Summary of the evaluation of the chief financial officer attestation for Cabinet submissions

Internal Audit and Evaluation Bureau, Treasury Board of Canada Secretariat

Program description

The Financial Management Sector (FMS) supports the Office of the Comptroller General (OCG) in strengthening financial management, oversight and reporting in the Government of Canada. FMS ensures the availability of appropriate frameworks, policies and guidance on financial management across the federal public service. Within this context, FMS is responsible for the Guideline on Chief Financial Officer Attestation for Cabinet Submissions, which provides a framework for chief financial officers (CFOs) in the due diligence review and attestation of the financial management aspects of Cabinet submissions.

Evaluation methodology and scope

The evaluation assessed the relevance and effectiveness of the CFO attestation instrument. It assessed six areas:

• the need for the CFO attestation
• the appropriateness of the attestation instrument
• the clarity and consistency of the approach to due diligence since the guideline was implemented
• the extent of meaningful involvement of CFOs
• the improvement of awareness of financial risk
• the understanding of data limitations

Data was collected between January and August 2020 and included the following lines of evidence:

• a comparative jurisdictional review
• a document review
• key informant interviews (29)
• focus groups (2)
• case studies (5)

Evaluation limitations

The COVID-19 pandemic precluded interviews with deputy heads; however, an interview with the Secretary of the Treasury Board and assistant deputy ministers who are responsible for Cabinet submissions provided proxy information.

Evaluation findings

Is there an ongoing need for the CFO attestation? Yes, it is an effective practice that provides independent assurance to submission owners that financial risks have been considered in TB submissions.

Is the attestation an appropriate instrument? Yes, it is an appropriate way of achieving consistency and robust due diligence in the activities undertaken by CFOs when reviewing TB submissions.

Has the guideline enabled a clear and consistent approach to due diligence? Yes, to some extent. The guideline has enabled a clear and consistent approach to due diligence. The guideline has not had the same influence on joint (multi-departmental) submissions, submissions from small departments, or submissions from departments that do not have formal centralized processes.

Is the involvement of CFOs meaningful? Yes, submission owners recognize CFOs as valuable business advisors. CFOs are usually involved early in the TB submission process, although this is not the case in all departments.

Has the awareness of risk improved with the CFO attestation? Yes, but there is still a lack of consistency in risk disclosure among CFOs. As reported in the 2019–20 Departmental Results Report, only half of assessed TB submissions transparently disclose financial risk.

Have CFO attestations improved the understanding of data limitations? Yes, to some extent. CFO attestations have improved the understanding of data limitations. Despite some progress, challenges remain in relation to data quality and completeness.

Recommendations

It is recommended that the Office of the Comptroller General:

1. establish a mechanism to share best practices that would guide small departments, departments that do not have formal centralized processes for the CFO attestation for TB submissions, and departments that are working together on submissions (multi-departmental submissions)
2. provide guidance and support
   1. on CFO attestations for joint submissions to increase consistency and to set expectations
   2. on data gaps to determine full‑time equivalent requirements
   3. in cases when a CFO attestation is needed but where funds are not requested
3. explore ways to increase financial risk transparency in the CFO attestation process to improve the consistency of risk disclosure across the Government of Canada