendation 7 (Low Risk):

The CIC Operations Sector should update the Immigration Loan Form (IMM-0500E) to include a field for the authorizing officer’s name and clarify procedures for completion of the form when costs are unknown or when additional authorization is required from the Immigration Program Manager following the calculation of costs.

Cost Recovery

We expected to find that controls were in place at the mission to ensure that immigration revenues are safeguarded and that cost recovery activities are performed in compliance with applicable legislation, policy and standard operating procedures.

The mission accepts payment by certified instruments (e.g. money orders, certified bank cheques) only and in three currencies: Canadian dollars, American dollars and Kenyan shillings. Prior to the on-site examination, the Cost Recovery Officer had implemented new procedures, including changing daily reconciliation and remittance of immigration revenues to DFAIT to a weekly occurrence, at the request of mission Finance; however, daily transfer of funds is required by departmental policy and the CIC Cost Recovery Manual. We also found that accountability and procedures for follow-up on returned cheques during the audit period was unclear between CIC and DFAIT. These responsibilities have since been clarified and follow-up with the banks is carried out by the Cost Recovery Officer.

There were controls in place for recording and processing cost recovery transactions, although documentation was lacking on file to explain small overpayments and the reasons for voids. Refunds for payments received in previous years were coded to the current year’s General Ledger account and not the previous year’s, as required by the Standard Financial Procedures for Immigration Fees Collected at Missions – Official Agreement Between DFAIT and CIC. Some refund request forms reviewed were incomplete when submitted to Mission Finance for processing; however, all refunds reviewed were appropriate.

Reconciliation and certification procedures were performed during the audit period, as required. Monthly certification of immigration revenues in Nairobi was facilitated by CIC providing a copy of the end-of-day reconciliation (1203A) report to which manual changes were made; this process was noted as a good practice. IPM certification of revenues for all satellite offices was not possible during the audit period, as the individual charged with overseeing cost recovery in Addis Ababa did not use the POS+ system due to a software installation issue. At the time of the audit, the missions had developed a temporary manual solution to use until the system was properly installed.

Recommendation 8 (Low Risk):

The Nairobi mission should ensure that end-of-day reconciliation procedures are performed in accordance with the Cost Recovery Manual and thejoint DFAIT and CIC Standard Procedures for Fee Collection or seek authorization from National Headquarters for an exemption.

Recommendation 9 (Low Risk):

The Nairobi mission should ensure that refund request forms are complete prior to authorization and that payments are coded to the appropriate General Ledger account.

Controlled Documents

We expected to find that standard procedures were in place to ensure the safeguarding and handling of controlled documents such as visa counterfoils and seals, in accordance with the forms management program.

Documented standard forms management procedures were developed and implemented by the current Forms Control Officer after the audit period. Daily management and reconciliation for PR counterfoils was shared by all officers in the PR unit and rotated on a weekly basis, which resulted in inconsistent application of procedures, such as the signing-out and signing-in of forms for printing purposes, and requires additional monitoring.

Control weaknesses in the manual tracking of forms were observed. A daily sign-out and sign-in log for the printing of counterfoils was not in place during the audit period but has since been implemented by the current Forms Control Officer. Manual records were maintained to trace visas and seals used and cancelled, although an inventory count revealed some seals that had previously been consumed but that had not been entered into the CKFITS, thus overstating the actual inventory. Records for the receipt of forms at the mission had not been consistently signed by the Forms Control Officer or a witness, as required. In addition, there was no documentation on file for the audit period to support Immigration Program Manager review of quarterly reporting prior to submission to National Headquarters.

All counterfoils and seals at the mission were accounted for through the on-site inventory count; however, weaknesses in the electronic tracking and quarterly reporting functions within CKFITS were identified, which resulted in unreliable electronic inventory records. The system calculations of the mission’s opening inventory for seals differed from the previous ending inventory amount for the first, second and third quarter of 2012. Further, the calculation of the quarter-ending inventory using the amounts recorded in the opening inventory, usage, receipt and transferred fields was incorrect due to a system error. Confirmation of actual inventory movement was achieved through a physical inventory count, manual inventory tracking records and discussions with Forms Management at National Headquarters.

In addition to the system issues noted above, the CKFITS quarterly reporting function used by missions does not provide for compliance with forms management policy and guidance. For example, there is no electronic control to ensure that the Immigration Program Manager reviews the report prior to submission to National Headquarters, as required by policy. This observation was previously noted in the 2012 report of the Audit of the Immigration Program in Mexico City; however, the issue remains and interim guidance was not provided during the audit period for missions to follow until the issue has been resolved.

Current guidance for controlled documents requires updating. Responsibility for forms management is split between CIC’s Operational Management and Coordination Branch (OMC) and the Solutions and Information Management Branch (SIMB). OMC is responsible for the forms management policy and functional guidance for missions while SIMB is responsible for the CKFITS and its system user guide. Documented procedures which were previously manual, such as quarterly reporting and ordering supplies of forms, have not been updated in the functional guidance to take into account current electronic procedures followed using the CKFITS. Collaboration is required between OMC and SIMB to ensure that the business requirements of the CKFITS are appropriate; to update the system, and functional and system guidance; and to ensure that electronic inventory tracking is reliable and that appropriate procedures are applied at missions.

Recommendation 10 (Medium Risk):

The Nairobi mission should ensure that standard procedures for forms management are implemented, including the daily sign-in and sign-out of forms, completion and reconciliation of the daily usage log and entry into CKFITS, signing for receipt of forms and transfers between missions, and Immigration Program Manager sign-off on quarterly reporting.

Recommendation 11 (High Risk):

The CIC Operations Sector and Corporate Services Sector should ensure that CKFITS system errors are rectified and that functional and systems guidance for forms management are aligned and meet current departmental policy requirements and strategic priorities.

Administrative Expenditures

We expected controls to be in place to ensure that travel, hospitality and overtime expenditures are managed in compliance with the applicable policies, regulations and collective bargaining agreements.

Although operational budgets were respected and not exceeded, weaknesses in manual controls over individual travel, hospitality and overtime expenditures were observed. Travel authorities were frequently signed after flights were booked and expenses incurred, and some of the travel estimates were insufficient to cover the final cost of the travel because all costs were not identified on the Travel Authority and Advance form. Hotel expenditures for some travel exceeded the city rate maximum according to the National Joint Council Directive and no justification was on file. Further, an updated Travel Authority and Advance form, which clarifies authorization of expenditures according to Section 32 of the Financial Administration Act and was introduced during the audit period, had yet to be used at the mission.

Quarterly and annual hospitality advances provided to the IPM were approved by the Head of Mission, as required, but no details or estimate for events were included as justification for the advance. DFAIT’s Official Hospitality Outside Canada Policy states that all hospitality advances are supported by an appropriate justification.

The majority of the mission’s overtime expenditures were related to travel and approved through the mission’s IRIMP. A portion of the mission’s overtime budget was allocated to each immigration program unit and expenditures were tracked throughout the year. Although documented pre-approval was not on file to support all individual overtime expenditures, the alternate controls in place were found to be sufficient. Inconsistent documentation of pre-approval for overtime was also noted in the Audit of the Immigration Program at the Canadian Mission in Lagos; therefore, this may be a systemic issue for further investigation by the CIC Operations Sector.

Immigration section LES and ELES were hired in compliance with applicable policies and directives and maximum term lengths for appointments were not exceeded. Performance appraisals were completed and on file for all LES and expectations were aligned with work descriptions and requirements.

Recommendation 12 (High Risk):

The Nairobi mission should ensure that administrative expenditures are pre-approved in accordance with the Financial Administration Act and applicable policies.

Appendix A – Nairobi Processing Summary 2009–2012

Appendix B – Detailed Audit Criteria

The sources of criteria for the audit are based on Citizenship and Immigration legislation, policies, guidelines and procedures, and on the Office of the Comptroller General Audit Criteria related to the Management Accountability Framework.

Objective 1: To assess the adequacy of the mission’s governance framework for administering the immigration program.

Criterion 1.1

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

• A clear organizational structure is established, documented, and communicated.
• Roles and responsibilities have been determined and documented.
• Delegated financial authorities have been established and documented.
• Designated decision-making authorities are appropriate.
• Staff are provided with the appropriate training in order to discharge their responsibilities.

Criterion 1.2

Resources are planned and managed to support Immigration Program delivery.

• Processes are in place for budgeting and program resource allocation.
• A framework is in place for planning and managing human resources to meet program delivery requirements.
• Program performance information is gathered and used to support decision-making, resource allocation, service standards and achievement of targets.

Criterion 1.3

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

• Staff are made aware of their obligations regarding values, ethics and conflict of interest.
• Processes are in place at the mission to deal with malfeasance and conflict of interest issues.

Objective 2: To assess the mission’s risk management and quality assurance practices to support the delivery of the immigration program.

Criterion 2.1

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

• Mechanisms are in place to identify and mitigate risks to the Immigration Program.
• Risks are periodically monitored throughout the year.
• Risk information informs operational and financial decision-making.
• Business continuity planning for the Immigration Program is in place at the mission.

Criterion 2.2

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

• Quality assurance and control mechanisms for program activities have been identified and implemented in the mission.
• Quality assurance activities for third-party service providers have been established and implemented.
• Issues arising from quality assurance activities are periodically reported to NHQ.

Objective 3: To assess the adequacy of the mission’s internal control framework over administration, financial and operational activities related to the Immigration Program.

Criterion 3.1

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

• Access to and use of GCMS/CAIPS is consistent with operational guidelines, designated authorities and position requirements at the mission.
• Access to and use of POS+ is consistent with operational guidelines, designated authorities and position requirements at the mission.
• Access to other applicable systems 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 limited to authorized individuals.

Criterion 3.2

Controls are in place to ensure that immigration applications are processed in accordance with applicable legislation, regulations, policies, and standard operating procedures.

• Standard application processing procedures, which incorporate applicable requirements, have been established and implemented at the mission.
• Applications are complete and required supporting documentation is maintained.
• Key decisions are in compliance with designated authorities.
• Warrants and loans are granted to applicants in accordance with program terms and conditions.

Criterion 3.3

Controls are in place to ensure that revenues are safeguarded and that cost recovery is performed in compliance with applicable legislation, policy, and standard operating procedures.

• Quality assurance and control mechanisms for program activities have been identified and implemented in the mission.
• Quality assurance activities for third-party service providers have been established and implemented.
• Issues arising from quality assurance activities are periodically reported to NHQ.

Criterion 3.4

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

• Standard procedures for forms management have been established and implemented at the office. 
• Inventory is managed and securely stored in accordance with program guidelines.
• Quarterly and periodic verification and reporting exercises are completed as required.

Criterion 3.5

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

• Travel expenditures are managed in compliance with applicable legislation and policies. 
• Hospitality expenditures are managed in compliance with applicable legislation and policies.
• Overtime expenses are approved and paid in compliance with applicable legislation and guidelines. 
• Other expenses are approved and paid in compliance with applicable legislation and policies.  (as applicable for special expenditures)
• Employees are hired and managed in compliance with applicable legislation and policies. 

Appendix C – Management Action Plan