Audit reports 2014-2015: 4 - Audit of Treasury Board of Canada Secretariat
We concluded that Treasury Board of Canada Secretariat (TBS) had an appropriate framework in place to manage its appointment activities. We found that TBS had put in place a sub-delegation instrument that was accessible to all employees. Related controls around the exercise of sub-delegated authority were established, although there is room for improvement in how these controls are implemented. We noted that the mandatory appointment policies and criteria were established and compliant. We found that sub-delegated managers were informed of their roles and responsibilities and had the support to carry out this role. Finally, we found that monitoring activities were conducted, results were reported and practices were adjusted accordingly.
We also concluded that most of TBS’ appointments and appointment processes were compliant with the Public Service Employment Act, any other applicable statutory and regulatory instruments, the Public Service Commission’s Appointment Framework and the organization’s own appointment policies. We found that TBS demonstrated that the person appointed met the essential and asset qualifications and organizational needs established by the deputy head in 93% (37 out of 40) of the appointments. In most instances, we found that persons with a priority entitlement were considered before appointments were made. We also found that information on appointment processes was sometimes incomplete or inaccurate, which could have had an impact on the decision of potential applicants to apply.
Table of Contents
Audit of Treasury Board of Canada Secretariat
4.1 This audit covers the Treasury Board Secretariat’s (TBS) appointment activities for the period of August 1, 2013, to July 31, 2014. The first objective of the audit was to determine whether TBS had an appropriate framework, practices and systems in place to manage its appointment activities. The second objective was to determine if appointments and appointment processes in TBS complied with the Public Service Employment Act (PSEA), any other applicable statutory and regulatory instruments, the Public Service Commission’s (PSC) Appointment Framework, including the Appointment Delegation and Accountability Instrument (ADAI) and the organization’s own appointment policies.
4.2 As the administrative arm of the Treasury Board, the Secretariat has a dual mandate: to support the Treasury Board as a committee of ministers and to fulfill the statutory responsibilities of a central government agency. The Secretariat is tasked with providing advice and support to Treasury Board ministers in their role of ensuring value-for-money as well as providing oversight of the financial management functions in departments and agencies.
4.3 The Secretariat makes recommendations and provides advice to the Treasury Board on policies, directives, regulations and program expenditure proposals with respect to the management of the government’s resources. The Secretariat is also responsible for the comptrollership function of government. Under the broad authority of sections 5 to 13 of the Financial Administration Act, the Secretariat supports the Treasury Board in its role as the general manager and employer of the public service.
4.4 As of March 31, 2014, TBS’ workforce was comprised of 1 746 full-time equivalents (FTEs); most were of indeterminate status and all were working in the National Capital Region. According to TBS’ Report on Plans and Priorities 2013-2014, the total number of FTEs for the next three fiscal years is expected to decline.
4.5 In 2012-2013, there was a decrease in the number of appointments to TBS. In 2012, the TBS Resourcing Committee was created to review staffing actions in order to ensure employees impacted by TBS’ spending review reductions were given every opportunity for appointment within TBS. In 2013, the TBS Resourcing Committee evolved into the TBS Departmental Human Resources Committee (DHRC). Part of the DHRC’s mandate is to provide strategic direction and integrated advice on issues and initiatives related to internal human resources (HR) management at TBS. Some of the Committee’s specific areas of focus include the TBS HR Plan, workplace and workforce priority setting, strategies for departmental recruitment, staffing and skills development.
4.6 In July 2013, TBS’ Internal Audit and Evaluation Bureau published a report on the Audit of Human Resources Planning for Recruitment and Staffing. The TBS internal audit bureau focused on whether the Secretariat had developed and communicated recruitment and staffing strategies and whether it had established an adequate monitoring and reporting regime to support HR planning for recruitment and staffing. The TBS audit concluded that the management of HR planning for recruitment and staffing within the organization was adequate and that there were no recommendations outlined in the report. Therefore, the PSC did not audit whether TBS had developed staffing plans and related strategies that were measurable and approved and whether TBS had monitored the results of its staffing plans and related strategies.
4.7 The organization carried out 248 appointments during the period covered by our audit. As part of our audit, we conducted interviews with HR advisors and sub-delegated managers involved in appointment activities, analyzed relevant documentation and audited a representative sample of 40 appointments.
Observations on the Appointment Framework
Sub-delegation of appointment authorities
4.8 The PSEA gives the PSC exclusive authority to make appointments to and within the public service. The PSC delegates many of its appointment and appointment-related authorities to deputy heads who, in turn, may sub-delegate the exercise of these authorities. The PSC expects deputy heads to have a sub-delegation instrument in place that is well managed and accessible across the organization.
4.9 TBS was subject to the ADAI since the coming into force of the PSEA, delegating the Secretary appointment and appointment-related authorities. The Secretary established a sub-delegation instrument entitled “TBS Departmental Human Resources Delegation Instrument”. The ADAI and the sub-delegation instrument have been communicated and made accessible to employees on TBS’ intranet site.
4.10 We noted that the Secretary had established requirements to be met by managers prior to being sub-delegated appointment and appointment-related authorities. Once the managers met the requirements, a sub-delegation letter was issued by the Secretary and managers were required to sign it to confirm their acceptance of the sub-delegated authorities.
4.11 We found that TBS maintained a list of sub-delegated managers. This list was used by HR advisors to ensure that the manager signing an offer of appointment met the requirements to be sub-delegated and therefore was authorized to make the appointment. We noted that, for 14 out of the 24 managers who signed offers of appointment within our sample of appointments reviewed, the date of sub-delegation identified on the list used by HR advisors did not correspond to the date the manager accepted the sub-delegated authorities. We found that, for seven managers, TBS was unable to provide evidence that they had completed the mandatory training and/or that they had received and signed a sub-delegation letter. As a result, in 23% (9 out of 40) of the appointments audited, the offers of appointment were signed by a manager who did not meet all of the requirements to be sub-delegated or by managers for whom TBS was unable to provide evidence that they met the sub-delegation requirements.
4.12 Further, in its sub-delegation instrument, TBS has established a requirement that the TBS Employment Equity and Diversity Online Training be completed by managers prior to being sub-delegated. We found that the sub-delegation letter sent by the Secretary stipulated that this training must be completed within three months of sub-delegation, which differs from the requirements set out in the sub-delegation instrument. We also found that two managers had not completed the training within the timeline, as prescribed in the letter. Refer to recommendation 1 at the end of this report.
4.13 The PSC expects deputy heads to establish mandatory appointment policies for area of selection, corrective action and revocation, as well as criteria for the use of non-advertised processes. The PSC also expects the other appointment policies that organizations develop be compliant with the PSEA, any other applicable statutory and regulatory instruments and the PSC’s Appointment Framework.
4.14 We found that TBS put in place the mandatory appointment policies as well as criteria for the use of non-advertised appointment processes and that they were compliant with the PSC’s Appointment Framework. These policies were communicated and accessible to employees on TBS’ intranet site.
Capacity to deliver
4.15 The PSC expects deputy heads to ensure that those who have been assigned a role in appointment processes have been informed of their roles and responsibilities and have access to tools and the HR support to carry out this role.
4.16 We found that roles and responsibilities were defined, documented and communicated through various documents such as the instrument of sub-delegation and organizational policies. All of these documents were available to employees through TBS’ intranet site.
4.17 In addition, sub-delegated managers receive a copy of the ADAI and the TBS Departmental Human Resources Delegation Instrument with their sub-delegation letter. Furthermore, the letter informs the sub-delegated managers that the TBS intranet site provides further details on staffing-related information and tools for managers. These tools include a staffing process checklist for managers that describes steps that the manager must complete during the conduct of an appointment process.
4.18 We found that sub-delegated managers had access to an HR advisor who had passed the PSC’s Appointment Framework Knowledge Test. This test is designed to evaluate knowledge of all parts of the PSC’s Appointment Framework (policy, delegation and accountability) and the legislative framework. In addition, TBS developed a PE Development Program. According to TBS, this program aims to develop professional and versatile HR professionals to partner with and support TBS managers in attaining their business and HR management objectives.
4.19 Finally, we noted that the sub-delegation instrument and letter as well as the mandatory in-house staffing training indicated that sub-delegated managers are encouraged to seek advice from their HR advisor. Although it is not a PSC requirement to document the advice provided by HR, all the documented advice we reviewed was compliant with the PSC’s Appointment Framework.
4.20 Monitoring is an ongoing process that allows deputy heads to assess staffing management and performance related to appointments and appointment processes. Monitoring makes it possible to identify issues that should be corrected, to manage and minimize risk and to improve staffing performance. The PSC expects deputy heads to undertake the mandatory monitoring outlined in the PSC’s Appointment Framework, including the ADAI, and adjust practices accordingly.
4.21 TBS established a Staffing System Monitoring Program to gather information and prepare staffing system monitoring and evaluation reports. We found that TBS monitored, through file review, appointments and appointment processes to ensure they were compliant with the PSEA as well as any other statutory requirements and policies pertaining to the integrity of appointments.
4.22 We also found that all mandatory monitoring of risk-based policy areas was completed (e.g., acting appointments of over 12 months and appointments of casual workers to term or indeterminate status through non-advertised processes). This monitoring was conducted by extracting a Staffing Activity Report from TBS’ HR database. In order to determine the reliability of TBS’ electronic information, we conducted an analysis of TBS’ HR database, including the staffing action codes used. We found TBS’ HR database was sufficiently accurate to produce reliable information regarding appointment processes.
4.23 The results of these monitoring exercises, as well as suggested strategies to address the areas of risk identified, were presented to senior management. For example, to help ensure that appointment decisions are effectively documented to demonstrate that persons appointed met the qualifications prior to appointment, it was suggested that staffing processes and tools be reviewed and updated. We found that some staffing tools, such as the rationale template for non-advertised appointments, have been updated to address the issues raised by the monitoring exercises. TBS also indicated that the HR advisors were informed of the issues identified through the monitoring of appointments and, in some cases, sub-delegated managers were consulted and were requested to take corrective measures.
Observations on appointments
Appointments – Merit
4.24 The PSEA requires that all appointments be made on the basis of merit. Merit is met when the Commission is satisfied that the person to be appointed meets the essential qualifications for the work to be performed, as established by the deputy head and, if applicable, any asset qualifications or organizational needs identified by the deputy head.
4.25 We found that TBS demonstrated that the person appointed met the essential and asset qualifications and organizational needs established by the deputy head in 93% (37 out of 40) of the appointments reviewed.
4.26 While merit was demonstrated in almost all of the appointments reviewed, the following section provides additional information, in the interest of promoting understanding and learning, on the three appointments where the essential qualifications were not fully assessed before the appointment was made. In one case, there was insufficient evidence to demonstrate how the appointee met two of the essential experience qualifications required for the appointment as they were not indicated on the appointee’s curriculum vitae and no other form of assessment was done for these qualifications. In another case, the assessment of the appointee was completed eight months after the effective date of the appointment. In the last case, the appointee’s Second Language Evaluation result for written expression was no longer valid on the date that the notification of appointment was issued. In June 2015, as a corrective measure, the appointee was tested and now has valid results for written expression. The Appendix includes tables detailing our observations concerning merit for the appointments audited. Refer to recommendation 2 at the end of this report.
Appointments – Other requirements
Persons with a priority entitlement
4.27 The PSEA and the Public Service Employment Regulations provide an entitlement for certain persons who meet specific conditions to be appointed in priority to others. The organization must take into consideration persons with priority entitlements prior to making appointments and must also obtain a priority clearance number from the PSC before proceeding with an appointment process or an appointment.
4.28 As part of our sample, 32 appointments reviewed required and obtained a priority clearance before proceeding with an appointment. In most instances, we found that persons with a priority entitlement were adequately considered. However, in three instances, there were differences in the essential qualifications or position requirements (e.g., tenure, location, group and level) used in the request for priority clearance and those used to make the appointment. For example, in one instance, the type of employment used in the request for priority clearance was “Part-time” when the appointment was “Full-time”. Such situations could have resulted in persons with a priority entitlement not being appropriately considered. Refer to recommendation 3 at the end of this report.
Information on appointment processes
4.29 The PSC’s Policy on Advertising in the Appointment Process and Policy on Official Languages in the Appointment Process require that information be provided to allow persons in the area of selection to make an informed decision and that the information concerning appointment processes is communicated in both official languages, when required.
4.30 We found that in 23% (9 out of 40) of the appointments, the English and French versions of the advertisement were not identical. For example, the English version of a Statement of Merit Criteria (SMC) stated “…experience in investment planning OR project management and recommending OPTIONS/Strategies to address them”, while the French version stated: “…experience de planification des investissements ET de gestion de projets et de la recommendation d’option ET de stratégies visant à les régler.” Therefore, the French version of the SMC required more experience than the English version. Inaccurate information on an advertisement or SMC could have had an impact on the decision of potential candidates to apply. Refer to recommendation 2 at the end of this report.
1.The Secretary of the Treasury Board of Canada Secretariat should ensure that managers meet the conditions of sub-delegation before exercising appointment and appointment-related authorities and that the controls in place are effective.
2.The Secretary of Treasury Board of Canada Secretariat should ensure that:
- All of the qualifications used to make the appointment are fully assessed before proceeding with the appointment; and
- Information on appointments and/or advertisements provided to potential candidates or persons entitled to be notified is the same in both official languages.
3.The Secretary of Treasury Board of Canada Secretariat should ensure that the essential qualifications and position requirements used for the appointment decision and those used for the priority clearance request are the same.
Overall response by Treasury Board of Canada Secretariat
The Treasury Board of Canada Secretariat (TBS) has reviewed the Public Service Commission (PSC) audit report, and acknowledges that the facts presented are accurate and accepts its recommendations.
TBS takes its delegated authorities seriously and works hard to ensure that appointments are made in accordance with legislative, regulatory and policy requirements as well as the preamble of the Public Service Employment Act.
TBS is committed to continuously improving its staffing regime and to addressing the risks identified in the audit in a timely and effective manner. TBS will use the recommendations as opportunities to further improve its existing staffing framework. To this end, consultations with key stakeholders within the Human Resources Division have taken place during the development of the action plan to ensure successful implementation of the recommendations outlined in this report. TBS will also align its framework with the PSC’s new policy direction once it is implemented.
Action taken by the Public Service Commission
Organizations that have been audited by the Public Service Commission (PSC) receive guidance and assistance from the PSC to develop an action plan that will address the audit recommendations. The PSC systematically reviews audit information, the organization’s management response and associated action that it has taken or will take in response to the audit recommendations to determine whether any action should be taken by the PSC. As a result of this review, the PSC is satisfied with the Treasury Board of Canada’s management response and the actions it has taken or has committed to take to address the audit recommendations. The PSC expects the Secretary to monitor the implementation of the organizational action plan and the PSC may request an update on the action plan. The PSC can provide assistance for this implementation as required.
|Merit was met||Assessment tools or methods evaluated the essential qualifications and other merit criteria identified for the appointment; the person appointed met these requirements||37 (93%)|
|Merit was not met||The person appointed failed to meet one or more of the essential qualifications or other applicable merit criteria identified||0 (0%)|
|Merit was not demonstrated||Assessment tools or methods did not demonstrate that the person appointed met the identified requirements||3 (7%)|
|Total appointments audited||40 (100%)|
Source: Audit and Data Services Branch, Public Service Commission
|Reasons for merit not being met or demonstrated||Number of incidences|
|Appointee did not meet one or more essential qualifications (experience, knowledge, abilities, competencies, personal suitability)||0|
|Appointee did not meet the official language proficiency||0|
|Appointee did not meet the education/occupational certification or qualification standard||0|
|Appointee did not meet the additional qualifications (asset and/or organizational needs) used to make the appointment||0|
|The essential qualifications (experience, knowledge, abilities, competencies, personal suitability) of the appointee were not fully assessed||2|
|The official language proficiency of the appointee was not fully assessed||1|
|The education/occupational certification or qualification standard were not fully assessed for the appointee||0|
|The additional qualifications (asset and/or organizational needs) used to make the appointment were not fully assessed||0|
Source: Audit and Data Services Branch, Public Service Commission
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