Audit of Inland Offices - CIC Calgary
Audit Report
Internal Audit and Accountability Branch
Citizenship and Immigration Canada
November 2008
Table of Contents
- List of acronyms
- 1.0 Introduction
- 2.0 Audit Conclusions
- 3.0 Observations and Recommendations
- Appendix A: Detailed Audit Criteria
- Appendix B: Management Action Plan
- Appendix C: Audit Time Lines
List of acronyms
- APR
- Application for Permanent Residence
- CAS
- Chief of administration services
- CBSA
- Canadian Border Services Agency
- CPC
- Case processing centre
- CPIC
- Canadian Police Information Centre
- CIC
- Citizenship and Immigration Canada
- FCO
- Forms Control Officer
- FOSS
- Field Operations Support System
- H&C
- Humanitarian and compassionate
- IM/IT
- Information management/Information technology
- IRB
- Immigration and Refugee Board
- IRPA
- Immigration and Refugee Protection Act
- NHQ
- National headquarters
- OMC
- Operational Management and Coordination
- PR
- Permanent resident
- PRRA
- Pre-removal risk assessment
- QA
- Quality Assurance
- RHQ
- Regional headquarters
- TR
- Temporary Resident
- TPRD
- Temporary Resident Program Delivery Division
1.0 Introduction
1.1 General
The Citizenship and Immigration Canada (CIC) Internal Audit and Accountability Branch’s Risk-Based Audit Plan for 2007–2010 identifies the requirement to conduct audits of inland offices. CIC Calgary was selected as a result of a series of consultations with regional directors general and a risk assessment of each inland office. The on-site field work was conducted from January 28 to February 1, 2008.
1.2 Background
1.2.1 Organizational Structure
CIC programs are delivered inland by over 40 offices in five regions: Atlantic, Quebec, Ontario, Prairies/Northern Territories, and British Columbia/Yukon. The regions are managed by a regional director general who reports to the Assistant Deputy Minister of Operations at national headquarters (NHQ).
CIC Calgary employs a staff of 48. The office was managed by the Director of Operations and, at the time of our audit, was organized into five units. The supervisor or coordinator for each unit reported directly to the Director of Operations, as shown in Figure 1.
Figure 1: CIC Calgary Organizational Structure (effective January 15, 2008)
Text version: Organizational Chart
There are five operational business lines at inland CICs: the citizenship program, the immigration program, the temporary resident program, the refugee program and the settlement program. CIC Calgary manages all five business lines.
1.2.2 Citizenship Program
Applications for the granting and proof of citizenship are two major lines of business of the citizenship program. Other application types include applications to register and retain citizenship, and applications to renounce or resume citizenship.
Applications for Canadian citizenship are sent to the case processing centre (CPC) in Sydney, Nova Scotia. CPC‑Sydney ensures that all required documentation and fees are submitted with the application. Once the application is processed, it is forwarded to the CIC local office closest to where the applicant lives. In general, the CIC local office administers official languages and Canadian knowledge tests. When necessary, local offices will investigate concerns raised by the CPC regarding an applicant’s residency, criminality or security. The final stage in granting citizenship takes place at a citizenship ceremony where the applicant takes the oath of Canadian citizenship and receives the Certificate of Canadian Citizenship.
1.2.3 Immigration Program
Permanent Residents
In general, foreign nationals apply to come to Canada as permanent residents at Canadian missions abroad. However, the Immigration and Refugee Protection Act (IRPA) lists four specific classes (Live-in Caregiver, Permit Holders, Protected Persons and Spouse/Common-Law Partners) under which a person may apply for permanent residence (PR) from within Canada.
Any foreign national in Canada who does not meet the eligibility criteria for any of the four PR classes, or who is inadmissible, may request an exemption from any legislative or regulatory requirement on humanitarian and compassionate (H&C) grounds or for public policy considerations.
Applications for permanent residence (APR) in Canada are submitted through the CPC in Vegreville. When CPC‑Vegreville cannot process or conclude on a case, it is referred to a CIC local office for processing based on specific referral criteria. In most cases, all fees are paid by applicants when they send their applications to the CPC, but local offices accept payment in the form of cash, credit card or money orders.
The Admissions Unit at CIC Calgary processes APRs and conducts the assessment of admissibility (security, criminality, health) before granting permanent residence and landing individuals. The Pre-Removal Risk Assessment (PRRA) Unit reviews applications on H&C grounds where risks are identified as part of the H&C factors.
Business Immigration – Entrepreneur Program
There are three separate programs within business immigration: self-employed, investor and entrepreneur. The entrepreneur program is the only program of the three with implications for local inland offices. The selection of entrepreneurs is done overseas while the monitoring of conditions imposed on them is done by inland offices. Entrepreneurs are granted permanent residence but must meet the conditions for a period of at least one year. Once entrepreneurs have satisfied the conditions, they are required to apply to have the conditions cancelled.
Currently, both pre- and post-IRPA cases are being monitored inland. Pre-IRPA cases have two years to meet the terms and conditions whereas post-IRPA cases have three years to do so.
The Admissions Unit at CIC Calgary monitors permanent residents in the entrepreneur program to ensure that imposed conditions are met.
Permanent Resident Cards
The PR card came into existence with the coming into force of IRPA on June 28, 2002. It is the official document that indicates the holder’s permanent resident status in Canada and it is required for return travel to Canada on a commercial carrier. PR cards are generally valid for five years. For new permanent residents, the PR card process is automatically initiated after examination at a port of entry or an inland CIC office. A completed PR card is then mailed to each new permanent resident.
Permanent residents who received permanent resident status before June 28, 2002 (before IRPA) and all permanent residents who would like to replace an expired, a lost or a stolen PR card may submit an application for a PR card to CPC‑Sydney. The final stage of processing involves the local CIC office. When clients arrive to collect their card, a CIC officer verifies their identity, confirms that the biodata on the PR card are correct and conducts final database checks.
In a number of situations, CPC‑Sydney also refers applications to inland CIC offices for further investigation when there are concerns with respect to the applicant’s identity or information provided by the client.
The Admissions Unit at CIC Calgary is responsible for carrying out these functions.
1.2.4 Temporary Resident Program
Temporary residents (TR) include workers, students, visitors and temporary resident permit holders. People may apply to extend or change their status as a TR in Canada beyond the initial period of stay that was granted.
Applications for TR extensions are processed by CPC‑Vegreville and only cases requiring further clarification are referred to local offices.
At CIC Calgary, the Admissions Unit is responsible for processing temporary residence applications referred by CPC‑Vegreville.
1.2.5 Refugee Program
Applicants Seeking Refugee Protection
A claim for refugee protection can be made at any port of entry or at any CIC office in Canada. The role of the CIC officer is to determine whether or not a person is eligible to have a claim assessed by the Immigration and Refugee Board (IRB). Since the final determination for the applicant is made by the IRB and not CIC, this type of processing has also been called “refugee intake,” a type of pre-screening of claimants for the IRB.
CIC officers refer eligible claimants to the IRB for final determination and ineligible claimants to the Canada Border Services Agency (CBSA) for removal from Canada. A person who has been determined by the IRB to be a Convention refugee or a person in need of protection returns to CIC for processing toward permanent residency.
The Admissions Unit at CIC Calgary is responsible for processing applications for refugee protection.
Pre-Removal Risk Assessment
The PRRA process is triggered by a removal order issued by the CBSA. A CBSA officer sends to the individual facing a removal order a Notification Regarding Pre-Removal Risk Assessment with the accompanying application and the address of the CIC office where the individual should send the application. There are no fees associated with a PRRA application.
The PRRA is used to evaluate the risk individuals face upon returning to their country. Individuals awaiting removal from Canada who allege risk of persecution, torture, or cruel and unusual treatment or punishment if returned to their country of nationality or former residence will not be removed prior to a risk assessment.
PRRA decision makers are responsible for assessing the risk applicants would face upon return to their country of origin. If the PRRA officer determines that there are no risks for the individual to return to their country, the person will be removed. Under a positive determination, PRRA offers the same protection as the IRB process.
The PRRA Unit is responsible for processing PRRA applications at CIC Calgary.
1.2.6 Settlement Program
The Settlement Program consists of three main programs: Language Instruction for Newcomers to Canada, the Immigrant Settlement and Adaptation Program, and Host. These programs are delivered through contribution agreements with service providers. Contribution agreements with service provider organizations are generally managed by the local CICs.
1.2.7 Operating Budget
The operating budget and annual processing volumes for the office over the past three years are presented in Table 1.
| 2005 | 2006 | 2007 | ||
|---|---|---|---|---|
| Budget1 | Salaries | $1,791,249 | $1,816,735 | $2,008,958 |
| Operations and Maintenance | $127,550 | $150,572 | $193,129 | |
| Total | $1,918,979 | $1,967,307 | $2,202,087 | |
| Processing Statistics2 | Citizenship Grants | 7,932 | 8,224 | 12,524 |
| Applications for Landing | 301 | 303 | 230 | |
| PR Cards Issued | 4,012 | 2,137 | 2,836 | |
| Temporary Resident Decisions (Output) | 606 | 677 | 592 | |
| Entrepreneur Monitoring Concluded Cases | 183 | 76 | 26 | |
| Refugee Claims | 161 | 225 | 276 | |
| PRRA Decisions | N/A | 100 | 146 |
1. By fiscal year (2005–2006; 2006–2007; 2007–2008).
2. By calendar year.
Source: Operational Management and Coordination (OMC), Statistics and Immigration Branch.
1.2.8 Environmental Context
This section of the report highlights some of the operating environment issues facing CIC Calgary. These are presented here for information purposes only and do not reflect any particular order.
CIC Calgary’s jurisdiction is southern Alberta, including the cities of Calgary, Lethbridge, Red Deer and Medicine Hat. Of all immigrants destined for the province of Alberta, 65% are destined to southern Alberta.
The office provides the following business lines: immigration processing, citizenship processing, settlement, pre-removal risk assessment, and the Temporary Foreign Worker Unit. A satellite office in Lethbridge delivers services in Admissions and Settlement. CIC Calgary operates with an extremely heavy workload, in one of Canada’s fastest growing metropolitan areas, which is both fast-paced and subject to many conflicting demands and priorities.
In the last couple of years, the office experienced a very high turnover rate of approximately 25% a year. As a result of retirements and promotions, the current members of the local management team (except for the Area Director) have less than two years of experience in their substantive positions. The officers in the Admissions Unit have less than three years of experience on average. The PRRA coordinator position became vacant in November 2007 because of a promotion but was filled an on acting basis until it was filled permanently in June 2008.
CIC Calgary is housed with the CBSA in a federal building which also houses several government departments, including the Canada Revenue Agency, Service Canada and the Passport Office. In June 2007, the CIC offices were flooded by heavy rain and the building was closed for eight business days. As a result, many business lines, including front counter, citizenship testing and ceremonies, operated out of temporary facilities. In addition, the Administration Unit experienced another flood in February 2008 and it had to work out of temporary quarters for three months. The office is still recovering from these events and trying to resume regular operations.
1.3 Audit Objectives
The objectives of the audit are as follows:
- To assess the adequacy of the governance processes;
- To assess the effectiveness of the organization’s risk management system; and
- To assess the adequacy and effectiveness of the controls over financial, administrative and operational activities.
1.4 Audit Criteria
The criteria used in the audit are based on the applicable Treasury Board and CIC legislation, policies and directives. The detailed criteria for the audit are presented in Appendix A.
1.5 Audit Scope
The audit examined the overall activities of CIC Calgary from April 1 to December 31, 2007, except for the entrepreneur monitoring files, which continue to be monitored. The activities in satellite offices were not included. Individual immigration application file review samples were drawn from cases finalized over the last three months of 2007. Sample sizes were judgementally determined based on an assessment of risk in relation to program materiality for the office, although individual cases were randomly selected. The scope of the audit includes three lines of enquiry: governance, risk management and controls. This section describes the areas to be addressed in each line of enquiry.
1.5.1 Governance
The governance processes to be assessed at CIC Calgary include the seven elements of the Management Accountability Framework as listed in Appendix A.
1.5.2 Risk Management
The risk management line of enquiry involves an examination of the adequacy of the risk management system in place in the local office as listed in Appendix A.
1.5.3 Controls
The adequacy of internal controls will be assessed at CIC Calgary in the following areas:
- Financial management, which includes cost recovery, travel and hospitality;
- Administrative management, which includes controlled documents; and
- Operational activities, including integrity of the immigrant program, the temporary resident program and the refugee program.
The citizenship program was not included in the scope of this audit because of the quality assurance (QA) program currently in place which lowers the risk of legislative non-compliance, and improves the quality of reporting on program integrity.
The settlement program is not included in the scope of audits of inland offices because comprehensive settlement program audits have been and will continue to be conducted separately.
The distribution of PR cards is not included in the scope of audits of inland offices as the volume of pre-IRPA PR cards continues to decline, thereby decreasing the risk associated with the local office’s distribution of the cards. Our assessment indicated that the risk was low.
Landings, which involve the provision of the PR card to the permanent resident applicant after reviewing the Field Operations Support System (FOSS) and determining the identity of the applicant, have also been scoped out of the audit. This is a low-risk administrative function. Audits of the integrity of the immigration program examine applications for permanent residence (APRs) to ensure that the decision is compliant at an earlier stage in the process where the risk is higher.
An in-depth audit of information management and information technology (IM/IT) issues will not be conducted as auditing IM and IT controls requires specific auditing techniques and can be better achieved through horizontal audits of IM/IT activities.
Lastly, the area of security, which includes occupational health and safety, has been scoped out of the audit. A departmental audit of security is planned for 2008–2009 to address the area more broadly than the scope of this audit. In addition, a threat-and-risk assessment was conducted by NHQ in March 2007.
1.6 Audit Methodology
Three lines of enquiry were examined for this audit: governance, risk management and controls.
The observations and conclusions of the report are based on an analysis of the following sources of evidence:
- Selection and review of five to 28 case files for each business line. Judgmental sampling was used by the audit team to select case files. Observations resulting from the case file reviews relate only to the files reviewed by the audit team;
- Review of documents and standard operating procedures;
- Examination and testing of internal controls in the areas of finance and administration to ensure that the controls function as intended;
- Observation of operational activities; and
- Interviewing of management and staff.
The criteria used in the audit are based on the applicable CIC and Treasury Board legislation, policies and directives. The detailed criteria for the audit are presented in Appendix A.
The audit was conducted to be in accordance with the Government of Canada’s Policy on Internal Audit as well as the professional practice standards of the Institute of Internal Auditors.
2.0 Audit Conclusions
Overall, the audit found the following:
- While the governance processes in place were ad hoc, they were sufficient to ensure that the local office’s objectives were being met.
- There is evidence that CIC Calgary manages risk effectively. However, there is no formal, documented process in place.
- In assessing the adequacy and effectiveness of the controls over financial, administrative and operational activities, the audit found weaknesses in the area of cost recovery, controlled documents, the immigration program, the temporary resident program and the refugee program.
The detailed observations and recommendations are discussed in the next section of the report. A total of 11 recommendations were made as part of the audit report. Management’s response and action plan along with the proposed implementation dates for the recommendations can be found in Appendix B.
3.0 Observations and Recommendations
3.1 Governance
3.1.1 Governance and Strategic Direction
The audit assessed the collection of management processes and controls in place to set CIC Calgary’s strategic direction. We expected to find that:
- operational plans were in place to achieve the local office’s objectives; and
- communication protocols existed for internal and external stakeholders.
The audit found that a formal operational plan is not developed by CIC Calgary. However, it was noted in Regional Management Team meetings that CIC Calgary plans in accordance with the priorities established by the Prairies/Northern Territories Region. In addition, the Prairies/Northern Territories Region was in the process of developing a new integrated planning process for the Region which called on local offices to develop operational plans for the next fiscal year. While the audit did not review these, management indicated that their introduction would allow offices to establish performance expectations that would allow them to better measure performance. This is what we would expect from operational plans, and we are encouraged by the introduction of this process in the Region.
Internally, priorities are communicated through the establishment of performance agreements and various levels of management meetings. Externally, the Director participates in an immigration network comprised of clients, partners and other external stakeholders to ensure that accurate information regarding the immigration program is disseminated to the community through information sharing with the external stakeholders. In addition, the Director is a member of a working group focused on enhancing departmental partnerships.
3.1.2 Values and Ethics
The audit expected to find that:
- management promotes and reinforces values and ethics; and
- employees are aware of the Code of Conduct for Citizenship and Immigration Canada.
The Prairies/Northern Territories Region developed a binder on values and ethics that was distributed to all CIC Calgary staff in the fall of 2007. All new employees receive a copy. In addition, staff meetings address values and ethics as required. Ten employee files were reviewed to ensure that a signed CIC Code of Conduct was on file and all employees’ letters of offer indicated that the Code of Conduct was distributed with the letter. Seven of the 10 files reviewed included a signed copy of the Code of Conduct.
3.1.3 People
The audit assessed the controls in place to support the training and development of staff. It expected to find that:
- the human resources plan is aligned with operational requirements and considers the current and future needs of the organization;
- the organization provides employees with the necessary training, tools, resources and information to support the discharge of their responsibilities; and
- the organization has a system in place for the performance evaluation of employees.
While CIC Calgary does not have a formal human resources plan in place, there is evidence that the management team regularly considers the needs of the organization as staffing is a standing agenda item at weekly management meetings. In terms of training, 10 employee files were reviewed to ensure that a learning plan was on file, and this was the case in all but one file. In addition, the Prairies/Northern Territories Region requests that each local office compile the training needs of their staff. This information is then used by the Region to decide how to allocate funding. When staff were asked whether they had adequate tools, resources and information to support the discharge of their responsibilities, no concerns were identified in these areas. Finally, the audit examined the same 10 employee files to ensure that performance evaluations were on file, and this was the case in all 10 files.
3.1.4 Client-Focused Service
In order to ensure that citizen-focused service is delivered to Canadians, mechanisms should exist to establish and maintain service standards and to respond to client feedback. The audit expected to find that processes were in place to:
- establish, maintain and monitor service principles and standards for clients; and
- effectively track and resolve client complaints.
Service standards have not been set for local offices due to the fact that local offices process referral cases, which by nature are non-standard cases, and they generally require more time to complete for a variety of reasons. However, CIC Calgary responds to information requests from NHQ and regional headquarters (RHQ) regarding the status of their workload. In addition, CIC Calgary monitors the status of all types of files within the office to ensure that the information required to respond to requests from NHQ and RHQ is available. However, the information collected would also allow CIC Calgary to track service standards if it became a requirement. Generally, client complaints are received at RHQ and therefore, it is the Region that tracks this information. The director indicated that when the local office receives a complaint, he is responsible for managing the response.
3.1.5 Accountability
The audit examined the delegated authorities within CIC Calgary to ensure that staff were aware of and complied with their responsibilities. The audit expected to find that:
- processes existed to ensure that accountabilities and responsibilities were clearly delegated, communicated and adequately discharged; and
- a clear organizational structure was established and documented.
To ensure that staff were aware of their accountabilities and responsibilities, the audit undertook a review of employee files to see if they contained job descriptions and performance evaluations. It found that four of 10 files were missing job descriptions. However, as indicated above, all files examined contained performance evaluations. In addition, CIC Calgary had an up-to-date clearly defined organizational chart.
The audit used the files selected for the review of program integrity from each business line to ensure that they complied with delegated authorities. It found that the entrepreneurs, refugees and PRRA cases examined all complied with the delegated authorities. However, due to a lack of documentation, it was unclear who made the final decision in two APRs and five temporary resident extensions. Therefore, the audit was unable to determine whether the decisions were made by the person with the appropriate delegated authority.
Recommendation 1
All final decisions must be documented in order to demonstrate the exercise of the appropriate delegated authority.
Management Response
We accept this recommendation. Since the audit, the Admissions Unit staff have begun to indicate the final decisions of the officers on the Case Processing Support screens. Officers have also been instructed to clearly indicate the rationale for their decisions in their Notes to File, and to include either their initials or signature.
3.1.6 Learning, Innovation and Change Management
The audit examined the controls and practices in place to ensure effective learning on a continuous basis and to manage all types of significant change. Specifically, the audit expected to find that:
- the organization had in place a process to identify change opportunities and requirements; and
- the organization had processes and practices to ensure that change initiatives were properly implemented and well communicated.
While the process in place to identify change opportunities is ad hoc, it is nonetheless effective. As part of the planning process, discussions of risk identify areas where change is required. One example of a change opportunity that was identified as a result of these discussions involved a citizenship blitz that expedited citizenship processing to address the increasing citizenship inventory. Again, while the processes for change initiatives are also ad hoc, the initiative identified was well defined and well managed, and it achieved its goal.
3.1.7 Results and Performance
The audit focused on the controls in place to establish and review both financial and operational performance objectives, targets and indicators. The audit expected to find that:
- processes existed to ensure that the planned results and outcomes were linked to organizational objectives;
- management had identified appropriate performance measures linked to the planned results; and
- management monitored actual performance against the planned results and adjusted as required.
As CIC Calgary did not have a business plan at the time of our audit, we found that operational performance was measured primarily against priorities set by NHQ for processing applications. Processing targets are set at the regional level, and CIC Calgary tracks the information required in order to report on these targets. The citizenship blitz described above provides evidence that management monitors their performance and makes adjustments as required to ensure that they are fulfilling their objectives. Financial performance is set out in the form of the budget, which is monitored in compliance with departmental requirements as described above. We note, however, that with the change in the planning process in the region, this area has been strengthened.
3.2 Risk Management
The objective of this component of the audit was to assess the effectiveness of the organization’s risk management system. The audit expected to find that:
- processes were in place to identify, assess, mitigate and monitor risks;
- management appropriately communicated risk and risk management strategies to key stakeholders; and
- planning and resource allocation considered risk information.
As was the case in the area of governance, there is evidence that CIC Calgary manages risk effectively. However, there is no formal, documented process in place. Planning at the regional level – into which the local office has input – includes a risk analysis and identifies risks that are often specific to CIC Calgary. The example of the citizenship blitz described above in Section 3.1.6 clearly demonstrates that the management team was able to identify a risk to their program, communicate the risk to the key stakeholders, and put a process in place to mitigate that risk. As indicated above in the Governance and Strategic Direction section (3.1.1), the Prairies/Northern Territories Region intends to introduce integrated planning at the local office level for the next fiscal year. This in turn will introduce a more formal risk management process to the local office.
3.3 Controls
3.3.1 Financial Activities
The objective of this component of the audit was to assess the adequacy and effectiveness of the controls over financial activities, including budgeting, cost recovery, and travel and hospitality.
3.3.1.1 Budgeting
In the area of budgeting, the audit expected to find that financial resources would be budgeted, committed and spent to meet the priorities and objectives in the work plan, and that forecasts and variances are monitored on a regular basis.
The audit found that CIC Calgary planned and budgeted in accordance with the priorities established by the Prairies/Northern Territories Region. The audit also found that the budget variances from forecasts were monitored in accordance with NHQ requirements.
3.3.1.2 Cost Recovery
The audit expected to find that financial policies and practices for cost recovery complied with legislation, regulations, policies and authorities.
The audit found weaknesses in the compliance of financial policies and practices for cost recovery. It noted limited accountability for the funds collected:
- multiple cashiers shared one cash register drawer;
- the key to the cash register drawer was left in the drawer while the front counter was left unattended;
- access to the cashier’s room was not limited to employees who deal with public money; and
- during the end of day reconciliation, the supervisor did not verify the value of the funds collected to ensure that the proper amount was being reconciled.
These findings increase the risk that if funds were to go missing, there would not be an audit trail to determine the cause.
All cost-recovery transactions in CIC local offices are processed through the POS system. The POS access profiles are centrally managed by NHQ. When a new staff member requires access to the system, a request is sent to NHQ and once approved, access is granted to the employee. Prior to the on-site audit, it was noted that POS access profiles allowed cashiers access to void transactions without the supervisor’s confirmation. When on site, it was confirmed that cashiers were voiding their own transactions and at the end of the day, the supervisor would review the list of daily voids and confirm the justification although there was no written record available to track the voids or the justification. Between April and December 2007, CIC Calgary processed 14 voids, and all but two were processed by a cashier.
Recommendation 2
CIC Calgary must implement physical and procedural controls to ensure that funds are properly collected and accounted for.
Management Response
Over the past few years, the Calgary office has struggled with accommodation challenges due to increased growth. The lease on the facility expired in 2006 and has been repeatedly extended to March 2009 to allow for delays in the planning, design and move of the office to new space in the Harry Hays Building. The front counter is one area where design, layout, space and security challenges significantly affect operational requirements. The front counter area is small for the number of staff, handles large volumes and until quite recently, afforded no glass barrier between staff and the public. Needless to say, staff were uncomfortable collecting cash.
A financial assessment of the Region pointed to a requirement for additional cash drawers to be installed in Calgary and training provided to staff on the collection of cash. Staff were provided detailed instructions on the handling of public moneys by the chief of administrative services (CAS) immediately following the assessment.
In December 2007, after the front counter had moved back to its leased space (after the June flood), new cash drawers were installed. It was found that this installation significantly reduced the physical working space required to house supplies and tools necessary to perform the routine work, thereby compromising the intended objective.
While staff are aware of the requirements and operate with appropriate attention, a more streamlined process is required to address the current space issues. In response, since the audit, we have designated one cash collector position to maintain singular access to a cash drawer during the day. It is important to note that the requirement for individual cash drawers has already been incorporated into the planning and design of the new premises, scheduled for opening in November 2009.
On receipt of revenue collected at the front counter by the immigration counsellor assistant, the revenue collected is verified by the finance assistant in preparation for deposit and reconciled by the CAS.
Recommendation 3
NHQ Financial Policy and Systems should remove access to void transactions from all SAP cashier profiles and limit this access to the SAP supervisor profile.
Management Response
We agree with the recommendation. NHQ Financial Policy and Systems and NHQ Accounting Operations (business process owner) will review the business process and cashiers’ access.
The ability to void transaction access will be removed from SAP cashier profiles. Regular monitoring will ensure adequate control over voided transactions.
3.3.1.3 Travel and Hospitality
The audit expected to find that financial and administrative policies and practices for travel and hospitality complied with legislation, regulations, policies and authorities.
In order to determine compliance, we judgmentally selected nine out of 97 travel claims to be reviewed along with the two hospitality claims during the examined time period. All claims were reviewed to ensure that the charges were properly pre-approved, and that the expense claim was properly processed and contained the appropriate delegated authorities. One travel claim was missing the Section 33 signing authority and in one hospitality claim, the audit found that the initial estimate of the expense was understated, but the claim contained proper signing authorities. Overall, the audit found that the practices for processing travel and hospitality complied with legislation, regulations, policies and authorities.
3.3.2 Administrative Activities
The objective of this component of the audit was to assess the adequacy and effectiveness of the controls over controlled documents.
3.3.2.1 Controlled Documents
The audit expected to find that administrative policies and practices for controlled documents complied with legislation, regulations, policies and authorities.
The audit found the following weaknesses in the compliance of administrative policies and practices for controlled documents.
- Rather than having an experienced officer conduct the duties of the forms control officer (FCO) as required in departmental policy, the duties were split between the CAS and a financial assistant.
- The office was not submitting its quarterly inventory reports and was therefore not reporting its inventory levels or their use of controlled documents to NHQ.
- In some situations, the office was tracking documents that were destroyed by the CAS, but the destroyed forms were not reported to NHQ. In other situations, some documents were improperly destroyed by other staff members in the office and these forms were not tracked.
- The office did not maintain a usage log to track the forms that were used, destroyed or spoiled; a usage log would also track the form to a client.
- There was no evidence that the FCO performed monitoring activities.
Recommendation 4
CIC Calgary must implement the required procedures listed in SA6 to ensure that the controlled documents are safeguarded.
Management Response
We accept the recommendation. We will review current office procedures to ensure compliance with the SA6 Policy Manual and amend as necessary. The responsibilities of a forms control officer were assigned within the Administration Unit.
3.3.3 Operational Activities
The objective of this component of the audit was to assess the adequacy and effectiveness of the controls over operational activities, which include:
- the immigration program, including the monitoring of entrepreneurs;
- the temporary resident program; and
- the refugee program, including pre-removal risk assessments.
3.3.3.1 Immigration Program
We expected to find that operational policies and practices complied with legislation, regulations, policies and authorities.
Applications for Permanent Residence
Between October 1 and December 31, 2007, 42 APR cases were finalized at CIC Calgary. Twenty-one randomly selected APR files were reviewed to ensure that the application was complete, that the appropriate criteria were assessed based on the type of application, that admissibility was established and documented, and that final decisions were properly documented.
The audit found that each file contained a complete application with all the required documents, and that the appropriate criteria were assessed.
In order to demonstrate that the applicant is not inadmissible on grounds of criminality, CIC obtains an RCMP criminal clearance for each APR. These clearances are valid for one year. Each file had the appropriate RCMP clearance. However, the RCMP has recommended that CIC conduct a Canadian Police Information Centre (CPIC) check prior to landing if the clearance is out of date. We found that four of the 21 files contained clearances that were more than a year old, and there was no evidence that a CPIC check had been conducted. All other admissibility requirements had been met in the files reviewed.
As well, the audit found that three H&C files were missing the required rationale for the final decision in the FOSS case processing system. However, the audit did note that the final decision was documented in detail in the physical file.
Recommendation 5
A CPIC check must be conducted and documented in FOSS when the criminal clearance was obtained close to or more than one year in advance of the landing date.
Management Response
We accept this recommendation.
Chapter 5, Section 19 of the Inland Processing Manual entitled “Procedures Granting Permanent Residence” states: “Criminal checks have no specific validity date; officers should check FOSS for information about recent charges or convictions. If one year has elapsed from the time of the criminal check, or whenever warranted, a new CPIC check is recommended.” Currently, officers apply discretion in conducting CPIC verifications prior to landing. They consider all information available to them, including file information, FOSS entries, and the client’s statement and declaration at the time of landing. After analysing all available information, if the officer concludes that a CPIC check is warranted, he must perform it. If, however, the officer concludes that a CPIC check is not warranted, he must document the rationale for such a decision. All officers and immigration counsellor assistants will be reminded of the current policy requirements.
Entrepreneurs
Entrepreneurs and their family members are granted permanent residence under specific conditions that are monitored by CIC at inland offices. They must meet the conditions imposed on them over a period of two to three years.
Between October 1 and December 31, 2007, 59 entrepreneur files were being monitored by CIC Calgary. The audit reviewed 12 entrepreneur files and expected to find that CIC Calgary was monitoring each entrepreneur to ensure that conditions imposed on the applicant were being met. The audit found that only one file complied with all the monitoring requirements defined in the Inland Processing Manual.
Recommendation 6
CIC Calgary must ensure that entrepreneurs are monitored in accordance with the procedures outlined in the Inland Processing Manual.
Management Response
We accept this recommendation. Since the audit, an officer has attended a one-week pilot course on entrepreneur monitoring and has been participating in the Prairies/Northern Territories Entrepreneur Working Group. Welcome packages and form letters have been updated and monitoring is now ensured.
3.3.3.2 Temporary Resident Program
The audit expected to find that operational policies and practices complied with legislation, regulations, policies and authorities.
Between October 1 and December 31, 2007, 112 temporary resident cases were finalized at CIC Calgary. The audit reviewed 28 randomly selected files for such applications to ensure that the applications were complete, that the appropriate criteria were assessed based on the type of application, that admissibility was established and documented, and that all final decisions were properly documented.
Facilitating Documents
The audit found that four files were not initially processed through CPC‑Vegreville and therefore, were not referred to CIC Calgary for processing. The applicants contacted CIC Calgary directly because of their urgent need for their immigration documents. The applicants were not requested to submit an application form. In three of the four cases, only an electronic file was created in FOSS while the fourth case did have a previous paper file. The audit noted that draft guidance was created in another inland office and that CIC Calgary was using this draft guidance as direction in specific situations where clients directly approach a local CIC with an urgent request for immigration documents.
Recommendation 7
The Temporary Resident Program Delivery Division should issue guidance to clarify the procedures for the processing of urgent documents.
Management Response
The Temporary Resident Program Delivery Division of OMC will ensure that guidance on how to proceed with urgent requirements for immigration documents is included in the relevant operational manuals.
Recommendation 8
In the absence of guidance from the Temporary Resident Program Delivery Division, complete applications should be required for all urgent cases.
Management Response
We accept this recommendation for applications not referred to CIC Calgary by CPC‑Vegreville. For routine extensions, instructions will be issued to ensure that a formal application is accompanied by any request to extend or to change the status.
However, there is also a need to issue temporary resident documents in the case of errors on documents issued by CIC or the CBSA. Until guidance is issued by OMC, the current process will continue (new applications will not be requested and notes will be made in the remarks portion of the replacement document).
Admissibility
While determining if admissibility requirements were met, the audit found that extensions were granted to three temporary visitors from designated countries, extending their stay in Canada to more than six consecutive months. Since the visitors were from designated countries, medical examinations were required. However, no medical examinations were requested nor were conditions to undergo future medical examinations imposed when the extension was issued.
Recommendation 9
The office must ensure that all temporary visitors from designated countries whose stays in Canada are extended to exceed six consecutive months receive the required medical examination.
Management Response
We accept this recommendation. A reminder has been given to all Admissions Unit staff.
3.3.3.3 Refugee Program
The audit expected to find that operational policies and practices complied with legislation, regulations, policies and authorities.
Application Claims for Refugee Protection
Between October 1 and December 31, 2007, 75 applications for refugee protection were finalized at CIC Calgary. Six randomly selected applications for refugee protection were reviewed to ensure that the application was complete and that the correct processing steps were followed, including specific timelines and interview steps.
The audit found that four of the six files did not contain a signed statement from the interpreter who attended the interview. These statements should indicate that all the information was interpreted to the claimant and that the claimant told the interpreter they completely understood the information.
Recommendation 10
CIC Calgary must ensure that when interpreters are required during interviews with inland refugee claimants, the Interpreter Declaration form is signed.
Management Response
We accept this recommendation. Since the audit, officers have been reminded to ensure that the interpreter declarations are completed.
Pre-Removal Risk Assessment
Between October 1 and December 31, 2007, 18 PRRA were finalized at CIC Calgary. The audit reviewed 5 randomly selected Pre-Removal Risk Assessment (PRRA) cases to ensure the correct processing steps were followed, that a QA review was performed on each file and that the final decisions were properly documented.
Upon review of the sampled files, the audit found that the correct processing steps were followed for all and that the final decisions were properly documented. However, in none of the cases did the audit find any evidence that a QA review was performed to ensure the integrity of the written decisions.
Recommendation 11
CIC Calgary must perform quality assurance reviews of written PRRA decisions on a regular basis.
Management Response
We accept this recommendation. The new PRRA coordinator, appointed in June 2008, will ensure that quality assurance reviews are undertaken in line with the guidelines contained in manual chapter PP3. The In-Canada Protection Unit of the OMC is currently reviewing the quality assurance tool.
Appendix A: Detailed Audit Criteria
Governance Processes
Governance and Strategic Direction
- Operational plans are in place to achieve objectives.
- Communication protocols exist for clients, partners, employees and external stakeholders.
Accountability
- Processes exist to ensure that accountabilities and responsibilities are clearly delegated, communicated and adequately discharged.
- A clear organizational structure is established and documented.
Citizen and Client Focused Service
- Processes are in place to establish, maintain and monitor service principles and standards for clients.
- Processes are in place for effective tracking and resolution of client complaints.
Values and Ethics
- Management promotes and reinforces values and ethics.
- Employees are aware of the Public Service Values and Ethics Code for Public Servants.
Results and Performance
- Processes exist to ensure that planned results and outcomes are linked to organizational objectives.
- Management has identified appropriate performance measures linked to planned results.
- Management monitors actual performance against planned results and adjusts as required.
Learning, Innovation and Change Management
- The organization has in place a process to identify change opportunities and requirements.
- The organization has processes and practices to ensure that change initiatives are properly implemented and well communicated.
People/Human Resources
- The human resources plan is aligned with operational requirements and considers the current and future needs of the organization.
- The organization provides employees with the necessary training, tools, resources and information to support the discharge of their responsibilities.
- The organization has in place a system for the performance evaluation of employees.
- Human resources policies and practices comply with relevant legislation.
Risk Management
- Processes are in place to identify, assess, mitigate and monitor risks.
- Management appropriately communicates risk and risk management strategies to key stakeholders.
- Planning and resource allocation consider risk information.
Control
Stewardship
- Financial resources are budgeted, committed and spent to meet the priorities and objectives of the work plan.
- Forecasts and variances are monitored on a regular basis.
- Financial and administrative policies and practices comply with legislation, regulations, policies and authorities (including contracting, asset management, records and business continuity plans).
- Non-financial policies and practices comply with legislation, regulations, policies and authorities.
- The quality assurance function exists and operates as intended.
Appendix B: Management Action Plan
| # | Recommendation | Action Plan | Responsibility | Target Date |
|---|---|---|---|---|
| 1 | All final decisions must be documented in order to demonstrate the exercise of the appropriate delegated authority. | Issued instructions to officers directing them to clearly indicate the rationale for their decisions in their Notes to File, and to include either their initials or signature. | CIC Calgary Director | Completed |
| 2 | CIC Calgary must implement physical and procedural controls to ensure that funds are properly collected and accounted for. | Designate a position for a cash collector who will maintain singular access to a cash drawer during the day. | CIC Calgary Director | Completed |
| The requirement for individual cash drawers was incorporated into the planning and design of the new facilities scheduled for opening in November 2009. | CIC Calgary Director | November 2009 | ||
| 3 | NHQ Financial Policy and Systems should remove access to void transactions from all SAP cashier profiles and limit this access to the SAP supervisor profile. | NHQ Financial Policy and Systems and NHQ Accounting Operations (business process owner) will review the business process and cashiers’ access. |
NHQ Financial Policy and Systems and NHQ Accounting Operations | To be completed by December 2008 |
| The ability to void transaction access will be removed from SAP cashier profiles. Regular monitoring will ensure adequate control over voided transactions. | ||||
| 4 | CIC Calgary must implement the required procedures listed in SA6 to ensure that the controlled documents are safeguarded. | Review current office procedures to ensure compliance with the SA6 Policy Manual and amend as necessary. | CIC Calgary Director | December 2008 |
| Usage logs will be implemented. | CIC Calgary Director | December 2008 | ||
| The responsibilities of a forms control officer were assigned within the Administration Unit. | CIC Calgary Director | Completed | ||
| 5 | A CPIC check must be conducted and documented in FOSS when the criminal clearance was obtained close to or more than one year in advance of the landing date. | Officers will be reminded of the policy requirements contained in Chapter 5, Section 19 of the Inland Processing Manual which states: “If one year has elapsed from the time of the criminal check, or whenever warranted, a new CPIC check is recommended.” | CIC Calgary Director | Completed |
| 6 | CIC Calgary must ensure that entrepreneurs are monitored in accordance with the procedures outlined in the Inland Processing Manual. | An officer has attended a one-week pilot course on entrepreneur monitoring and has been participating in the Prairies/Northern Territories Entrepreneur Working Group. Welcome packages and form letters have been updated and monitoring is now ensured. | CIC Calgary Director | Completed |
| 7 | The Temporary Resident Program Delivery Division should issue guidance to clarify the procedures for the processing of urgent documents. | Review the existing guidance to determine gaps. | TPRD, OMC | March 31, 2009 |
| Consult with the necessary stakeholders and draft new guidance. | ||||
| Communicate new guidance to operations. | ||||
| 8 | In the absence of guidance from the Temporary Resident Program Delivery Division, complete applications should be required for all urgent cases. | For routine extensions, instructions will be issued to ensure that a formal application is accompanied by any request to extend or to change the status. | CIC Calgary Director | Completed |
| New guidance to operations to be issued for cases involving documents incorrectly issued by CIC or the CBSA. | TPRD, OMC | March 31, 2009 | ||
| 9 | The office must ensure that all temporary visitors from designated countries whose stays in Canada are extended to exceed six consecutive months receive the required medical examination. | A reminder has been given to all Admissions Unit staff. | CIC Calgary Director | Completed |
| 10 | CIC Calgary must ensure that when interpreters are required during interviews with inland refugee claimants, the Interpreter Declaration form is signed. | A reminder was issued to officers to ensure that the interpreter declarations are completed. | CIC Calgary Director | Completed |
| 11 | CIC Calgary must perform quality assurance reviews of written PRRA decisions on a regular basis. | Quality assurance reviews are being conducted with the recent appointment of a new PRRA coordinator. | CIC Calgary Director | June 2008 – Completed |
| Quality assurance tool being reviewed. | In-Canada Protection Unit, OMC | November 2008 | ||
| Ongoing monitoring (one decision per officer per year) with yearly report | In-Canada Protection Unit, OMC | Ongoing, starting April 2009 |
Appendix C: Audit Time Lines
Audit planning — December 2008
On-site examination — January 28 to February 1, 2008
Clearance draft to CIC Calgary for comments — July 17, 2008
Management action plan finalized — November 2008
Report reviewed by Audit Committee and approved by Deputy Minister — November 25, 2008
- Date Modified:
