Self-Assessment of Staffing Activities

Final Report
September 19, 2017

1.0 Background

In April 2016, the Public Service Commission (PSC) implemented a new human resources appointment framework. One of its goals was to improve the hiring practices of federal departments and agencies that fall under the purview of the PSC. In order to determine the extent to which the Privy Council Office’s (PCO) new staffing policy and staffing activities are consistent with and adhere to the PSC’s new appointment framework, a Self-Assessment of Staffing Activities was approved by the Clerk of the Privy Council in PCO’s 2016-2019 Risk-Based Audit Plan.

Appointment Processes at PCO

Within the Federal government, the Public Service Employment Act (PSEA), and both the PSC’s Appointment Policy and Appointment Delegation and Accountability Instrument (ADAI) all outline deputy heads’ roles and responsibilities in building their own staffing systems, in conducting ongoing monitoring, and in assessing their respective organization’s compliance with PSC requirements. The PSC Appointment Policy and ADAI collectively make up PSC’s new appointment framework which was implemented on April 1, 2016.

The Commissioner of the PSC delegates hiring authority to deputy heads of various government organizations who may, in turn, sub-delegate their authority to members of their management teams. Thus, through the PSC’s ADAI, the Clerk of Privy Council Office is accountable for exercising his delegated staffing authorities or sub-delegates this authority to PCO’s hiring managers.

In order to comply with the PSC’s appointment framework, PCO released its own staffing policy, effective April 1, 2016. This policy, which is in line with PSC guidelines, outlines the process by which the Clerk may sub-delegate some of his functions and to name sub-delegated managers. Eligible hiring managers are required to complete mandatory training prior to being granted a sub-delegate role. Once all requirements are met, a certificate is issued by the Corporate Services Division of Human Resources to the hiring manager.

In order to assist and support the hiring managers with their delegated duties, PCO’s Human Resources division prepared tools and training materials in April 2017 and also released an application guide to provide further guidance on the PCO staffing policy. Additionally, a checklist was implemented as of April 1, 2016 to ensure accuracy and completeness of appointment files.

Structure, Scope and Criteria of the Self-Assessment

The scope of the self-assessment conducted by PCO’s audit and evaluation division included an assessment of PCO’s new staffing policy and ADAI, which were both implemented on April 1, 2016. A sample of appointment files tested for compliance with PSC’s staffing framework was selected from the period April 1, 2016 to June 30, 2017. The criteria developed to satisfy the objectives of the self-assessment included the requirements established in PSC’s appointment framework.

The adequacy of the overall framework supporting PCO’s staffing policy was assessed through various means, including a thorough comparison against PSC’s Appointment Policy, management discussions, interviews with individuals involved in departmental appointments and compliance testing of a limited sample of appointments completed between April 1, 2016 and June 30, 2017.

2.0 Conclusion

In comparing PCO’s staffing policy, ADAI and related procedures to the PSC appointment framework, the overall conclusion of this self-assessment is that all PSC requirements have been addressed within PCO’s policy and related documentation. In addition, testing of a limited sample of appointment files demonstrated that the files were well organized and contained the expected supporting documentation to demonstrate compliance to PCO’s staffing policy. In addition, the appointment checklist was completed and included in all files within the sample. However, some issues were noted within the files that lead to some opportunities for improvement for PCO to:

  • ensure that any manager without sub-delegated authority who takes on staffing activities signs an attestation form, as is required by policy; and,
  • improve attention to detail and quality assurance procedures when entering information into the human resources system.

The following section details observations and opportunities for improvement. Recommendations, as well as management’s response and action plan have also been included in this report.

3.0 Observations and recommendations

3.1 Monitoring of Hiring Managers’ Certification

Occasionally, managers without a sub-delegated authority participate in a hiring panel without having the mandatory certification. In these circumstances, the manager must sign a form developed by PCO entitled, “Attestation Form for Managers Involved in Staffing” in order to demonstrate awareness of and attest to their compliance with PSC requirements. This signed form should be included in the appointment file. For one of the six files reviewed, there was no evidence of signed attestation by a manager who did not have sub-delegated authority, but was part of the hiring panel. Without this attestation, PCO cannot demonstrate compliance with the expectations of PCO’s policies and PSC’s appointment framework. However, the letter of appointment in this file was signed by an appropriate sub-delegated manager, as is required by policy.

Recommendation One

The Assistant Deputy Minister, Corporate Services Branch should establish measures to ensure that PCO Guidelines put in place to be compliant with the PSC framework are followed and documented consistently

3.2 Ongoing and Cyclical Monitoring

After the implementation of PCO’s new staffing policy, theWorkplace Policies and Programs Unit, Corporate Human Resources, Corporate Services Branch conducted staffing reviews and prepared a Staffing Review Report in May 2017. This work is considered part of the Human Resource division’s ongoing and cyclical monitoring of staffing activities. Initial self-assessment results noted that reviews of appointments from the executive group, which represented 14% of all appointments between April 1, 2016 and June 30, 2017, were not included in the May 2017 Staffing Review Report. Their exclusion limits PCO’s ability to have full insight into the level of compliance of all appointment activities.

The rationale to exclude the executive appointments (which do not fall under the staffing policy) was that monitoring activities were dedicated to the function of the new staffing policy only. Since the process for hiring executives is slightly different, a decision was made to remove executive appointments from the report. However, regular monitoring was resumed over the summer, and additional information provided to the self-assessment team confirms that PCO complies with the ADAI in executive appointments as well.

3.3 Data Entry Accuracy

Testing of appointment files indicated that for two of the six appointments files, specific appointment information in the electronic system of record did not align with the paper file. In one instance, the selection process was erroneously identified in the system; it was recorded as an internal advertised process instead of non-advertised. In the second instance, the end date of the employee’s term position was different from the letter of offer. After further investigation, the self-assessment team obtained confirmation that the end date was changed in the electronic system to accurately reflect the appointment file. In both cases, the data entry error did not impact the employees’ compensation. However, the fact that 33% of a small sample of files contained errors that could potentially impact compensation suggests that greater attention should be paid by PCO to the data entry function.

Recommendation Two

The Assistant Deputy Minister, Corporate Services Branch should institute a program of regular cyclical reviews of data entered into the human resources electronic record system to ensure its accuracy.  The review should include a reporting and follow up element to ensure systemic changes are instituted when required.

3.4 Conclusion

The overall result of this self-assessment is that PCO is in compliance with the requirements of the new policy and framework, but there are opportunities for improvement of administrative processes.

4.0 Management action plan

Self-Assessment of Staffing Activities
The Assistant Deputy Minister, Corporate Services Branch has overall accountability for the Action Plan.
Recommendations Risk Rating Management Response and Planned Actions Responsibility Due Date
We recommend that the Assistant Deputy Minister, Corporate Services Branch should:  
1. Establish measures to ensure that PCO Guidelines put in place to be compliant with the PSC framework are followed and documented consistently. Moderate The ADM, CSB accepts the recommendation and will ensure that the staffing checklist reflects this requirement and that files are documented consistently by conducting sporadic verifications.  As the PCO Staffing Policy governs appointments rather than staffing processes it already requires that those authorizing appointments sign the attestation as a condition to receiving their staffing sub-delegation authorities. Director General – Human Resources October 2017
2. Institute a program of regular cyclical reviews of data entered into the human resources electronic record system to ensure its accuracy.  The review should include a reporting and follow up element to ensure systemic changes are instituted when required. Moderate Corporate Human Resources already has a regular cyclical review of staffing files, however they will implement a regular review of the electronic records to ensure data accuracy.

In addition, HRD Operations has recently created an AS-03 position whose responsibilities include the provision of standardized training and individual coaching to HR Assistants.  Furthermore, the incumbent will proactively implement quality control measures.  He/She will actively review the administrative aspects of the staffing files and report findings to the Director and Managers - HR Operations.
Director General – Human Resources December 2017

Recommendation Risk Ratings refers to the urgency of the recommendation, based on PCO’s exposure to risk. Based on the risk rating, AED recommends management actions associated with the recommendation be completed using the following timeline:

Recommendation Risk Rating
Risk rating Attention Time frame
High Immediate management attention is required Complete the action plan within 6 months
Moderate Timely management attention is warranted Complete the action plan within 12 months
Low Management attention is warranted Complete the action plan within 18 months
Source: Institute of Internal Auditors Practice Guide: Formulating and Expressing Internal Audit Opinions

Appendix A – Self-Assessment Approach, Criteria and Methodology

The self-assessment was conducted in three phases: planning, examination and reporting during the months of July and August, 2017.  During the review planning phase, the team held consultations with senior management of the Public Service Commission (PSC), conducted interviews with PCO officials, gathered and reviewed relevant documents. The team identified proposed criteria to be used for the examination phase of the review, developed a Review Planning Document (RPD) which documented the results of the planning phase and provided the roadmap for developing the review criteria and executing the project. Criteria for the self-assessment were the PSC’s appointment policy requirements and PSC’S ADAI requirements.

During the examination phase, the team conducted the detailed comparison of PCO’s staffing policy and ADAI to the PSC appointment framework and conducted limited testing of a sample of appointment files to assess compliance to the appointment framework.

At the conclusion of the examination phase, observations were prepared and validated with appropriate levels of management. A draft self-assessment report was prepared and provided to the Executive Director, Human Resources for acceptance and for development of a management action plan to address the self-assessment recommendations.

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