Management Action Plan
Line of Enquiry : Program Evaluation
Finding
The Agency has a decentralized and somewhat disparate approach to enforcement and lacks a clear well articulated and operationally entrenched enforcement strategy. Shared ownership of objectives achievement is not clearly understood and managed. Accountability with only limited authority has impacted Enforcement and Disclosures Directorate's (EDD) efforts to achieve its mandate.
Recommendation
The agency should determine the extent to which it wishes to strengthen its capability to pursue both criminal non-compliance and non-compliance in the criminal economy and then develop a comprehensive enforcement strategy.
Action Plan
We will review the Agency's enforcement approach to ensure that it continues to reflect a strong Agency-wide approach to enforcement and then adjust the strategic direction as required.
The approach we propose includes:
Actions
- Establish a steering committee consisting of Regional Assistant Commissioners (ACs) and functional ACs to review the Agency's approach to enforcement to ensure it is aligned to our enforcement mandate and to make any required adjustments to our strategic directions.
- Establish a working group involving key stakeholders, to make recommendations to the steering committee on changes to the strategic direction. The main areas of review will be: file selection, program delivery, legislative framework, partnerships and communication products.
- Present recommendations from the steering committee and working group to Strategic Directions Committee for review and input.
- Present the recommendations of the Steering Committee to Agency Management Committee for input and direction.
Timelines
- Establish steering committee and working group: March 31, 2011
- Present recommendations to senior management: December 31, 2011
Finding
Currently there exists the opportunity to strengthen existing partnerships. Some of the factors influencing partnerships are legislative, technical, procedural and operational while others are specific to communication, training and human resources.
Recommendation
The EDD should engage internal and external partners in a dialogue to discuss roles, expectations, impediments and seek solutions to the factors that appear to be negatively impacting partnerships.
Action Plan
As noted above, we will develop recommendations which will include objectives and initiatives related to building and strengthening partnerships.
Action
Please refer to action item b) above.
Finding
Leads and Voluntary Disclosures Programs do not align with the EDD mandate. Both programs perform review processes focussed on a taxpayer group that would normally be addressed by regular audit areas.
Recommendation
The agency should review the appropriateness of the location of the Leads Program and the Voluntary Disclosures Program within the EDD.
Action Plan
We will undertake a review to assess whether the Leads and Voluntary Disclosures Programs are best situated within the EDD. This will be done in conjunction with a review of the Agency's enforcement approach and development of a strategic direction (see management response to the first recommendation).
Action
Review whether the Leads and Voluntary Disclosures Programs should be resituated within the Agency in order to maximize program delivery and to enhance the intelligence gathering capacity for Agency programs by September 30, 2011.
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