Key Considerations for Drafting a TB Submission

This tool provides a series of practical questions that your organization should take into consideration when discussing a proposal for the Treasury Board and drafting a submission. The questions are reflective of the perspectives of program analysts, assistant secretaries and ministers in their review of Treasury Board (TB) submissions.

The tool’s objective is to help strengthen TB submissions by supplementing the Detailed Guidance for Writers. The structure of the tool aligns with the main sections in the guidance.

Table of Contents

Authorities Sought From the Treasury Board

  1. Do the proposals in your submission conform to existing organizational and/or Treasury Board authorities?
    • Have you listed the source of the authority for bringing the submission before the Treasury Board (e.g., specific law, regulation, Cabinet decision) in the appendix entitled Existing Statutory and Policy Authorities?
    • Are there any legal issues?
    • Do they align with your organization’s mandate?
  2. Do your proposals provide sufficient and appropriate new or amended authorities to proceed with implementation of the initiative?
    • Have all appropriate ministers or delegates signed the submission?
    • Are your proposals clear, straightforward and worded in a manner to achieve the desired outcome?
    • Are any Treasury Board policy exceptions required to deliver the initiative? For example, if the initiative is to be delivered through contracting, will contracts exceed Treasury Board contracting limits or other policy conditions and therefore require Treasury Board authority? Provide a clear rationale for the exception from a Treasury Board policy and indicate how long the exception will apply.
    • Are there any outstanding Treasury Board conditions related to this initiative?
    • Will approval of your proposals create precedents?
    • Will vote wording need to be changed, or will a new vote be required (e.g., to write off a debt owing)?
    • Is this a program that requires new terms and conditions? Are there any exceptions to the terms and conditions required?
    • Will delivery of the initiative require a project authority? Has a Project Complexity and Risk Assessment been completed?
    • Will delivery of the initiative require Treasury Board approval of contracting authority? If yes, what is the basis for the cost estimate? What were the assumptions used in the cost estimate, and are they reasonable? Will the procurement touch on an area of particular interest to Treasury Board ministers?
    • Is an order-in-council required? Will this also need to go to Treasury Board?


What is the context for each proposal?

  • How is the proposal linked to your organization’s mandate?
  • What is the history of the proposal or program? How long has it existed? What has its budget been historically? What were the previous results achieved?
  • Have there been any previous Cabinet or Treasury Board decisions related to the proposal?
  • Have there been any relevant public announcements related to the proposal?
  • How does the proposal align with your organization’s existing Program Alignment Architecture; or for those who have transitioned to the TB Policy on Results, Departmental Results Framework and Program Inventory?
    • Has your organization demonstrated a clear gap in its suite of programs and policies, or in the relevant Departmental Results Frameworks and Program Inventories of other government organizations, for horizontal activities?
    • Has your organization demonstrated that the results and associated resources of related programs in the Departmental Results Frameworks and Program Inventories of other governmental organizations support this proposal, both in terms of the proposed instrument and activities?


  1. Why is the proposed course of action needed? What problem is being solved by the authorities that are being sought?
    • How does your proposal support or link to government priorities?
    • Is this a legitimate and necessary role for the federal government, or could the problem be addressed by another level of government, the private sector or the voluntary sector?
    • How does the proposal support or link to key risks identified in your organization’s corporate risk profile (if available)?
    • Does this proposal offer an innovative opportunity, despite risks?
    • Explain how your proposal is in the public interest?
    • Could any existing solutions or instruments be used to address this issue?
    • Will the proposal pass a public scrutiny test (i.e., the test of prudence, probity and equity)?
    • Will it provide a business case and evidence to support the “value for money” argument?
  2. What is the relevant policy and expenditure context?
    • Is this a new initiative, or the renewal of an existing program? What were the previous results achieved?
    • Was the proposed course of action developed as a result of a gap analysis? If yes, please explain.
    • What are the planning assumptions associated with this initiative?
    • Has an environmental scan been completed? Does the proposed direction align with the environmental scan?
    • How does the proposed investment relate to the previous or existing level of investment by the government or other stakeholders in this policy or program area?
    • What comparative benchmarks have been used to gauge the reasonableness of this proposal? Has similar work been undertaken by other governments or other stakeholders?
    • What are the horizontal policy or program impacts associated with this initiative?
  3. How does the proposal align with your organization’s existing programs and program activity architecture (PAA)?
    • Has your organization demonstrated a clear gap in its suite of programs and policies, or in the relevant PAAs of other government organizations, for horizontal activities?
    • Has your organization demonstrated that the results and associated resources of related programs in the PAAs of other governmental organizations support this proposal, both in terms of the proposed instrument and activities?

Design, Delivery and Implementation

  1. Does the program design make sense? Is it likely to succeed?
    • How will this initiative be delivered? Is this the most cost-effective and efficient delivery approach? What alternative delivery approaches were considered (e.g., P3, third-party delivery)?
    • What is the relative proportion of internal services and administration costs to direct program costs? Is there a comparable benchmark for this kind of delivery mechanism? Are other parties delivering similar programs in a similar way? Has your organization explored potential opportunities to learn from the experiences of others?
    • To what extent has innovation and experimentation been incorporated as part of the design, delivery, and implementation of each program? What lessons can be learned from other departments and jurisdictions to help facilitate program design, delivery, and implementation? 
    • Has experimentation been used to evaluate potential alternative approaches (e.g., randomized controlled testing, behavioral insights, design thinking, co-design, etc.) to the proposed initiative?
    • What evidence and data (from evaluations, audits, studies or reviews) exist to support the selected approach to deliver the program? Does this approach allow for the rapid collection of data and performance measures to facilitate ongoing adaptation and adjustment when presented with new evidence?
  2. Have all requested Treasury Board policy exemptions and exceptions been explained and justified?
    • Are adjustments to existing authorities and policies possible to facilitate experimentation? Has the potential impact of these changes been fully assessed?
  3. Are the accountabilities of all parties clear and straightforward?
    • Are there any governance issues? If yes, how will they be addressed?
    • Are there any horizontal issues?
    • Are there any unaddressed issues impacting other federal organizations?
  4. Does your organization have the capacity to deliver the program, service or initiative?
    • Does your organization and its partners and recipients have a good track record for this kind of program or service delivery?
    • Do the organizations have experience and a demonstrated capacity to plan and deliver?
    • Do the government organizations involved in this proposal have acceptable or strong Management Accountability Framework (MAF) ratings in relevant areas? If not, what measures will be put in place?
    • Does your organization have a well-developed performance management capacity and/or demonstrated results in this area?
    • Does delivering the program, service or initiative involve the use of a new approach within your organization? If so, what skills and supporting resources may be required for the program, service, or initiative to be successfully implemented?
  5. Will your organization have the people to deliver the program, service or initiative, and what are the full-time equivalent (FTE) impacts?
    • How does your business case support the request for new, renewed or temporary FTEs?
    • Are FTEs new or existing? Will staff work at headquarters or in the regions? Are training requirements built in?
    • Are the FTEs temporary or permanent? If temporary, what are the human resources strategies in place to manage the temporary nature of the FTEs?
    • If FTEs are required, has the organization considered reallocating internally?
  6. Are there procurement or project components to the program?
    • Does the program have a project component, and does the Project Complexity and Risk Assessment (PCRA) fall within your organization's Organizational Project Management Capacity Assessment (OPMCA) rating? How does it relate to your organization's approved investment plan? Has the related PCRA been reviewed by the Treasury Board of Canada Secretariat (Secretariat)?
    • Are all submission requirements related to projects requiring Treasury Board approval included (e.g., project brief)?
    • Are all submission requirements related to IT-enabled projects included? How does this align with government-wide direction on the review of information technology (IT) and administrative services?
    • What is the procurement strategy? Will any Treasury Board approval of contracting be required?

Expected Results

  • What are the expected results?
    • How does your proposal align with the results and resources of existing programs?
    • What are the short-, medium-, and long-term expected results? How will performance and results be measured and reported)?
    • Do the expected results and performance indicators align with the relevant Performance Information Profile and Departmental Results Framework?
    • Is this a renewal, top-up or modification of a previous program? Have there been recent audits or evaluations? What were the results (e.g., what was the management response)?
    • What are the future audit and evaluation plans?
    • Do you provide a balanced review of supporting evidence, including relevant evidence supporting your result as well as discuss key opposing or unfavourable evidence?
  • Has the organization’s Head of Evaluation or Head of Performance Measurement been consulted in the development of this content?

Risks and Risk Responses

  1. How complex is each proposal?
    • Does implementation of your proposal require an exemption from Treasury Board policy and/or deviate from historical government practice/policy? Would the required exemption or deviation be precedent-setting? Is the exemption required to facilitate experimentation in program design or service delivery?
    • Does your proposal require several accountabilities or a special governance structure for its success?
    • Does your proposal have horizontal linkages? If yes, does your proposal have a strategy for managing horizontal, shared risks?
    • Does your proposal have an impact on other federal organizations? If yes, how are these addressed?
    • Does your proposal involve shared accountability for risk responses?
    • Does your proposal involve horizontal information management (IM) or IT strategies, such as those related to addressing aging IT systems?
    • Does your proposal entail the implementation of a complex project (e.g., innovative design, use of a new approach for the first time, transformative rather than incremental change, new versus mature technologies, integration of different technologies, requirement for extensive testing, complex IT solutions, etc.)?
    • Does your proposal involve an innovative and complex delivery model? For example, is a public-private partnership model being used for the first time for this kind of project or initiative?
    • Does your proposal involve security risks that require specific risk responses (e.g., IM and IT security, physical security, security screening of individuals or business continuity planning)? If yes, are these addressed?
    • Does your proposal face environmental and/or geographical risks that could impact implementation (e.g., harsh climate conditions)?
  2. Does your proposal entail legal risks?
    • Has a legal opinion been provided? If yes, does it raise any legal issues or legal risks?
    • Is your proposal in compliance with laws, regulations and international treaties? Does your organization have the legal authority to implement the proposal?
    • Does your proposal have an impact on intergovernmental agreements and/or contractual obligations?
    • Will your proposal have an impact on Indigenous peoples (e.g., touch upon matters that are the subject of modern treaties)?
    • Will your proposal have an impact on linguistic minorities?
    • Will your proposal result in litigation against the government? What would be the impact of such litigation on implementation? Is such litigation likely to be successful?
    • If the implementation of your proposal is dependent on other parties (e.g., a province), what is the risk that these other parties could be subject to successful litigation?
  3. Does your organization and others have the capacity to deliver the initiative/project?
    • Are your organization’s structures and management regimes robust enough to successfully deliver the initiative in relation to HR, security, IT, capital or project management resources, for example?
    • For projects, do the areas of highest risk, as identified in the PCRA, correspond to the areas of low capacity, as identified in your organization’s OPMCA?
    • In light of its previous experience with similar work or the adequacy of its resources, can your organization plan and deliver the initiative?
    • Has your organization previously demonstrated results in this area?
    • Are any MAF ratings relevant to your organization’s capacity to deliver the initiative?
    • Does your proposal depend on third-party involvement for its delivery?
    • Does your proposal involve providing funding to another government (e.g., province, territory, municipality or a foreign government) or the private sector (e.g., not-for-profit sector) to help them implement a project or initiative? What is their capacity to deliver and what has been their track-record?
    • For procurements, what is the capacity of the private sector to deliver the project or initiative (experience, number of firms that can carry out the work, etc.)?
  4. Does the history of the issue indicate any risks?
    • Is there potential for controversy in the public domain?
    • Are the links to the government’s priorities clear?
    • Are there any federal, provincial or territorial issues?
    • Do recent audits or reviews raise any non-financial issues?
  5. What are the financial risks?
    • What is the financial risk of proceeding with your proposal?
    • Are there any caveats or qualifications in the chief financial officer’s attestation that suggest costs may change?
    • Are the planned financial resources adequate? Do they stretch your organization’s financial resources? Could your proposal exceed your organization’s financial capacity and generate future financial pressures?
    • How large is the resource request compared with your organization’s existing budget?
    • What is the level of certainty/confidence around the cost estimate? What is the likelihood that expenditures will exceed available resources?
    • Is there a risk of default or incurring a liability or cost overruns? Have all loans been guaranteed (if applicable)?
    • If your proposal involves a cost-shared initiative/project, how firm are the funding commitments from the other party/parties?
    • Is there a strong business case supporting the use of the funds?
    • Do recent audits or reviews raise any issues?
    • What is the potential impact of economic fluctuations (inflation, change in commodity prices, interest rates, exchange rates, etc.) on the cost estimate?
    • Are adequate financial management systems in place?
    • What is the quality of the data underpinning the cost estimate (sources, applicability and reliability)?
    • Has a sensitivity analysis been conducted to test the sensitivity of cost elements to changes in key assumptions?
    • Does the risk analysis identify and quantify the effects of changes in key cost driver assumptions?
    • Has a schedule risk analysis been conducted and has it been quantified as to the potential cost impact?
  6. How will your organization respond to and monitor risks?
    • Has your organization determined its risk tolerance? Do principles and practices exist to help facilitate smart risk taking through experimentation? If so, what processes exist to learn from failures and disseminate lessons learned from experimentation?
    • Has a risk management plan been completed to identify and analyze risks, plan for risk mitigation and track risks? If not, has a monitoring, reporting and control process been documented in another way?
    • Has an environmental scan been completed?
    • How will these risks be monitored over the life of the project? For example, will a Residual Risk Assessment be completed?
    • Who is involved in responding to risks?
    • Have accountabilities been assigned for the management of risks and the implementation of risk responses? How are shared risks to be handled?
    • Has a senior management governance body been assigned to provide oversight over risks and risk responses?
    • What level of priority has your organization given the project?
    • Are relevant stakeholders and your organization’s management aware of the project? If yes, to what degree?
    • Have the business and project requirements been validated with users?
    • Have feasibility studies been conducted and documented? Is there confidence in the assumptions made in the feasibility studies?
    • Have risk response costs been considered in the feasibility study?

Cost, Funding Requirements and Source of Funds

  1. Has your organization considered every aspect of each proposal’s cost, funding requirements and source of funds?
    • What is the source of funds for the proposal?
    • If the proposal builds on an existing program, what is the current level of funding for that program?
    • How would new funding be allocated between operating, capital or transfer payments, and for what purpose?
    • Have cost estimates considered the cost of performance measurement (such as planned evaluations or studies) or the cost of experimenting with new approaches (pilots)?
    • Is there a risk of costs exceeding estimates that could lead to unfunded costs and program integrity concerns in the future?
    • If external cost recovery is to fund the proposal, have legal professionals been consulted on the User Fees Act?
    • Is temporary access needed to Treasury Board Vote 5 – Government Contingencies? If yes, why?
  2. How will your organization coordinate or manage regional or horizontal involvement?
    • If the proposal involves other federal organizations or collaborators outside the federal government, how will activities and outcomes be managed and coordinated? Is a Memorandum of Understanding among federal organizations required? Is a contract among collaborators required?
    • What roles do the collaborators play in delivering key results? Who is accountable for what?
    • Does the proposal have federal-provincial implications? If so, how are they managed?
    • Does the program design incorporate adequate resources to manage and support collaboration with the other parties?
    • Does the proposal have regional implications? How is funding distributed across regions?
    • Are there horizontal linkages that should be brought to ministers’ attention?

Costing Due Diligence and Validation

  1. How are costs contained?
    • Are the requested financial resources adequate to deliver the program?
    • Is there sufficient rationale for ongoing resources?
    • Is the level of operating funding to deliver this program reasonable? What efforts has your organization made to minimize operating costs?
    • Has your organization explored the potential to minimize costs by taking advantage of opportunities to achieve internal synergies (e.g., using existing resources to administer a new transfer payment program rather than hiring new resources to do it)?
    • Has your organization explored its potential to minimize costs by leveraging efforts of other federal and non-federal partners?
    • Is financial information provided to the dollar?
    • Have accommodation costs been identified accurately?
    • Have corporate administration costs been adequately justified?
    • Has GST/HST been identified for projects?
    • Are there other costs that must be considered (e.g., foregone revenues), or are there revenues that will fully or partially offset the costs?
    • Are the proposals likely to generate significant ongoing cost pressures?
    • Does the costing include amounts for contingencies? What are the assumptions around contingencies, and how were these amounts calculated?
    • How sensitive are these costs to economic fluctuations (e.g., currency risk)?
    • How does this proposal align with your organization’s corporate costing model? Do all implicated government organizations use consistent costing assumptions and formulae?
    • Has the costing been validated through market consultations and/or a competitive procurement?
    • Have other governments or third parties taken on similar initiatives? How does the costing compare to what other parties have paid for similar initiatives?
    • Is this proposal related to previous Deficit Reduction Action Plan and Strategic Review decisions? Does it recreate previously cut or reduced programs?
    • What efforts were made to keep costs down?
    • Is it affordable in the current fiscal context?
    • Will new temporary or permanent FTEs be created?
    • Is your organization absorbing costs and reallocating existing funding? From where are funds reallocated? What are the program, organizational or portfolio impacts?
    • Will the initiative create efficiencies that lead to cost savings (e.g., harvestable savings, cost avoidance)?
    • Are there program integrity impacts or cost implications for other government organizations?
  2. Has your organization demonstrated due diligence?
    • Is the methodology that was used to prepare the cost estimates in line with the Guide to Costing? If not, what is the rationale for not doing so?
    • Has the Chief Financial Officer or Deputy Chief Financial Officer reviewed and approved the cost estimates?
    • Are there comparable national or international initiatives?
    • Has the costing analysis factored in all costs, such as the following?
      • Program costs;
      • Internal services costs;
      • Employee benefit plans;
      • Accommodation premium for space from Public Works and Government Services Canada, or the costs of space owned by the sponsoring organization;
      • Reasonable life-cycle costs, such as maintenance and replacement;
      • Future audits or evaluations; and
      • Performance measurement strategy implementation;
    • Does the cost estimate include a contingency to mitigate risks of unforeseen costs?
    • Does the cost estimate include any investment required to mitigate security risks associated with the program or project? If yes, have they been adequately costed?
    • Does the program or project require any investment to support replacement of aging IT infrastructure, systems or applications? Are there any rust-out issues? If yes, have they been adequately costed or addressed?
    • Have other federal organizations that will be impacted by the proposal been adequately consulted? If there are downstream costs, are implicated organizations aware of this?
    • Have you demonstrated why projected costs are reasonable?
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