Guidance for Drafters of Treasury Board Submissions

Title

The title should be no more than 20 words and succinctly convey the submission’s purpose.

Synopsis

The synopsis should be no more than 150 words and include the following:

• a summary of the authorities sought
• total cost
• how and when the initiative will be implemented
• key intended outcome(s) of the initiative, specifically, the change(s) that would result if the initiative were approved
• overall residual risk level

Authorities sought from the Treasury Board

Begin with: “It is proposed that Treasury Board…” followed by a numbered list of the authorities being sought.

When seeking authorities for multiple departments, ensure that these are distinct (do not create a hybrid authority for more than one organization).

Learn more about commonly sought authorities and how to draft them by consulting Commonly Sought Authorities (accessible only on the Government of Canada network).

Design

Outline the rationale for the design of the initiative and how it will work to achieve outcomes.

How?

• Will the initiative involve direct delivery, a contract, grants and contributions, or other mechanism?
• What or who will benefit? Who are the intended recipients, and how will eligibility be determined (if relevant)?
• How will funding flow from the federal organization to the ultimate recipient?
• What agreements or mechanisms exist or will be put in place?
• What system components will be designed, upgraded or replaced?
• If applicable, what is the procurement strategy to deliver and implement this initiative?

Why?

• Why is the proposed approach best suited to achieve the desired outcomes? Examples are past results data and other evidence, such as evaluations.
• What is the value for money? Examples are expected efficiency or effectiveness.
• How have parameters from policy decisions informed the design? Examples are memoranda to Cabinet, budgets or funding decisions.
• What key constraints were considered?
• Are there any significant trade-offs involved? Examples are service standards and cost.
• How does the initiative link to or impact other programs or initiatives at federal, provincial and territorial levels? Examples are complementing efforts, filling gaps, and allowing certain activities to be discontinued.

Who?

• Who is impacted by the initiative? Explain how Gender-based Analysis Plus (GBA Plus) (GBA Plus) considerations informed the design of the initiative.

Identify gaps in available evidence that supports the proposed design, either overall or in part (for example, a lack of experience delivering a service to a particular group). Be clear whether these gaps will be addressed through a deliberate design choice (for example, a pilot, an evaluation with a randomized controlled trial, or other form of experimentation).

Delivery and implementation

Outline how the design will be applied and executed. Address details such as the following:

• major tasks and activities to be undertaken, including key milestones and timelines, communications considerations, procurement strategy, due diligence requirements for real property transactions, and the basis for associated payments
• who is involved in implementing the initiative, including other government departments and organizations, provinces and territories, partners (including Indigenous partners), or suppliers (for example, for third-party services)
• how the approach will avoid overlap or duplication of other programs or initiatives

Include the following as applicable:

Stakeholder consultations and partner engagement

Describe who was consulted or engaged with to develop the implementation plan (for example, other levels of government and non-governmental organizations, Indigenous groups, equity-seeking groups) and how they were included. Outline:

• what influence the consultations had on the proposed approach
• what ongoing consultation or engagement, if any, will take place

If applicable, describe co-development with Indigenous partners.

Governance structures

Explain how governance structures will oversee the initiative. Do not simply provide a list of existing or planned committees. Instead, outline the initiative’s leadership (that is, accountable office), oversight and management structures, including (as relevant):

• the assigned roles and responsibilities of implementation partners
• any dispute resolution or change processes
• capacity of supporting governance (for example, project office and reporting mechanisms)
• any evaluations or assessments of the efficacy of the governance

Other considerations

Organizations are also expected to describe how applicable government-wide requirements and considerations have informed the design of the initiative. For example:

• Indigenous considerations, including:
  • the legal duty to consult
  • modern treaty implications
  • the Inuit Nunangat Policy
  • whole-of-government approach to implementing the United Nations Declaration on the Rights of Indigenous Peoples Act (UNDA) and the UNDA Action Plan
  • mandatory minimum target that 5% of the total value of federal contracts be sourced from Indigenous firms
• official languages, including the Advancement of Equality of Status and Use of English and French (Part VII of the Official Languages Act)
• well-being considerations informed by Statistics Canada’s Quality of Life Hub (for information on Canada’s Quality of Life Framework, consult Measuring What Matters: Toward a Quality of Life Strategy for Canada)
• assessments made through a Climate, Nature and Economy Lens (CNEL) as set out in the Cabinet Directive on Strategic Environmental and Economic Assessment (for information, consult Strategic Environmental and Economic Assessments - (accessible only on the Government of Canada network)
• sustainability considerations (consult Canada’s Federal Implementation Plan for the 2030 Agenda, Greening Government Strategy and Policy on Green Procurement)
• service and digital considerations (consult the section on the Service and Digital Appendix)

Consult with your TBS Program Sector analyst on these or other additions.

Cost and source of funds

When this section is required, provide a summary that includes the following:

• total cost:
  • total cost of the proposal at the departmental level on a cash basis, including the fiscal year range over which costs will be incurred and any ongoing funding
• source of funds:
  • clearly identify the approved source of funds to finance the proposal (for example, Budget 20XX, off-cycle funding decision, existing reference levels)
  • submissions without a confirmed source of funds will not be considered by TB
• accrual profile:
  • indicate whether the accrual profile is the same as the cash profile; if they differ, provide a brief overview of the accrual profile
• key funding elements:
  • highlight any distinct sub-measures or components and their amounts that correspond to key elements of a funding decision
• required table(s):
  • include the Cost, Funding Requirements and Source of Funds Table by Estimates Vote Structure in the Financial Appendix (accessible only on the Government of Canada network)
  • if cash and accrual profiles for new funding differ, also include the Accrual Profile of New Funding table in the Financial Appendix (accessible only on the Government of Canada network)
  • depending on authorities sought, additional tables (such as special purpose allotment tables or frozen allotment tables) may be required

Examples of summary statements

Strategic costing considerations

To support informed decision-making, communicate the total life-cycle costs of a proposal based on available information, including the following:

• degree of financial risk to the Government of Canada
• long-term financial implications
• resources required for a successful transition to operations

Cost estimate ranges should be developed and assessed in full alignment with the expectations laid out in the Guide to Costing and Guide to Assessing Cost Estimates to ensure that the credibility of costing information is achieved for informed decision-making.

As part of early engagement, particularly on complex proposals, departments should provide TBS with:

• the cost model used to develop the costing information
• supporting documentation, evidence and data that informed key aspects of the costing that would be important to inform strategic decision-making
• other documents as requested by TBS

To promote an informed discussion of key financial considerations, the costing narrative should be clear and concise, with emphasis on strategic-level considerations, such as the following:

• the range of potential cost outcomes, including best- and worst-case scenarios
• risks, uncertainties, opportunities and limitations that may cause estimated cost ranges to fluctuate in the future
• contingency included in the authorities sought and an assessment of whether it is expected to be sufficient to mitigate the risks, uncertainties and limitations described above
• findings of validation efforts undertaken to assess the reasonableness of the costing information and whether it represents value for money to the Government of Canada (this may include comparisons to independent estimates, benchmarking studies or the cost of similar initiatives)
• governance structures, processes and strategies in place to monitor the initiative’s implementation and proactively monitor, update and refine cost estimates as new information becomes available
• factors that have driven variations in estimated cost ranges from previous Cabinet proposals or funding requests, as applicable

Where there is an increased investment in an existing initiative, indicate what percentage of an increase it represents and what, if any, impact it has on overhead (administrative) costs.

For proposals that are complex or involve significant costs, strategic costing considerations should be elaborated upon in a dedicated Costing Information Appendix (accessible only on the Government of Canada network). To confirm whether this requirement applies and to receive guidance on completing the appendix, departments should consult their TBS Program Sector analyst and the Investment Management Sector of the Office of the Comptroller General at CCE-CEEC@tbs-sct.gc.ca.

Defining the initiative and its goals

• The initiative’s intended key outcome(s) and the difference, change or impact that the initiative seeks to make (what success looks like)
• How the initiative will enable that change effectively and efficiently
• For proposals that form part of a broader strategy, how the initiative’s impacts contribute to achieving the broader outcome

Measuring and monitoring performance

• How outcomes and outputs will be measured
• How results will be monitored and what interventions are planned if progress unfolds differently than anticipated
• Data collection plans to generate reliable performance information (for example, disaggregated data in support of GBA Plus)

Evaluation progress and learning from experience

• For existing initiatives, how results have evolved over time
• Plans for evaluation to complement ongoing performance measurement and support decision-making
• For existing initiatives, information on previous evaluations (for example, when they took place, findings and actions to improve areas of underperformance)

Additional information on the Policy on Results and other results-related resources is available on the TBS Results Portal (accessible only on the Government of Canada network). Additional resources on GBA Plus are available on the GBA Plus Resource Centre (accessible only on the Government of Canada network).

Legal risks

The high-level overview of the legal risks associated with the initiative should be included in the body of the TB submission. Also include the rationale for selecting low, moderate, balanced, elevated or high. The legal risk range for each legal risk level is as follows:

• low: below 30%
• moderate: 30% to 50%
• balanced: 50%
• elevated: 50% to 70%
• high: above 70%

The legal risk level selected will consider any mitigation measures that the organization commits to implementing. If multiple legal risks are identified, the legal risk level is determined by reference to the issue that presents the highest level of legal risk. Legal risks must be reflected in the rating even if it’s unlikely that there would be any legal consequences (for example technical breaches to legislation).

The legal risk assessment must be drafted by the organization’s legal services unit. For organizations receiving legal services from the Department of Justice Canada, the legal risk analysis is a Justice Canada–led assessment and based on its legal risk framework. For other organizations, this section should indicate that these risks were determined by the organization’s legal advisors. Further elaboration in the appendix may be required if requested by your TBS Program Sector analyst.

If the legal risk is moderate, balanced, elevated or high, a departmental response that indicates the mitigation measures that will be implemented, as relevant, to address the legal risk as well as the department’s assessment of the likelihood of a legal challenge should be provided. Organizations should consult their legal counsel early in the submission process, prior to submitting a first draft.

The draft legal risk assessment must be included in the first draft of the TB submission for TBS to proceed to substantive review; if this section is missing, the submission will not pass the quality review stage.

Resources

• Guide to Costing
• Guide to Assessing Cost Estimates
• Costing Information Appendix (accessible only on the Government of Canada network)

Table on Cost, Funding Requirements and Source of Funds by Estimates Vote Structure

Any TB submission that has cost impacts must include a Table on Cost, Funding Requirements and Source of Funds by Estimates Vote Structure. If the submission’s accrual profile differs from its cash profile, an Accrual Profile of New Funding Table is also required to present accrual information. If there is more than one source of funds (such as funds for more than one department or more than one initiative), a dedicated table is required for each one. A consolidated funding table may be included but cannot replace the requirement for individual tables for each source of funds.

Unless otherwise negotiated, departments must include:

• the Shared Services Canada core information technology services premium, calculated as 4% of FTE salary costs
• the Public Services and Procurement Canada accommodation premium, calculated as 13% of FTE salary costs

TB submissions should include Employee Benefit Plan (EBP) funding requirements based on the EBP rate in effect at the time of the funding decision. EBP rates are as follows:

The template for the Table on Cost, Funding Requirements and Source of Funds by Estimates Vote Structure is available in the required bilingual format: Cost, Funding Requirements and Source of Funds Table by Estimates Vote Structure Template (accessible only on the Government of Canada network).

The table presents total costs on a cash accounting basis. The numbers in the table should:

• be whole numbers
• add correctly
• be consistent with costing information and with the financial information in the tables for costing due diligence, validation and other detailed financial tables

The total costs are at the organizational level and broken out by vote, input factor, accommodation costs and other statutory items. The table is separated into three sections: “New funding,” “Existing funding” and “Transfers.”

The following are requirements for completing the table:

Funding and financial breakdown

• If the submission is seeking new funding for an existing program, include the full amount for the initiative in the costing table (new funding and existing funding).
• If the submission is seeking approval of new grants or increases to existing grants, include the names of the grants and amounts to be included.
• Include vote-netted revenue if your organization is seeking an authority related to such revenue.
• The grand total represents the initiative’s total cost, except when adjustments to vote-netted revenue are included in the submission. In these cases, the grand total does not represent total costs because costs funded by revenues have been netted in the TB submission. In the text section, include costs funded by revenues when presenting the total cost of the initiative.
• If more than one organization is involved, the grand total should be the sum of all organization-specific costing tables.

Personnel-related costing details

• EBP and accommodation premiums are calculated as a percentage of personnel costs and are rounded to the nearest dollar.
• If the accommodation premium is not 13% of new personnel funding, provide a footnote to explain the difference (for example, in cases where Public Services and Procurement Canada is not the custodian of the related buildings).

Special costing notes and annotations

• For any amount that the submission seeks from TB Vote 5: Government Contingencies, indicate with an asterisk the figure(s) in the table to which the footnote relates.

Transfers between organizations or between votes within an organization

Under the “Transfers” section of the table, indicate in the “Sending organization” and “Receiving organization” areas the transfer by organization, vote and input factor. The sending organization amount will show as a negative, and the receiving organization amount will show as positive. The “Transfers” section should total to zero.

For current-year transfers of personnel, the increase in the personnel sub-allotment of the receiving organization should be offset by an identical reduction in the personnel sub-allotment of the sending organization. If there is no transfer of personnel, transfers to or from the operating budget allotment should be made entirely within the other operating costs sub-allotment.

Chief financial officer attestation

The Guideline on Chief Financial Officer Attestation for Cabinet Submissions requires chief financial officers (CFOs) to:

• perform a due diligence review of the financial management aspects of TB submissions
• provide an attestation on their findings

The CFO is to attest to the accuracy of financial information contained in organizations’ Cabinet submissions, as at the date of signature, by:

• conducting robust analysis based on the best information currently available to support decision-making
• challenging the assumptions and proposals made by program areas, noting that the CFO attestation on the financial implications of a submission does not constitute an assessment of policy or program effectiveness
• maintaining supporting documentation
• being involved early in the TB submission’s development

The CFO’s attestation letter is expected to cover six assertions and include an overall conclusion. It is recommended that any material observations regarding a specific assertion be detailed as part of, or directly following, the assertion itself.

The overall conclusion takes into account the six assertion statements and any observations made. The three options for the overall conclusion in the attestation letter are that the proposal:

1. has sufficient financial information for decision-making
2. has insufficient information for the CFO to assess the proposal’s financial aspects
3. has substantial financial issues or risks

Where a CFO is unable to assess or has identified substantial financial issues or risks (conclusions 2 and 3 above), it is recommended that the CFO consult with:

• departmental managers and the deputy head
• their TBS Program Sector analyst
• the Office of the Comptroller General, Financial Management Sector

Such consultations will provide TBS with awareness of any uncertainty or increased risk associated with a TB submission.

The Guideline on Chief Financial Officer Attestation for Cabinet Submissions contains an example of text for a CFO attestation letter.

CFO attestations should be provided for all submissions, including those that do not have financial implications. Consult your TBS Program Sector analyst if you have questions regarding the CFO attestation.

Overview

The appendix should expand the narrative for FTEs provided in the “Design, delivery and implementation” section. The following questions should be considered:

• How many FTEs are required and why? See the definitions below.
• Why are new FTEs required? Examples are increased workload or a new program.
• What are high-level descriptions of the work or area of responsibility, summarized in main groups of activities? Examples are policy development, data analysis and processing.
• What efforts have been made to minimize the number of FTEs requested? Examples are innovations and efficiencies in processing.
• What happens to new FTEs once time-limited funding expires?

Your TBS Program Sector analyst may request a table. A template is available at Human Resources Table (accessible only on the Government of Canada network).

Resources

• Work Force Adjustment Directive
• Policy on People Management
• Policy on the Management of Executives

Resources

• Policy on Results
• Directive on Results
• Guide to Departments on the Management and Reporting of Horizontal Initiatives

Constitutional Duty to Consult

The Government of Canada has a duty to consult and, where appropriate, accommodate Indigenous groups when it considers conduct that might adversely impact potential or established Aboriginal or treaty rights. This includes initiatives that aim to implement the Aboriginal rights of a group where other groups may have overlapping rights or claims.

Departments are encouraged to consult with their legal services units and related guidelines for federal officials to assess whether an initiative involves a constitutional duty to consult. The Consultation and Accommodation Unit of Crown-Indigenous Relations and Northern Affairs Canada supports federal departments in fulfilling the Government of Canada’s duty to consult by providing guidelines, training and other tools.

The Indigenous Considerations Appendix should provide detailed information on consultations undertaken and with whom. It should also provide information on the following:

• whether any issues were raised during these consultations
• how the proposal was designed to address the issues raised, including any accommodations
• where issues cannot be accommodated, how the department intends to manage any risks involved

Inuit Nunangat Policy

The Inuit Nunangat Policy sets out an approach for considering the perspectives of Inuit and the potential impacts of proposed federal initiatives on Inuit and/or Inuit Nunangat. Departments should assess whether their proposal involves the Inuit Nunangat or is likely to have an impact on its residents.

If it does, the Indigenous Considerations Appendix should detail how the submission aligns with the principles of the policy, such as the provision of communications materials in Inuktitut or reporting requirements related to Inuit-specific funding allocations, as applicable.

Modern treaty implementation

Modern treaties describe federal obligations to specific Indigenous signatories and must be considered in the context of those treaties.

The Indigenous Considerations Appendix should demonstrate how the submission supports the full, effective and timely implementation of modern treaties. Drafters are encouraged to consult Canada’s Collaborative Modern Treaty Implementation Policy for further information.

The appendix should also confirm:

• that an assessment of modern treaty implications has been completed
• how the initiative has been designed to comply with the provisions and obligations contained in the relevant modern treaties

United Nations Declaration on the Rights of Indigenous Peoples and the United Nations Rights of Indigenous Peoples Act

Departments also consider whether the proposal may potentially affect the rights and interests of Indigenous Peoples (First Nations, Inuit or Métis), be they direct, indirect, positive or negative, as set out in the United Nations Declaration on the Rights of Indigenous Peoples.

Resources for public servants on the declaration and action plan are available at Implementing the United Nations Declaration on the Rights of Indigenous Peoples Act. The Department of Justice Canada has also published a backgrounder on the United Nations Declaration on the Rights of Indigenous Peoples and the United Nations Rights of Indigenous Peoples Act (UNDA) and its interpretation.

The Indigenous Considerations Appendix should provide detailed information on how the department has considered its obligations under sections 5 and 6 of the UNDA and fulfilled them. This information should be developed in consultation with your departmental consultation and engagement unit and legal services.

Resources

• Guidelines for federal officials on Crown-Indigenous Relations and Northern Affairs Canada and Indigenous Services Canada
• Inuit Nunangat Policy
• Cabinet Directive on the Federal Approach to Modern Treaty Implementation
• United Nations Declaration on the Rights of Indigenous Peoples Act Action Plan

Resources

• Official Languages Act
• Official Languages (Communications with and Services to the Public) Regulations
• Policy on Official Languages and its related directives

Resources

• Policy on Service and Digital
• Directive on Service and Digital
• Strategic plans, policies, standards and guidelines related to government digital services
• Directive on Stewardship of Financial Management Systems

Greening Government and Green Procurement

Submissions related to government operations in the following areas must comply with the Greening Government Strategy and the Policy on Green Procurement:

• government-owned and leased real property
• fleets (conventional; national safety and security)
• government services and activities
• procurement of goods and services, including materiel management

For more information, consult Supplementary Guidance for Drafters of Treasury Board Submissions: Greening Government (accessible only on the Government of Canada network) and the following as required:

• Standard on Embodied Carbon in Construction
• Standard on the Disclosure of Greenhouse Gas Emissions and the Setting of Reduction Targets

Sustainable Development

Additional information may be required when there are sustainable development considerations to highlight for the initiative. The Federal Sustainable Development Act provides the legal framework for developing and implementing the federal Sustainable Development Strategy to make environmental decision-making more transparent and accountable to Parliament.

For more information and guidance, consult Environment and Climate Change Canada’s website and your organization’s Sustainable Development Strategy.

Resources

• Cabinet Directive on Strategic Environmental and Economic Assessment
• Greening Government Strategy
• Policy on Green Procurement

Rationale

• Detailed description with supporting evidence of why an additional corporate identifier is required; examples are qualitative or quantitative research, statistics, and feedback from target audience
• Potential risks or sensitivities associated with the department adopting an additional corporate identifier and mitigations for each
• Anticipated duration of the additional corporate identifier and a rationale for the proposed timeline
• If there is interest in including additional corporate identifiers in stationery (for example, letterhead, envelopes, business cards) and vehicle applications (for example, fleet motor vehicles), organizations will need to consult with TBS and provide a rationale
• Confirmation that the additional corporate identifier:
  • will not be used in government signage
  • will not be used in place of the official symbols in partnering arrangements, sponsorships, or federal acknowledgments for grants and contributions
  • will be used in conjunction with the official symbols of the Government of Canada (corporate signature or Government of Canada signature and Canada wordmark)

The following will not be accepted as a rationale:

• a need to create a positive public perception of the department or program
• a need to give specific prominence over and above the Government of Canada
• internal interests
• a need for compatibility with symbols of another institution or government
• a need to change public awareness or perception
• a need to increase recognition

Delivery and implementation details

• Description of the outcome of consultations to demonstrate the need for an additional corporate identifier, including:
  • who was consulted
  • approximate number of participants
  • questions or topics covered
  • how the information gathered from consultations influenced the current proposal
• Outline of the potential impact, if any, on other departments (for example federal departments, provincial or territorial counterparts, international partners)
• Description of how the department will monitor and collect measurable data about the new corporate identifier to determine whether it performs as planned, why it is or isn’t performing, and the public’s perception of the identifier
• Outline of the legal provisions or protections that will be required for the additional corporate identifier to ensure it is not used by any individual or organization outside the Government of Canada
• Outline of the department’s capacity to manage the implementation of an additional corporate identifier, including the financial and human resources implications to design, develop, implement, manage and advise department officials on the use of an additional corporate identifier, such as developing a graphic standards manual

Cost analysis

• Details on projected financial and human resources costs associated with adopting an additional identifier, including:
  • research and consultation
  • design, development, production and printing
  • implementation (including distribution)
  • management

Periodic review

• Confirmation that the department will conduct periodic reviews and provide a clear outline of the review frequency (for example, monthly, quarterly, annually)

Consultation with the Treasury Board of Canada Secretariat

• Confirmation that the department will engage with the Communications and Federal Identity Policy Centre at TBS to:
  • ensure the design meets official language, accessibility, legibility and non-partisan requirements
  • create standards manual prior to implementation
  • address requirements related to legal protection and measures to address misuse or unauthorized use (for example, trademark registration)
  • seek advice on subsequent amendments to the design or changes to its application