Comptroller General of Canada Appearance Before the Standing Committee on Government Operations and Estimates (OGGO): October 8, 2024

Mandate of the Committee

The Standing Committee on Government Operations and Estimates (OGGO) focuses on the estimates process as well as on the effectiveness and proper functioning of government operations.

Under Standing Order 108(3)(c), the Committee’s mandate includes the study of:

• the format and content of all estimates documents;
• the effectiveness, management and expenditure plans of:
  • central departments and agencies;
  • new information and communication technologies adopted by the government;
  • cross-departmental mandates, including programs delivered by more than one department or agency;
  • Crown corporations and agencies that have not been specifically referred to another standing committee;
  • statutory programs, tax expenditures, loan guarantees, contingency funds and private foundations deriving the majority of their funding from the Government of Canada.

Committee operating procedures

Witness’ opening statements: five minutes

Questions Round 1

1. Conservative: 6 minutes
2. Liberal: 6 minutes
3. Bloc Québécois: 6 minutes
4. New Democratic Party: 6 minutes

Questions Round 2 (and subsequent rounds)

1. Conservative: 5 minutes
2. Liberal: 5 minutes
3. Bloc Québécois: 2.5 minutes
4. New Democratic Party: 2.5 minutes
5. Conservative: 5 minutes
6. Liberal: 5 minutes

Appearance of Environment and Climate Change Canada on federal grants and contributions (October 1, 2024)

Appearance of the Comptroller General on McKinsey & Company (September 19, 2024)

Chair:

Kelly McCauley (Edmonton West, Alberta), Conservative

• Elected as the Member of Parliament in 2015 for Edmonton West.
• Former Conservative Shadow Minister for Treasury Board.
• Also serves on the Standing Committee on Public Accounts, and the Subcommittee on Agenda and Procure of OGGO.
• Before his election in 2015, Mr. McCauley was a hospitality executive specialized in managing hotels and convention centres.
• He is a graduate of the British Columbia Institute of Technology in the Hospitality Management program.
• Interest in the TBS portfolio: Pushes for a reform in the Public Servants Disclosure Protection Act to protect whistleblowers; has been one of the most critical MPs regarding the state of the access to information and privacy system; and has expressed repeated concerns about the late tabling of the Public Accounts.

First Vice-Chair:

Majid Jowhari (Richmond Hill, Ontario), Liberal

• Elected as the Member of Parliament in 2015 for Richmond Hill.
• Also serves on the Standing Committee on Health, Standing Committee on Natural Resources, and the Subcommittee on Agenda and Procedure of OGGO.
• Previously served on the Standing Committee of Industry, Science and Technology as well as the Special Committee on the COVID‑19 Pandemic.
• Born in Iran, he is the first federal MP of Iranian heritage.
• He has a degree in industrial engineering from Ryerson University and a Master’s of Business Administration from York University’s Schulich School of Business.
• Before his election in 2015, Mr. Jowhari was a consultant and engineer.
• Interest in the TBS portfolio: Has expressed interest in the Refocusing Government Spending initiative and in compliance with TBS guidelines as it pertains to procurement and management of real property.

Second Vice-Chair:

Julie Vignola (Beauport–Limoilou, Quebec), Bloc Québécois

• Elected as the Member for Parliament in 2019 for Beauport-Limoilou.
• Bloc Québécois Critic for Public Services, Tourism, Government Operations and Procurement.
• Also serves on the Subcommittee on Agenda and Procedure of OGGO.
• Previously a member of the Special Committee on the COVID‑19 Pandemic.
• Before her election in 2019, she was a teacher in a private high school.
• Ms. Vignola has a Bachelor’s degree in History and Geography Teaching from the Université du Québec à Rimouski.
• Interest in the TBS portfolio: Believes Bill C-290 should be adopted; believes outsourcing should be cut drastically and that the reliance on private consultants is undermining the expertise of the public service; has been critical over shortcomings in the procurement process as it relates to McKinsey, as well as their lack of respect of official languages.

Garnett Genuis (Sherwood Park–Fort Saskatchewan, Alberta), Conservative

• Elected as the Member of Parliament in 2015 for Sherwood Park–Fort Saskatchewan.
• Previously served on many committees, including Public Accounts.
• Attended Carleton University where he obtained a Bachelor’s degree in Public Affairs and Policy Management and a Master’s degree in Public Policy from the London School of Economics.
• Prior to his election, he was a political correspondent, assistant to Prime Minister Stephen Harper and adviser to Rona Ambrose
• Interest in the TBS portfolio: His main focus in recent studies has been to identify ministerial accountability in the procurement process; often focuses on the relationships between contractors and the government.

Kelly Block (Carlton Trail–Eagle Creek, Saskatchewan), Conservative

• Elected as the MP for Carlton Trail–Eagle Creek in 2008.
• Also sits on the Subcommittee on Agenda and Procedure for OGGO.
• Shadow Minister for Public Services and Procurement.
• Previously served as Parliamentary Secretary to the Minister of Natural Resources and Member of Panel of Chairs during the 41st Parliament.
• Previously sat on many committees, including Public Accounts.
• Prior to her election, Ms. Block served two terms as mayor of Waldheim, Saskatchewan.
• Interest in the TBS portfolio: Expressed repeated concern over a perceived lack of oversight across departments and a lack of enforcement of the Financial Administration Act.

Stephanie Kusie (Calgary Midnapore, Alberta), Conservative

• Elected as the Member of Parliament in 2017 for Calgary Midnapore.
• Conservative Shadow Minister for the Treasury Board.
• Also sits on the Standing Committee on Official Languages.
• Has a Bachelor of Arts in Political Science from the University of Calgary and a Master’s of Business Administration from Rutgers University.
• Prior to her election, Ms. Kusie occupied multiple positions, including chargé d’affaires ad interim for Canada to El Salvador, consul for Canada to Dallas, Texas, and senior policy advisor to Peter Kent in Latin America.
• Some of her duties before her time in office included negotiating free trade deals, work related to the Keystone Pipeline project, and lobbying the United Nations to place Canada on the Security Council.
• Interest in the TBS portfolio: Believes TBS lacks accountability and transparency; has recently been seized with issues of dual employment and conflict of interests in the public service; has been critical of the timing and methodologies of the Estimates process.

Taylor Bachrach (Skeena–Bulkley Valley, British Columbia), New Democratic Party

• Elected as the Member of Parliament in 2019 for Skeena–Bulkley Valley.
• NDP’s Transport Critic, as well as Deputy Critic for Infrastructure and Communities and Fisheries, Oceans and the Canadian Coast Guard.
• Also serves on the Standing Committee on Transport, Infrastructure and Communities.
• Before his election, Mr. Bachrach was first a municipal councillor in the Village of Telkwa and then was mayor of the Town of Smithers from 2011 to 2019.
• Interest in the TBS portfolio: Believes the government should invest more in the public service while cutting down outsourcing drastically; has expressed concerns over the return-to-office mandate in the public service and the facts that unions were not consulted.

Parm Bains (Stevenston–Richmond East, British Columbia), Liberal

• Elected as the Member of Parliament for Fredericton in 2019 representing the Green Party and re-elected in 2021 representing the Liberal Party.
• Also serves on the Standing Joint Committee on the Library of Parliament.
• She completed a Master’s in Education at the University of New Brunswick.
• Has personal ties to the Indigenous community.
• Interest in the TBS portfolio: Has expressed repeated concerns regarding systemic racism and issues of discrimination within the public service.

Jenica Atwin (Fredericton, New Brunswick), Liberal, Parliamentary Secretary to the Minister of Indigenous Services

• Elected in 2019 as the Member of Parliament for Fredericton representing the Green Party and re-elected in 2021 representing the Liberal Party.
• Also serves on the Standing Joint Committee on the Library of Parliament.
• She completed a master’s in education at the University of New Brunswick.
• Has personal ties to the Indigenous community.
• Interest in the TBS portfolio: Has expressed repeated concerns regarding systemic racism and issues of discrimination within the public service.

Irek Kusmierczyk (Windsor–Tecumseh, Ontario), Liberal, Parliamentary Secretary to the Minister of Employment, Workforce Development and Official Languages

• Elected as the Member of Parliament for Windsor–Tecumseh in 2019.
• Born in Poland, he immigrated to Canada in 1983 after his father was imprisoned for being a member of a movement opposed to communism.
• Before his election, was a city councillor for the Windsor City Council.
• Has a PhD in Political Science from Vanderbilt University, a Master of Science degree in government from the London School of Economics and a Bachelor’s degree in Journalism from Carleton University.
• Interest in the TBS portfolio: Has shown interest in Greening Government initiatives; often asks questions regarding compliance with TBS policies in the procurement process.

Charles Sousa (Mississauga–Lakeshore, Ontario), Liberal, Parliamentary Secretary to the Minister of Public Services and Procurement

• Elected as the Member of Parliament for Mississauga–Lakeshore in 2022.
• Before his election, he joined the provincial Cabinet as the Minister of Labour in 2010 and became Ontario’s Minister of Citizenship and Immigration in 2011. Also was the Minister of Finance for Ontario from 2013 to 2018.
• Graduated from Wilfrid Laurier University in 1982 with a degree in Business Administration in September 2023.
• Interest in the TBS portfolio: Asked several questions on what public servants can do to ensure best practices are applied in the procurement system, including implementing more trainings.

1. How transfer payment programs get created: memorandum to Cabinet to Treasury Board submission

Transfer payment programs are used to address government priorities and achieve results for Canadians and are governed by the Policy on Transfer Payments and Directive on Transfer Payments.

Departments first obtain policy authority for government programs through the tabling of a memorandum to Cabinet.

Departments will then seek Treasury Board approval of this request with a Treasury Board submission to confirm the program authority decision.

For Gs&Cs, departments seek approval of program Ts&Cs as part of their Treasury Board submission. Departments also recommend whether a funding program should provide grants and/or contributions.

2. What is the role of Treasury Board with respect to new transfer payments?

As outlined in the Policy on Transfer Payments, the Treasury Board is responsible for approving Ts&Cs for new transfer payment programs.

In the case where Cabinet directs one-time funding, where development of a program (and related Ts&Cs) is not needed, Treasury Board will approve funding agreements.

3. What is the role of Treasury Board with respect to existing transfer payment programs?

Treasury Board approves any amendments to existing Ts&Cs, such as:

• changes to program objectives;
• repayability; or
• up-front-multi-year funding.

In addition, Treasury Board will approve exceptions to existing Ts&Cs that may be needed to support specific project requirements.

The Treasury Board is also responsible for reviewing the effectiveness of transfer payment programs in addressing government priorities and contributing to departmental results. This can take the form of a formal program evaluation and/or be assessed through the Management Accountability Framework (MAF), which is undergoing a renewal process.

4. What is the Minister’s responsibility with respect to existing transfer payment programs?

Once Treasury Board has approved a transfer payment program, the Minister can make amendments to the following elements of Ts&Cs:

• the eligible activities, initiatives or projects (for example, funding to build a bridge, support to a community festival, support relief efforts for natural disasters in Canada).
• The class of eligible recipients (for example, not for profit organizations, individuals, provinces or territories).
• The maximum amount of funding available to a recipient.
• The stacking limit (that is, percentage of total federal, provincial and municipal funding toward the same project).
• amendments that give effect to a Cabinet decision or direction.

Also, as outlined in the Policy on Transfer Payments, there are two exceptions to Ts&Cs that the Minister can approve on a case-by-case basis:

1. to allow payment up to 25% more than the maximum amount payable.
2. that a recipient need not repay a repayable contribution when the funding is less than $250,000.

5. What is the role of the Treasury Board of Canada Secretariat with respect to grants and contributions?

TBS is responsible for:

• making recommendations to the Treasury Board with respect to the approval of Gs&Cs programs;
• monitoring, providing guidance and recommending corrective actions with respect to compliance with the Policy on Transfer Payments (for example, corrective actions may include recommending that a department review its risk practices, internal assessment documents or internal policies to better monitor funding);
• promoting and facilitating collaboration and the sharing of best practices between departments;
• providing leadership for the professional development of the Gs&Cs community;

6. What is the role of the Comptroller General of Canada?

The Comptroller General of Canada is responsible for providing functional direction and assurance government-wide for:

• financial management
• transfer payments
• internal audit
• investment planning
• procurement
• project management
• the management of real property and materiel

The Transfer Payment Policy Centre supports the Comptroller General of Canada by:

• ensuring that the Policy on Transfer Payments and its supporting instruments support departmental Gs&Cs programs;
• overseeing compliance across the federal government and providing policy interpretation when reviewing departmental proposals, including Treasury Board submissions;
• providing leadership by maintaining and building a professional grants and contribution community through a range of operational supports, governance and training activities.

7. How often is the Treasury Board increasing ministerial delegation limits?

While there are no provisions or references within the Policy on Transfer Payments related to delegation limits, some departments or programs (mostly those with larger-scale projects) have had limits imposed on them which may be listed within their Treasury Board approved Ts&Cs that identify when Treasury Board approval is required.

Ts&Cs are not required by the policy to be made available to the public. Typically, departments develop program guides based on elements of their Ts&Cs to support applicants to access funding.

In the absence of any limits documented within approved Ts&Cs, ministers have full authority to enter into funding agreements. This authority and any further delegation are typically governed by a department’s Delegation of Financial Signing Authorities matrix.

8. What are the responsibilities of deputy heads in the administration of grants and contributions?

Deputy heads play a key role in the design, delivery and management of transfer payments.

They are responsible for ensuring that Gs&Cs programs are accessible, usable and understandable for applicants and recipients.

Deputy heads ensure that departmental practices and procedures are in place and look for opportunities to standardize the administration of Gs&Cs within the department and with other departments, ensuring that requirements are proportionate to the risks involved.

Deputy heads also monitor departmental compliance with the Policy on Transfer Payments and its supporting instruments, according to the Framework for the Management of Compliance.

9. What is the role of the chief financial officer for the Policy on Transfer Payments (including internal controls)?

The Policy on Transfer Payments does not impose specific requirements for chief financial officers, as this would duplicate the responsibilities provided in other policies. Instead, the Policy on Transfer Payments points to the Policy on Financial Management as a key reference.

The Policy on Financial Management sets out the following key responsibilities for deputy heads, chief financial officers and senior departmental managers with respect to internal controls over financial management and financial reporting:

• departmental chief financial officers support the deputy heads by establishing, monitoring and maintaining a risk-based system of internal control over financial management to provide reasonable assurance that:
  • resources are used prudently and economically;
  • financial management processes are effective and efficient;
  • relevant legislation, regulations and financial management policy instruments are being complied with.

For departments with significant transfer payment programs, the chief financial officer’s responsibility with respect to internal controls would be to ensure that sufficient internal controls are established, monitored and maintained with respect to financial reporting and management. This could be controls such as ensuring that sections 32, 33 and 34 of the Financial Administration Act are adequately functioning before making payments and having sufficient information documented in support of payments.

10. What is the role of the department’s Internal Audit?

11. Office of the Comptroller General Audit Operations

The Comptroller General of Canada is responsible for:

• leading internal audit engagements that address horizontal, sectoral or thematic risks or issues or any other internal audit engagements requested by the Secretary or the Comptroller General;
• leading internal audit engagements focused on departments that do not have an internal audit function (that is, small departments; list provided in the Annex).

Such work is determined annually by OCG Audit Operations and presented in the OCG RBAP, which is shared with all deputy heads. The OCG RBAP includes a list of top government-wide risks along with the associated OCG audits that are planned:

• horizontal internal audits in large and small departments in areas of high risk (approximately one horizontal audit per year);
• audit coverage specifically tailored to small departments that involves five-year cycles of self-assessments in key financial management policy areas and follow-up audits to assess the accuracy of self-assessments in a sample of departments.

Given the coverage by departmental internal audit functions in the area of transfer payments, no OCG horizontal internal audits have been completed in this area in recent years. None are currently planned going forward.

12. Policy on Results (information provided by Expenditure Management Sector)

The Federal Administration Act requires that all Gs&Cs programs undergo a review of relevance and effectiveness every five years (Financial Administration Act, subsection 42.1).

The Policy on Results elaborates on this requirement, assigns responsibilities to ministers and deputy heads, and outlines the Mandatory Procedures for Evaluation.

The Treasury Board clarified, through the Policy on Results, that these mandatory reviews are in fact evaluations and that the requirement only applies to Gs&Cs with an annual average expenditure that exceeds $5 million (Policy on Results, subsection 2.5).

However, even if a Gs&Cs program is exempt from the Financial Administration Act requirement, departments still need to consider if the risks, needs and priorities warrant an evaluation (for example, to support funding renewal or performance improvement).

13. How many G&C evaluations are completed by the Government of Canada?

According to an annual survey carried out by TBS, the Government of Canada completed a total of 331 evaluations over the past three years:

Source: 2023–24 Capacity Survey on Results

Roughly one third, or about 100 of those evaluations, were evaluations of G&C programs over $5 million.

Some examples of G&C evaluations completed in 2023–24 include:

• Evaluation of Management and Implementation of Agreement and Treaties (Crown-Indigenous Relations and Northern Affairs Canada);
• Horizontal Evaluation of Canadian Drugs and Substances Strategy (Correctional Service Canada);
• Evaluation of the Fisheries Funds (Fisheries and Oceans Canada);
• Evaluation of the Core Climate Change Mitigation Program (Quarter 1, 2022 to 2023) (Environment and Climate Change Canada);
• Evaluation of Future Skills Program (Employment and Social Development Canada);
• Anti-Crime and Counter-Terrorism Capacity Building (Global Affairs Canada);
• Canadian Drugs and Substance Strategy (including opioids and drug overdose crisis in Canada) (Health Canada);
• Thematic Evaluation of Computers for Schools and the Computers for Schools Intern Program (Innovation, Science and Economic Development Canada).

14. What observations can be made about evaluations, including those of grants and contributions?

A recent review of the Treasury Board Policy on Results found that:

• evaluations are used by departments and central agencies for program improvement, public reporting and resource allocation decisions;
• most senior decision-makers found evaluation findings useful for these purposes.

15. What transparency mechanisms are in place for grants and contributions?

The proactive publication of Gs&Cs falls under the Access to Information Act, section 87, which requires:

• government entities to publicly disclose Gs&Cs with a value of more than $25,000, including amendments.

Gs&Cs funding must be published on the Open Government Portal within 30 days after the end of the quarter in which an agreement was entered into.

In addition, grants and contribution program information, results and financial information is presented as part of Supplementary Information Tables on departmental websites.

These Supplementary Information Tables are available at the same time as Departmental Plan and Departmental Results Reports, which are tabled in Parliament by the President of the Treasury Board.

16. Are departments still required to report on grants and contributions under $25,000?

The Access to Information Act applies to Gs&Cs over $25,000 (subsection 87(1)) as well as Gs&Cs that are of $25,000 or less but were amended to have a value over $25,000 or more (subsection 87(2)).

However, the TBS Guidelines on the Reporting of Grants and Contributions Awards encourages that departments report on all transfer payments, regardless of value.

17. How do grants and contribution programs address potential conflicts of interest?

The Policy on Transfer Payments and its supporting instruments require that recipient funding agreements include a provision that no current or former public servant or public office holder receive direct benefit from the funding.

18. Do transfer payments have an integrity regime?

The Policy on Transfer Payments does not have a formal integrity regime such as procurement contracts.

However, the policy requires that Gs&Cs be managed in a risk-based manner.

As part of the departmental risk assessment, program managers will look at the capacity of the recipient and other criteria in alignment with the Minister’s tolerance for risk.

19. What are the best practices in grants and contributions?

Best practices for Gs&Cs include well-thought-out design and delivery considerations that:

• address government priorities and achieve results for Canadians;
• support sufficient and effective oversight to manage the risks involved;
• are recipient-focused and deliver value for money.

Some concrete examples of best practices include:

• clearly defined roles, responsibilities and accountabilities for the management of Gs&Cs within a department;
• potential recipients can access programs that have clear application processes that follow accessibility standards;
• standard administrative practices across programs within a department to ensure a consistent approach and user experience;
• the implementation of an internal governance structure to review existing processes and continuously improve service delivery and, as applicable, make funding recommendations for higher-risk projects;
• ongoing training is available to employees related to the design, delivery and management of Gs&Cs.

20. What are the challenges with decentralization and the best practices specific to standardization of departmental practices?

Decentralization of program administration or the practice of having a unique set of program policies and procedures presents challenges for applicants and recipients.

Departments operating in a decentralized model may not have the same understanding of program delivery approaches, such as the elements of a funding agreement, the use of advance payments and how to monitor higher-risk recipients.

Conversely, the benefits of standardized practices and procedures within a department is a consistent approach to the delivery of Gs&Cs.

It helps applicants and recipients understand and anticipate the requirements of applying for and receiving government funding.

Standardization also benefits departmental officials by ensuring that roles and responsibilities are clear and that operational practices are effective in ensuring stewardship of public funds.

Some best practices for standardization may include:

• the development of shared tools and templates for risk assessment, recommendations for approval, funding agreements and requests for payment;
• evergreen guides and training to outline expectations and ensure a common understanding among practitioners;
• the establishment of a feedback loop to ensure that tools, templates and training are effective and efficient;
• an oversight function that facilitates discussions and information-sharing to work through operational questions to support informed decision-making.

21. What is the Treasury Board of Canada Secretariat doing to support innovation in grants and contributions design and delivery across government?

The pandemic has accelerated the pace of change and required us to rethink Gs&Cs design and delivery to explore innovative ways to support systemic change across government.

TBS engaged delivery departments over the course of 2022 to 2023 to surface innovations and modernization initiatives and developed an interdepartmental agenda of work. This enterprise-wide approach, co-developed with ministries, addresses key enabling systems and resources across three broad pillars:

1. digital and data: transforming digital and data capabilities to support design and delivery;
2. policies and processes: supporting flexibility, integrity and results in Gs&Cs delivery;
3. people and culture: empowering our Gs&Cs practitioners with learning, training and development opportunities.

This shared collaboration initiative is encouraging interdepartmental pilots, surfacing best practices, and creating whole-of-government approaches when and where they make sense.

22. What are the training supports offered by the Office of the Comptroller General and available to departments?

The OCG has worked closely with the Canada School of Public Service to launch a four-part, self-directed, online Grants and Contributions Learning Series.

Four courses were launched between October 2023 and May 2024, and include:

• Transfer Payment Basics;
• Authorities Related to Transfer Payments;
• Entering into a Funding Agreement;
• Managing and Monitoring a Funding Agreement.

The Grants and Contributions Learning Series enrollment to date is at almost 3,700 participants and is available as an ongoing reference tool for all participants. This includes course content and references as well as job aids.

23. To what extent are grants and contributions provided to under-represented groups?

When the Treasury Board approves a Gs&Cs program, departments are required to provide evidence on why and how the initiative will deliver targeted outcomes, including for specific and diverse groups. This is captured through Gender-Based Analysis Plus (GBA Plus).

Additionally, as per the Policy on Transfer Payments, deputy heads are responsible for ensuring that transfer payments programs are designed and delivered to be inclusive and gender- and diversity-sensitive.

TBS is aware that departments may support under-represented groups in the following ways:

• doing specific calls for proposal targeted to under-represented groups;
• allocating a portion of the overall Gs&Cs budget to address funding gaps; or
• provide additional consideration to under-represented applicants when making funding recommendations.

24. Are there specific grants or contributions provided to Indigenous recipients?

Indigenous Services Canda and Crown-Indigenous Relations and Northern Affairs Canda have Gs&Cs designed for and delivered to Indigenous recipients.

Other departments consider the importance of providing funding to Indigenous recipients as part of the design of the grants and contribution program.

TBS is aware that departments may operationalize these design elements in the following ways:

• doing specific calls for proposal targeted to Indigenous recipients;
• allocating a portion of the overall Gs&Cs budget to address funding gaps; or
• provide additional consideration to under-represented applicants when making funding recommendations.

25. How are Indigenous peoples defined in a grants and contribution context?

The Policy on Transfer Payments instruments define Indigenous people and recipients.

“Indigenous people” reflects the definition of Aboriginal Peoples of Canada in the Constitution Act, 1982, namely First Nation, Inuit and Métis Peoples.

An Indigenous recipient is the Indigenous individual or entity that has received a grant or contribution.

The Ts&Cs of a Gs&Cs program typically define and scope this eligibility in specific terms. For example, they may list their eligible recipients as:

• an Indigenous (First Nations, Inuit or Métis) governing body or one of their agencies that have historically demonstrated its commitment to artistic or heritage activities, including Indigenous heritage or cultural practice in their community;
• First Nations governments and communities in Canada, including bands, district, tribal councils and associations;
• Inuit representative organizations, Inuit governments and Inuit communities;
• Métis representative organizations and Métis settlements.

26. Are there special considerations for smaller organizations as recipients?

The requirements of the Directive on Transfer Payments provide for accountability, transparency and effective control in the management of transfer payments, regardless of the size of the recipient organization.

Smaller organizations can have various levels of risk and administrative requirements, which are identified through departmental risk assessments.

27. What is a grant? What is a contribution? What is procurement?

Transfer payments, which include Gs&Cs, are monetary payments that do not result in a recipient providing a good or performing a service for the Government of Canada.

They are payments that assist eligible recipients in undertaking their activities or projects, which contribute to government priorities and objectives.

• Specifically, grants are payments to recipients who meet eligibility criteria. There are no other conditions except that they may be asked to report on their results, based on departmental practice; whereas contributions are payments to recipients with conditions, which include results and financial reporting.

Procurement contracts are agreements between a contracting authority and a person or firm to provide a good, service or construction, or to lease real property. Contracts are instruments used to provide a good or service to the federal government.

In short, there are no real pros or cons to using Gs&Cs for procurement; rather, it is a distinction between the appropriate instrument to be used. What instrument you use depends on who is receiving the benefit.

28. What are the considerations for selecting a grant or a contribution?

Departments also recommend whether a funding program should have grants and/or contributions as Treasury Board submission process.

Grants do not require financial accounting but may require results reporting, depending on the departmental practice. As such, they are appealing for those recipients, such as academic institutions, that are deemed low-risk and have demonstrated capacity to deliver.

Contributions are used when performance and financial oversight is needed to give the department assurance that the recipient is on track to achieve success. While recipients may find the reporting requirements burdensome, they allow the department to review progress against eligible activities and expenditures to ensure they are appropriate and reasonable.

29. What are the policy requirements with respect to value for money?

The Policy on Transfer Payments defines value for money as the extent to which a transfer payment program demonstrates relevance and performance:

• relevance is achieved by addressing a need that is appropriate for the federal government and is responsive to the needs of Canadians;
• performance is achieved by using taxpayer resources to support outcomes consistent with transfer payment program objectives.

The policy requires that deputy heads ensure that Gs&Cs programs and their Ts&Cs are continuously kept up to date to ensure that program objectives can be achieved.

30. Why is information management challenging for grants and contribution practitioners?

Information management is not a requirement of the Policy on Transfer Payments.

However, other Treasury Board policies govern how information is to be retained and stored to support decision-making and oversight mechanisms, such as internal audits and program evaluations.

Additionally, the Financial Administration Act requires documentation to support sections 32, 33, 34. These are key financial stewardship processes that need to be followed.

31. Does the policy allow for grants and contributions to recipients outside of Canada (that is, foreign recipients)?

The Policy on Transfer Payments does not restrict the types of applicants who are eligible to receive funding.

Departments have the discretion to determine who is eligible to receive funding, for which activities and for what expenses.

Departments consider these elements when designing the Gs&Cs program and detail them in their program Ts&Cs. Funding to foreign recipients could be provided if the department has determined if funding to these types of recipients is necessary to achieve their program objectives.

32. How many departments are currently operating with grants and contributions information technology systems that are not integrated?

Based upon 2022–23 survey data and ongoing engagements with the over 50 Gs&Cs delivery departments and agencies:

• very few departments have a single information technology system to support all their Gs&Cs programs;
• delivery organizations which have a single system tend to be smaller, with specialized Gs&Cs programs (for example, Atlantic Canada Opportunities Agency; Canada Economic Development for Quebec Regions; Immigration, Refugees and Citizenship Canada; the Department of Justice Canada; Women and Gender Equality);
• of these organizations, Atlantic Canada Opportunities Agency, Canada Economic Development for Quebec Regions and the Department of Justice Canada have fully integrated their Gs&Cs system with their financial system;
• approximately 12 organizations (Agriculture and Agri-Food Canada; Canadian Space Agency; Employment and Social Development Canada; Health Canada; Indigenous Services Canada; Innovation, Science and Economic Development Canada; Public Health Agency of Canada; Public Safety Canada; Transport Canada; Canadian Institutes of Health Research; Natural Sciences and Engineering Research Council of Canada; Social Sciences and Humanities Research Council of Canada) have at least partial integration to their financial system for at least one of their portfolio programs;
• Environment and Climate Change Canada, Fisheries and Oceans Canada, Library and Archives Canada, and Natural Resources Canada are in the planning stages for a financial system integration with Gs&Cs;
• TBS (Office of the Comptroller General) continues to work with departments and agencies to support the delivery of their Gs&Cs through a common approach to systems and data.