Audit of the Cairo Immigration Program

Final Report
Internal Audit and Disclosures Branch
Citizenship and Immigration Canada
February 2005

Table of Contents

• 1.0 Background
• 2.0 Audit Findings and Recommendations
  • 2.1 Management Function
    • 2.1.1 Performance Information
  • 2.2 CAIPS Management
  • 2.3 Program Integrity and Compliance
    • 2.3.1 Admissibility Framework
  • 2.4 Cost Recovery
    • 2.4.1 Monitoring
  • 2.5 Control Documents
  • 2.6 Human Resources Management
  • 2.7 Risk Management and Quality Assurance
• 3.0 Conclusion
• Appendix A: Management Action Plan

1.0 Background

We carried out the audit of the Immigration Program at the Cairo Mission between March 15 and March 25, 2004. The audit was conducted in accordance with the generally accepted auditing standards set out by the Treasury Board Secretariat and the Institute of Internal Auditors.

The objectives of the audit were to assess the effectiveness of the management control framework and the Mission’s degree of compliance with legislation, and policies and procedures that are associated with the delivery of the Immigration Program.

The audit scope included the management of the Mission’s Immigration functions, performance information, management of the Computer-Assisted Immigration Processing System (CAIPS), program integrity and compliance, the admissibility framework, cost recovery, control documents, human resources management, and risk management and quality assurance.

In carrying out the audit, we reviewed files and documentation and interviewed the Canada-based officers and locally engaged program officers and staff members. To further our knowledge, we attended staff meetings, observed operational activities, and met with the Ambassador, Management and Consular Officer (MCO), and other staff members having links to Immigration operations.

The Cairo Mission is a full-service centre offering all immigrant and non-immigrant services and is responsible for processing all applications from Egypt and the Sudan. There are two Canada-based officers; the Immigration Program Manager (IPM); a Migration Integrity Officer; two locally engaged program officers at the Designated Immigration Officer level; and ten locally engaged staff members. Temporary duty officers and emergency employees are periodically engaged.

The economic conditions prevailing in Egypt and the Middle East have generated continuing interest in immigration to Canada, and because many Egyptians have friends and family in Canada, visitor traffic is on the rise. The Mission has processed an increasing number of refugees over the past few years. Most are Southern Sudanese refugees who have sought asylum in Egypt, and others—mostly Ethiopians and Eritreans—are located in the Sudan. This has resulted in a more complex caseload and increased concerns about the reliability of client information.

In 2003, the Cairo Mission received 1,584 applications for permanent residence. Of these, 38 percent were skilled workers and other Economic Class applicants, 36 percent were refugees, and 26 percent were Family Class applicants. In 2003, the Cairo Mission also received 5,233 applications for temporary resident visas, 262 for student permits and 84 for work permits. Cost recovery revenues in Cairo during the 2003 calendar year totaled $1.52 million.

2.0 Audit Findings and Recommendations

2.1 Management Function

We found the Immigration Program at the Cairo Mission to be well-managed by an experienced Immigration Program Manager (IPM) who had attended a formal IPM training workshop in Ottawa in December 2003. Since her arrival at the Cairo Mission in 2003, she has initiated a number of measures to strengthen program management and controls. Challenges of the operating environment included office layout, staffing issues, work distribution within the office, and risk management and quality assurance.

Cairo’s work plans and objectives reflect the International Region’s planning priorities and the Department’s strategic objectives. The Mission achieved and even exceeded its 2003 immigrant visa target despite staffing constraints, by relying heavily on temporary Canada-based and locally engaged staff members. This was particularly evident for the refugee program. In 2003–2004, the International Region supplied a temporary duty officer for 21 weeks and funded emergency support staff for 56 weeks. Area trips to Khartoum, Sudan for refugee interviews were also delegated to a temporary duty officer. The Mission’s ability to continue to meet the work-plan objectives depends largely on their resources. The International Region is aware of the Mission’s concerns. The IPM referred to the challenges of the operating environment in the annual International Region Immigration Management Plan (IRIMP).

Communications with staff on operational matters were open, regular and effective. Mechanisms were in place to review internal procedures and communicate changes to Immigration staff and other embassy programs. Working relationships were cordial and constructive with other embassy programs, outside stakeholders, and the Citizenship and Immigration Canada (CIC) International Region Geographic Desk.

We have concluded that the Cairo Mission is competently managed and that the IPM, with the support of the International Region, has the needed capability to address the office’s challenges and objectives. We have no recommendation with respect to the management function.

2.1.1 Performance Information

The Mission monitored its immigrant visa targets throughout 2003 and adjusted them upward in consultation with the International Region. The targets were met in all immigrant classes and were exceeded by 18 percent overall.

The Mission had processing standards for each stage of immigrant processing. Cairo’s processing times, except for those concerning refugees, were generally under the regional and world averages. Visitor processing times were also under average, while students and workers had processing times beyond the average overall.

We concluded that the Mission’s data reporting capacity met its current needs and that the IPM used an appropriate range of information to manage and monitor Mission operations. The IPM undertook to further strengthen the program monitoring function at the Mission level. Some advice was provided in this area during the audit.

2.2 CAIPS Management

The audit reviewed the Computer-Assisted Immigration Processing System’s (CAIPS) user accounts over calendar year 2003. We found that the CAIPS Manager and backup had a good knowledge of their CAIPS responsibilities and exercised close control (with the exception of visitor visas). All immigrant, student and temporary-worker decisions made in 2003 complied with delegated authorities.

We also noted some best practices in place using CAIPS features for allocating work and managing the workflow. The file-management system ran smoothly. Cross-referencing was used extensively to track repeat applications and an effective system was in place to track special client groups such as refugee claimants. CAIPS support functions such as equipment inventory and maintenance were capably managed by competent staff. We concluded that CAIPS-related work tools were well-integrated integrated in day-to-day operations.

Some suggestions were made to strengthen CAIPS controls at the Mission level. In particular, we observed excessive delegation of officer-level work in the non-immigrant program. We found that 22 percent of temporary resident applications processed in 2003 had been finalized by unauthorized staff and our review of twelve visitor files included four such cases. We noted that compensating controls were present. The work was only delegated to the most senior support staff, predominantly in the May-August high season period, took place under strict rules, and under the supervision of the locally engaged program officers. Finally, the high quality of the related file notes was another mitigating factor.

We were concerned about this practice of allowing unauthorized staff to finalize applications because the staff involved did not have the legal authority to make the decisions and had not received any certification or training from the International Region. We were also concerned about the extent of this practice that not only involved 1,160 visitor applications in 2003, but had taken place over previous years. We observed that the IPM and one of the locally engaged officers were located on another floor away from the visitor processing staff they were supervising. We also noted that Canada-based officers only made two percent of all visitor decisions in 2003. This suggests that the Canada-based officers had a low involvement in the non-immigrant program as a whole.

The IPM informed us that the processing of visitor visa applications by non-authorized staff stemmed from a lack of resources in peak periods. She communicated proposals to strengthen the visitor program with the International Region through the annual Immigrant Management Plan process. From our analysis, we agreed with the IPM’s conclusion that for current output to be maintained, the program may need additional resources. The IPM reported that in Summer 2004, Canada-based and locally engaged officers became more involved in the non-immigrant program, and that her request for a third Canada-based officer had been granted.

2.3 Program Integrity and Compliance

The audit found that the IPM accords a high priority to program integrity and wishes to dedicate more resources to this area. Among her priorities, she plans to strengthen the program integrity of the non-immigrant program and of the refugee program. In addition, she believes that clear and close supervision of staff is needed to better ensure program integrity.

Overall, our examination of program integrity found it was very good. We observed that the staff were dedicated to the program and had a strong command of policy and procedures. Staff expressed concern that workload had increased since three Canada-based officer positions were eliminated in the mid-nineties. Two competent Designated Immigration Officers provided continuity and depth of experience to local operations. The locally engaged staff relied heavily on these officers for guidance, training and supervision. The potential retirement of the senior Designated Immigration Officer in two years was a concern. Registry and reception staff were diligent and flexible, and worked closely with the non-immigrant program, often sharing staff during peak periods.

We examined a sample of twenty immigrant and twenty non-immigrant cases finalized in calendar year 2003. Our file review indicated that immigrant and non-immigrant cases were processed efficiently. Internal procedures were uniformly applied and an appropriate range of form letters and checklists were available for case processing. We found that the selection criteria were applied consistently and that case decisions were well-documented. The case notes we reviewed were generally clear, orderly and concise with well-noted processing steps and supporting documentation.

The IPM expressed concerns about office layout and shared them with the International Region through the IRIMP. These concerns related to the small public waiting room, the lack of privacy of interview booths, and the challenge to efficient workflow and adequate supervision caused by the section being housed on two floors without an internal staircase to link them.

The IPM pointed out that the Immigration registry was not physically isolated from a hallway being used by other embassy staff, and occasionally, by escorted visitors during business hours. Immigration files contain designated information categorized as particularly sensitive or protected B. Under the Government Security Policy, the minimum secure area for sensitive information is an area where access is limited to personnel who work there and to properly escorted visitors. Likewise, the TBS Physical Security Standard states that circulation routes commonly used by personnel and authorized visitors should also be designed to reduce the opportunity for unauthorized access to sensitive information and assets.

2.3.1 Admissibility Framework

The IPM was supported in admissibility screening by a competent, second Canada-based officer and by experienced and qualified staff. The second officer, who was also a Migration Integrity Officer, made the bulk of the Mission’s security and criminality decisions in 2003. We found diligent controls in place and a high compliance level with delegated authorities for security and criminality screening. The management of temporary resident permits was also in conformity with delegated authorities. The office also benefited from an established network of strategic partners to assist in admissibility determination.

Our file review indicated that security and criminality screening were integrated into routine processing and were systematic and thorough, both in the immigrant and non-immigrant cases reviewed. We also found strong routine procedures in place for medical screening.

2.4 Cost Recovery

Our audit showed that, in general, the Cost Recovery function at the Cairo Mission is functioning well. However, we did suggest some measures, which could be dealt with at the Mission level, that could improve controls and reduce risk. The majority of these suggested measures were implemented while we were on-site.

In the Cairo Mission, immigrant visa service refunds are done through the Administration section in accordance with suggested practices. The procedures in place for such refunds appear to provide effective controls. Likewise, the majority of the procedures for visitor visa service refunds ensure that there are equivalent controls. However, we observed that visitor visa service refunds are processed the same day and are provided in cash without any written acknowledgement from the applicant to document receipt of these funds. We are concerned that this practice has the potential to allow an applicant to receive more than one refund. We informed the Cost Recovery Officer (CRO) of this weakness and advised that in the future, applicants should sign a receipt to acknowledge they have obtained a refund.

2.4.1 Monitoring

Our audit of the cost recovery function focused on two aspects of monitoring. The first was ensuring that funds collected were transferred to Mission Administration and were ultimately deposited in the bank. Currently, the Cairo Mission does this by reconciling the Integrated Management System report produced by Foreign Affairs Canada to the daily Immigration revenue summary reports. This task is shared by the IPM and, for Foreign Affairs Canada, the Management and Consular Officer (MCO). Reconciliation of the Integrated Management System reports to the bank statement is undertaken by the MCO. These two reconciliations together provide assurance that funds collected made it to their intended destination. We found that while the results of the bank reconciliation conducted by the MCO were routinely shared with the IPM, the bank statements/deposit slips were not. We discussed this weakness in the control framework with the MCO, who expressed a willingness to provide the IPM with this additional documentation. Subsequent to the audit field work, the IPM reported that the MCO has instructed the Mission Accounts section to provide a copy of the official bank account statements and copies of deposit slips to the IPM as requested.

The second aspect of monitoring was ensuring that the funds collected by the Cost Recovery Clerk were what should have been collected. We found that this area was functioning adequately. However, some areas for improvement were identified which could help strengthen the monitoring process. These were communicated to the IPM.

2.5 Control Documents

Establishing strong management controls over Control Documents such as visitors’ visas and Immigration seals is essential at the Mission level. We found that the Mission was managing this function effectively. We suggested some measures that will strengthen controls, improve efficiency, and reduce risk, and which could be dealt with at the Mission level. Most of these suggestions were implemented prior to the completion of the audit.

2.6 Human Resources Management

We reviewed human resources management practices relating to training and development, annual performance appraisals, and security requirements and conflict of interest guidelines for locally engaged staff.

Generally, training needs were identified as part of the performance appraisal process. Training for Immigration Program staff is included in the overall Mission training plan. We found that staff currently relied largely on the two Designated Immigration Officers for on-the-job training, operational guidance, and supervision. The IPM and the second Canada-based officer provided additional direction. Staff benefited from training and learning opportunities, such as on IRPA.

For the most part, locally engaged staff appraisals were up-to-date although a few were outstanding at the time of our audit. The Mission Security Officer performs the locally engaged staff security screening and confirmed that Immigration staff clearances were recently updated. Upon hiring, locally engaged staff members are provided with a handbook that outlines (among other things) standards of conduct, acceptance of gifts and conflict of interest guidelines. The IPM shared an updated handout on this topic with her staff and plans to hold an information session.

We also noted that the Immigration Program has only two Canada-based officers. This means that each Canada-based officer is the other’s backup in such important functions as CAIPS management, cost recovery and control documents. When both are absent from the Mission, this reduces the decision-making capacity and efficiency of the office. The IPM requested an additional Canada-based officer in the 2003–04 IRIMP. We learned from the IPM that the request had been granted and that an additional officer arrived in Cairo in August 2004.

2.7 Risk Management and Quality Assurance

The IPM expected that a large part of her time in 2004–2005 would be spent on reviewing lines of responsibility and accountability and rebalancing staff workloads. One of her major work-plan objectives was to review procedures and utilize staff in all areas so as to identify vulnerabilities in the program. To meet this objective, the IPM was planning to conduct two quality assurance projects on file samples and to set up further checks on two programs.

The Cairo Mission has an active risk management program in place to address concerns about reliability of client information and when the information is not validated the applications are rejected. Mission experience indicates that the program is effective. The Mission currently identifies three percent of all documents presented in support of visitor applications as suspect and in need of verification before making a decision. Of these, one-third of the targeted documents are found to be false. With improved training the Mission expects to increase its detection rate of false documents.

The Mission also routinely verifies immigrant documents for about seventy percent of interview-waived cases and for all offshore cases. Selection interviews are held for quality assurance purposes for all refugee clients, and selectively, for other immigrant clients.

The file review confirmed that quality assurance was a high priority and that related procedures were being applied consistently. All of the eight, skilled-worker files in our sample had verifications of education, work experience or financial documents, as shown by the case notes or a checklist. However, in five of the cases, we did not locate the supporting documents inside the paper file because they had been discarded pursuant to the pre-IRPA document retention guidelines used at the Mission. All refugee clients in the sample had had selection interviews, as did four of thirteen other immigrant clients.

The IPM plans to refine the current verification system of client information in collaboration with the Migration Integrity Officer and by drawing on an inventory of local partners and contact points. She also plans to increase reporting and liaison on non-immigrant issues.

3.0 Conclusion

We concluded that the IPM is taking appropriate steps to strengthen the effectiveness of the Immigration Program management control framework at the Cairo Mission. Risk management practices were prevalent in the Mission’s operations. We also found that an effective control framework was in place for the safeguarding of key documents as well as for cost recovery revenue overall. Immigrant and non-immigrant programs were in compliance with applicable legislation, and policies and procedures. Finally, we are satisfied that the Management Action Plan fairly addresses the issues raised in this report.

Appendix A: Management Action Plan