CRA Response to the 2023 Systemic Examination Report: Charity Begins with Fairness

Original report submitted to the Minister of National Revenue March 2023.

Recommendation #1

The Taxpayers’ Ombudsperson recommends to the Minister of National Revenue that the CRA create an unconscious bias training course for CRA employees of the Charities Directorate, focus the training on those involved in the audit process, and make the course mandatory for all employees involved in the audit process, including decision makers.

CRA’s response

The CRA agrees with this recommendation.

CRA employees’ participation in courses and learning events on the subject of diversity, inclusion and bias is already underway in furtherance of the CRA’s broader efforts related to its action plan on inclusion, equity, diversity, and anti-racism, and the CRA’s commitment to create awareness and provide educational opportunities that increases both management and employee knowledge on topics such as unconscious bias and inclusiveness.

Recognizing the need to develop and promote a culture of respect, empathy, diversity and inclusion within its work, the Charities Directorate has already taken the initiative to identify and to attend a wide array of related courses offered by the CRA, the Canada School of Public Service (CSPS), and external learning providers, as well as to incorporate each of these elements in our service to the public.

CRA auditors in particular, including those auditing registered charities, receive extensive mandatory training on compliance activities. A key component of this mandatory training focuses on support to auditors in exercising professional judgement, skepticism and impartiality, including how to safeguard against unconscious bias. Auditors also follow guidelines and complete training that helps them improve their soft skills which they exercise during interviews and on-site visits with taxpayers, including registered charities. 

Further unconscious bias training currently exists via the CSPS and CRA, with courses available to all CRA employees.

In order to continue developing and promoting a culture of respect, empathy, diversity and inclusion within its work, the CRA has established the following short, medium, and long term deliverables in response to the Ombudsperson’s report:

Agency-wide specific actions

Complete.

Effective immediately, mandatory unconscious bias training will be added to the 2023-2024 performance agreement for all indeterminate CRA employees, unless such training was completed during the past two years. 

The training will continue to be offered to all term employees on a voluntary basis.

Actions specific to the Charities Directorate

Short term (by Q1 of 2023-2024): Complete

• Make the CRA course, "HQ1257-000 Unconscious Bias: Building tools to navigate the mind", mandatory for all employees and decision makers involved in the charity audit process. 
• Ensure that all staff in the Charities Directorate involved in the audit process, including decision makers, are familiar with the job aid, Professional Judgement, Skepticism and Impartiality.
• Update all Charities Directorate training products, as appropriate, to include information on unconscious bias.

Medium term (by Q3 of 2023-2024): Complete

• Introduce a new mandatory training suite tailored to the Charities Directorate and designed to strengthen the ability of staff to apply knowledge in the area of unconscious bias, cultural competency, and religious literacy, in their day-to-day roles. The new mandatory training suite will draw from existing course offerings in the CRA, the CSPS, other Government Departments and external providers. 
• Expand the requirement to complete “HQ1257-000 Unconscious Bias: Building tools to navigate the mind” to all Charities Directorate employees.

Long term (by Q4 of 2023-2024): Ongoing

• Develop and offer annual refresher training on the key concepts covered in the mandatory training suite.

The CRA remains committed to ensuring its employees are well-positioned to serve all Canadians with empathy and respect. The Charities Directorate will ensure that all employees complete a new suite of mandatory training on unconscious bias, cultural competency, and religious literacy. The Charities Directorate will also ensure that annual refresher courses are completed.

2024 Update

The CRA has completed the following:

• A new required training suite designed to strengthen the ability of staff to apply knowledge in the area of unconscious bias, cultural competency, and religious literacy, in their day-to-day roles, is complete and was distributed to employees in February 2024. All Charities Directorate employees must take the required training by the end of the 2024-2025 fiscal year. 
• All Charities Directorate employees and decision makers involved in the charity audit process have completed the CRA course, “Unconscious Bias: Building tools to navigate the mind", or its course equivalent.  
• Charities Directorate training products have been updated to include information on unconscious bias. Training products under development are also being updated with Equity, Diversity, and Inclusion (EDI) statements, and are being reviewed with an EDI lens.
• Refresher training on key concepts covered in the mandatory training suite has been provided through monthly religious literacy events for Charities Directorate employees.

Further customized training solutions to supplement the required training suite are currently under development and remain ongoing. 

This action plan item is ongoing.