Audit of the Inland Temporary Resident Program Delivery
Audit Report
Internal Audit and Accountability Branch
Citizenship and Immigration Canada
October 2009
Table of Contents
- List of Acronyms
- Executive Summary
- 1.0 Introduction
- 2.0 Conclusion
- 3.0 Best practices
- 4.0 Observations and Recommendations
- Appendix A: Lines of Enquiry and Criteria
- Appendix B: Roles, Responsibilities and Accountabilities
- Appendix C: Management Action Plan
- Appendix D: Audit Time Line
List of acronyms
- CBSA
- Canada Border Services Agency
- CIC
- Citizenship and Immigration Canada
- CPC
- Case Processing Centre
- CPC-V
- Case Processing Centre, Vegreville
- DG
- Director General
- FOSS
- Field Operation Support System
- NHQ
- National Headquarters
- OMC
- Operational Management and Coordination Branch
- QA
- Quality Assurance
- QDM
- Quality of Decision Making
- RPA
- Regional Program Adviser
- SOP
- Standard Operating Procedure
- SP
- Study Permit
- TFW
- Temporary Foreign Worker
- TR
- Temporary Resident
- TRP
- Temporary Resident Permit
- WIP
- Workload, Inventory and Production report
- WP
- Work Permit
Executive Summary
Citizenship and Immigration Canada’s (CIC’s) Risk‑Based Audit Plan for 2008–2011 includes an audit of Inland Temporary Resident (TR) Program delivery. This audit was identified as a priority because the program is an important component of CIC’s inland operations.
The goals of the Immigration and Refugee Protection Act with respect to foreign nationals as TRs are as follows: [note 1]
- To facilitate the entry of visitors, students and temporary workers for the purpose of fostering trade, commerce, tourism, international understanding and cultural, educational and scientific activities
- To protect the health and safety of Canadians and to maintain the security of Canadian society
- To promote international justice and security by fostering respect for human rights and by denying access to Canadian territory to persons who are criminals or security risks.
TRs include workers, students, visitors, and Temporary Resident Permit (TRP) holders. In 2007–08, CIC offices in Canada issued approximately 291,000 permit and visa extensions, including new permits, for TR status. Around 94% of the extensions/permits were issued by the Case Processing Centre in Vegreville, Alberta (CPC‑V), and around 6% of the extensions/permits were issued by local (inland) offices.
The objectives of the audit were to determine whether:
- The processes associated with Inland TR Program delivery are designed to ensure compliance with legislation, regulation, and policy; are in line with departmental guidance; and are operating as intended
- There is adequate oversight and risk management of the Inland TR Program.
The audit covered the delivery of the Inland TR Program, including the activities at NHQ, the inland regional offices, CPC‑V, and local offices. It excluded the Immigration Policy Branch, because program policy was outside the scope of this audit.
The audit was conducted to be in accordance with the Government of Canada’s Policy on Internal Audit as well as with the Institute of Internal Auditors professional practice standards.
Planning for the audit took place between April and July 2008. During the planning phase, interviews were conducted with regional and NHQ staff; legislation, policies and other relevant documentation was reviewed; and the audit criteria were developed and provided to TR Program management. The examination phase ran from August 2008 to March 2009 and included site visits and file review.
Based on our examination, we conclude that the processes associated with Inland TR Program delivery are designed to ensure compliance with legislation, regulation and policy; and are operating as intended. However, the quality of file and FOSS documentation requires improvement.
With regard to CIC procedures for the oversight and risk management of the Inland TR Program, the fundamentals are in place. However, improvements are required in order to have a robust and mature oversight framework. These improvements include updated manuals, an assessment of training needs, and gathering and reporting better performance information. Those improvements should be complemented by regular monitoring review and follow‑up that includes decisions made by CPC‑V and by local offices. Additional focus is needed on risk oversight on the TR Program.
It is acknowledged that Operational Management and Coordination Branch, which has the functional lead for the Inland TR Program, is evolving and has experienced staffing challenges.
1.0 Introduction
The Citizenship and Immigration Canada (CIC) Risk‑Based Audit Plan for 2008–2011 includes an audit of Inland Temporary Resident (TR) Program delivery. The audit was identified as a priority because the program is an important component of CIC’s inland operations. In 2007–08, CIC offices in Canada issued approximately 291,000 permit and visa extensions, including new permits, for TRs. Around 94% of the extensions/permits were issued by the Case Processing Centre in Vegreville, Alberta (CPC‑V), and approximately 6% of the extensions/permits were issued local (inland) offices.
1.1 Background
1.1.1 Inland TR Program delivery
The goals of the Immigration and Refugee Protection Act with respect to foreign nationals as TRs are as follows: [note 2]
- To facilitate the entry of visitors, students and temporary workers for the purpose of fostering trade, commerce, tourism, international understanding and cultural, educational and scientific activities
- To protect the health and safety of Canadians and to maintain the security of Canadian society
- To promote international justice and security by fostering respect for human rights and by denying access to Canadian territory to persons who are criminals or security risks.
TRs include workers, students, visitors, and temporary resident permit (TRP) holders. Workers, students and visitors initially apply from outside Canada. Once they are in Canada, they can apply for an extension of or, in some cases, a change in their status. The TR Program consists of a number of sub‑programs targeting specific categories of TRs, and each sub‑program has its own specific requirements. Some of the sub‑programs, such as the Live‑in Caregiver Program, may eventually lead to a permanent resident status.
In general, to extend their stay or to change their status, TRs have to obtain an application package and the related instructions by downloading them from the Internet or by requesting the package by mail from CIC. If they have questions, applicants can contact CIC’s call centre. Applicants must complete the application, attach the relevant documents, and pay the appropriate fees to CIC at a financial institution or online. The proof of payment form is included with the completed application. Visitors and students need to include documentation such as proof of identity, proof of status, and evidence of support. Temporary workers need to include documents such as their job offer or employment contract and evidence of medical examination, if applicable. Completed applications, accompanied by required documents, must be mailed to CPC‑V.
Most inland applications for TR extensions are processed by CPC‑V. During processing, designated CIC staff assess each application and the supporting documentation to determine whether the applicant meets the eligibility criteria set out in the applicable regulations and other related CIC requirements. As part of the decision‑making process, staff review information available on departmental systems and assess the validity of the reason for the extension and that of the supporting information. Some applications are referred to local offices for further information or clarification. Some local offices also handle walk‑in emergency applications.
1.1.2 Roles and responsibilities: Program delivery
The responsibilities associated with the inland delivery of the TR Program are described in Appendix B.
1.1.3 Resources
At CPC-V, approximately 140 employees and a budget of $7.6 million are dedicated to TR processing. The resources dedicated to TR Program delivery in inland offices have not been specifically identified in all of the inland regions.
1.1.4 Risk context
People who apply to modify or extend their TR status inland undergo admissibility screening when they first apply for a work permit or for a student or visitor visa at a CIC mission abroad or when they arrive at a port of entry. There is a separate process for TRPs, since they are only issued when there are compelling reasons to allow someone who does not meet the requirements of the Immigration and Refugee Protection Act to enter or remain in Canada.
On the one hand, the admissibility screening at the time of initial visa or permit application or at the Port of Entry, and the specific process for TRPs, limit the risks to program integrity for the Inland TR Program. On the other hand, those risks are increased by the fact that the TR Program has several sub‑programs, each of which has separate requirements for specific categories (workers, students, visitors) that are subject to change.
Approximately 94% of in‑Canada permits and extensions for TR status are processed at CPC‑V, thereby limiting the risk of inconsistency in program delivery that can happen when multiple points of service are involved in processing.
The process for determining whether an applicant is allowed to remain in Canada involves an element of judgment. That element of judgment and the fact some applications are processed at local offices pursuant to CPC-V referral increase the risk of inconsistency in decision‑making for applications processed at local offices.
1.1.5 Environmental context
Although the TR Program is demand‑driven, the resources for processing applications are part of the same resource base used to process permanent resident admissions, which is commitment‑driven. There is an inherent tension in the immigration system: the delivery network uses the same resource base to manage both temporary and permanent lines of business, but despite significant and sustained growth on the temporary side, there has been no corresponding increase in resources.
This tension continues through to the branch and division level, as program managers manage competing priorities, such as the Olympics project and operational readiness, by re‑allocating resources to on‑demand files and by shifting priorities. The regulatory agenda will continue to create pressure at the division level, as will the considerable investment needed to support the CBSA in its role in delivering CIC’s mandate.
1.2 Audit Objectives
The objectives of the audit were to determine whether:
- The processes associated with Inland TR Program delivery are designed to ensure compliance with legislation, regulation, and policy; are in line with departmental guidance; and are operating as intended
- There is adequate oversight and risk management of the Inland TR Program.
1.3 Audit Scope
The audit covered the delivery of the Inland TR Program, including activities at NHQ, inland regional offices, CPC Vegreville, and local offices.
The audit examined the oversight functions provided by the Operational Management and Coordination Branch (OMC) and by the regions, but excluded the Immigration Policy Branch, as program policy was outside the scope of this audit.
1.4 Audit Methodology
Planning for the audit was conducted between April and July 2008. During the planning phase, we conducted interviews with regional and NHQ staff; reviewed legislation, policies and other relevant documentation; and developed the audit criteria. The audit plan, including the audit criteria, was distributed to the regional Directors General and to the relevant Directors and Directors General at NHQ.
The examination phase consisted of three steps:
- An off‑site preliminary review of documents and case files, interviews with staff at NHQ, and telephone interviews with staff in the regions (August to September 2008)
- On-site examination at selected local offices and at CPC Vegreville, which included reviewing documents, interviewing staff and management, and reviewing case files (August and September 2008)
- A final off-site review of documents and files, an analysis of findings, and interviews at NHQ and with CBSA staff (October 2008‑March 2009).
The audit team reviewed a total of 299 local office files and 59 case files processed at CPC‑V. In the review, the audit team assessed whether the applications on file were processed in accordance with CIC policies and procedures and determined whether the correct fee was paid.
The sample of files from local offices was selected from files processed between April 1 and June 30, 2008. CPC‑V files were selected from the sample used in the 2007 national CIC Quality Assurance (QA) exercise. Files selected included decisions on work permits, study permits, visitor visas and TRPs. Sample sizes and locations were determined on a judgmental basis.
The audit was conducted to be in accordance with the Government of Canada’s Policy on Internal Audit as well as with the Institute of Internal Auditors professional practice standards.
2.0 Conclusion
Based on our examination, we conclude that the CIC processes associated with Inland TR Program delivery are designed to ensure compliance with legislation, regulation and policy; are in line with departmental guidance; and are operating as intended. However, the quality of file documentation and FOSS documentation requires improvement.
With regard to procedures for the oversight and risk management of the Inland TR Program, the fundamentals are in place. They include a functional guidance model with definition of roles and responsibilities; regular direction and guidance to staff at all levels, supported by program manuals and a national QA program. However, improvements are required to strengthen the oversight framework. These improvements include updating manuals, conducting a training needs assessment, and gathering and reporting better performance information. Those efforts should be complemented by regular monitoring review and follow-up that includes decisions made by CPC‑V and by local offices. Additional focus is needed with respect to risk oversight on the TR Program.
OMC, which is responsible for operational coordination and which is the functional lead for delivering the TR Program, is evolving and has experienced staffing challenges. It has been strengthening its role over the past year. However, the functional guidance model has created expectations from the regions in terms of guidance and monitoring. OMC has opportunities to strengthen TR Program delivery, and this is where our recommendations are primarily directed.
3.0 Best practices
Some best practices came to our attention during the audit. We describe them here for information purposes only and to promote sharing and discussion among program staff. It is not to be inferred that they should be adopted in other offices without due consideration of the local environment. If used in the right context, practices like these can provide management with additional assurance that the program is operating efficiently and effectively.
- One of the offices maintains a detailed spreadsheet on error corrections (based on client requests for the corrections). The errors relate to spelling, gender, missing digits in document numbers, etc. The office has been receiving many such requests, and this information helps demonstrate the impact of processing errors on CIC resources.
- Some offices had excellent documentation practices in place for FOSS and case files. For example, some of the files contained a clear reference to or an excerpt from the appropriate section of the Regulations or manuals. Some files clearly documented the rationale for the decision and explicitly addressed the CPC referral. In some cases, including a few complex ones, interview notes were well documented in FOSS. Good documentation practices support transparency and accountability and help in processing subsequent applications for extension.
- In one region, staff use a form to document the rationale for handling a walk‑in case. The form is then reviewed by a supervisor. While such a form may not be practical in offices that have a large volume of walk‑in cases, it may be useful to capture the rationale for “emergency” processing when considering future process improvements.
- Several local offices have documented standard operating procedures for TR processing. Some offices store them on a shared drive. These procedures are helpful to local staff when processing TR applications and for training purposes.
- In one region, the Regional Program Advisers (RPAs) provide explanatory comments when distributing new guidance such as Operational Bulletins from NHQ. Such comments generate additional interest and may help in adapting the changes to the local context; however, RPAs must take care not to interpret the instructions.
- One region colour‑codes the various types of TR files, which makes it easier for staff to monitor workload and retrieve files.
4.0 Observations and recommendations
The following observations and recommendations are based on the audit criteria detailed in Appendix A.
4.1 Compliance
In assessing compliance, we expected to find that processes and standard operating procedures (SOPs) were designed to ensure compliance with legislation, regulation and policy; that they are in line with departmental guidance; and that they are operating as intended. We also expected to find that records and information are properly maintained.
Overall, CIC’s processes and SOPs are designed to ensure compliance with legislation, regulation and policy; are in line with departmental guidance; and are operating as intended. The processes and procedures are documented in manuals and operational bulletins, and guidance is available on WebCart, a tool available on the Department’s Intranet site that provides access to a host of information on CIC’s programs and services. Although staff refer to the applicable legislation, regulation policy and guidance during the decision‑making process, and although we observed some best practices, there are opportunities to improve the file documentation in the following areas.
CPC‑Vegreville processes
Service Delivery Agents and Service Delivery Specialists at CPC‑V have access to relevant policies and manuals, and to tools such as WebCart. CPC‑V uses an internal training and mentoring process for service delivery agents to ensure that staff who process TR applications understand the applicable legislation, policies and procedures and have up‑to‑date guidance. Staff can ask supervisors for assistance, and they also have access to Service Delivery Specialists and to the Strategic Analysis Unit for help with complex cases. When further information or clarification is required, applications are referred to local offices. However, CPC-V staff reported that updates to procedures at local offices are not documented.
Our review of CPC‑V files and of the 2007 QA exercise indicates that file documentation needs to be improved in order to demonstrate compliance with CIC requirements.
CIC local office processes
Most local offices agreed with the criteria that CPC‑V uses when referring files to them. When processing referred files, local offices have access to and use the departmental manuals, operational bulletins, and other tools such as WebCart. In 91% of the files we reviewed, there was sufficient information, in the file, and/or in FOSS, to indicate that the decision complied with departmental policies and authorities. In some cases, however, initials were missing in FOSS or documentation was missing on whether an application had been submitted for security vetting, where necessary.
Areas for improvement are as follows:
- Guidance to strengthen documentation in FOSS and in case files is needed to help ensure consistent record keeping to support and explain the decision‑making process.
- In 3 of the 18 cases of TRPs in our sample, when it appeared that the admissibility decision should have been approved by someone at the site‑manager level or higher, there was no indication in the file whether such approval was obtained. Guidance is required regarding how to document the appropriate designated officer’s decision in such situations.
- Criteria are needed on what constitutes an emergency that would mean that an application could be handled as a walk‑in case. Normally, clients have to send their application directly to CPC‑V. Some local offices see clients by appointment only and do not provide walk‑in service. Other offices use CPC‑V processing times as the basis for determining whether to accept a walk‑in. The local offices indicated that they generally determine emergencies on a case‑by‑case basis. The lack of a common definition can cause inconsistency in client service among offices.
- When a TR extension document is issued in Canada for a period that results in a stay in Canada of more than six months for an individual from a designated country, an immigration medical examination normally has to be requested. Inland Processing manuals should specify that requirement.
Recommendation 1
TR Program Delivery Division, OMC, should develop appropriate guidance for CIC offices, including CPC‑V, to strengthen file documentation and to clarify the criteria for emergency processing. The guidance should address areas such as the standards for documentation in FOSS and case files with respect to TR decisions, definition of “emergency” for walk‑in service, and clarification/reminder regarding the application of medical requirements to TR extensions.
Management response
Agree. The TR Program Delivery Division will provide additional guidance in the areas specified, either by updating manuals or by issuing appropriate operational bulletins.
4.2 Oversight and risk management
4.2.1 Functional authority
In assessing functional authority, we expected to find that functional authority is clearly established, implemented and understood. We also expected to find that operational guidance is comprehensive and up to date.
Under the departmental reorganization of March 2006, the CIC Operations Sector was mandated to move to a model of centralized functional guidance. The basic constructs of that model include the following:
- Program advisers report directly through existing field structures, with functional authority coming from OMC and NHQ. Program advisers are to perform a mixture of service to the enterprise, with functional direction from OMC, and service to the field or region under direction from their own line Director General (DG).
- DGs in the Operations Sector have embedded in their performance management agreements specific accountabilities related to the provision of centralized functional guidance enterprise‑wide. These objectives are cascaded into the performance management agreements of their Directors in their respective organizations, in the field, and at NHQ.
Staff at NHQ and in the regional and local offices generally understand the functional guidance model. Operational guidance is received through the departmental manuals and Operational Bulletins from NHQ. The manuals are available on the Intranet, and all offices rely on them as their main source of guidance. OMC’s TR Program Delivery Division holds monthly conference calls on TR matters with RPAs and regional colleagues. In September 2008, case conferencing started on the Temporary Foreign Worker (TFW) Program. WebCart provides useful information for all staff and fosters understanding of issues and practices.
In the field, local officers receive instructions from supervisors and contact RPAs through the supervisor for guidance and clarification. When necessary, RPAs seek guidance from OMC at NHQ and communicate it back to local offices. Some local offices store operational procedures on a shared drive so that all staff can access them. For local offices in particular, rapid responses from NHQ are essential, and some offices indicated that they have experienced problems in this area. OMC mailbox statistics indicate that, in 2008, 88% of queries on the TR Program were answered and that 63% of the answered queries were answered within a week. OMC follows up on unanswered queries quarterly to ensure that all queries have been addressed.
The creation of a TR Program functional role in OMC has raised significant expectations in the field for timely advice, direction and tools. Although implementation of the functional guidance model is under way, several elements (e.g. training, manual revisions) still need to be completed. The functional guidance model is evolving, but full implementation will take time. OMC is coordinating the issuance of Operational Bulletins and has initiated a project to update the manuals.
The local offices and CPC‑V appear to be satisfied with the guidance they are receiving on program changes, although some offices find the extent of the changes somewhat overwhelming. Several interviewees indicated that, because the manuals were not being updated systematically, it was more difficult to obtain relevant information. Although operational guidance is available, the current process would be more efficient if staff could go to a single source on the Intranet, such as a portal, to identify resources for the TR Program.
Recommendation 2
TR Program Delivery Division, OMC, should strengthen the Division’s functional guidance role by updating manuals, providing timely responses to program inquiries and establishing relevant service standards, and facilitating access to program changes on the Intranet through a tool such as a portal.
Management response
Agree. The TR Program Delivery Division is implementing an aggressive schedule for updating manuals and training packages. It will continue to hold regular working group meetings with the regions in order to raise awareness about program changes. OMC will engage areas that have responsibility over Intranet/Internet products to relay user requirements.
4.2.2 Program monitoring
In assessing program monitoring, we expected to find that the TR Program is monitored to ensure the integrity of decisions and processes in accordance with legislation, regulations and policies. We also expected to find that the TR Program is monitored to ensure the consistency of program delivery across the regions.
CIC has a national QA program called Quality of Decision Making (QDM). The purpose of the program is to verify the accuracy of decisions rendered by CIC officials and to ensure that applications are being processed within the policy and legislative framework of the Immigration and Refugee Protection Act. At the time of our examination, this national program had only assessed the quality of TR Program processing decisions made by CPC‑V. As part of our procedures, we reviewed a sample of 59 case files that had already been subject to QA during the 2007 exercise. Our review of the sample files confirmed that the QA was carried out appropriately. However, no follow-up was being performed on matters of concern identified in the QA exercise, and the QDM reports did not explicitly indicate the level of compliance with departmental legislation and regulations.
The QDM exercise follows a model previously used for the Citizenship program and is based on the statistical sampling methodology. The methodology has not been updated recently or reviewed by statistical experts. At the time of our audit, the 2008 QA process for the TR Program had just been launched and was to include local office decisions. There was no systematic monitoring through RPAs or by NHQ of local office decision‑making processes.
Because of the high volume of decisions, an effective QA program is critical to monitoring the integrity of decisions. Updating the methodology and approach would ensure that the QA program provides reliable data for assessing program integrity. Extending QA to local office decisions would help ensure that compliance is monitored at that level.
For the actual delivery of the TR Program, local offices appear to have flexibility in how they organize and use resources. Workload varies widely from region to region, and local priorities differ. Our review also indicates that offices use different practices for processing applications. For example, one office schedules in‑person interviews as soon as it receives a referral from CPC‑V, whereas another office assesses cases based on the information in the applications and will occasionally contact applicants by phone or by mail.
Representatives of the Service Improvement Office and regional and/or NHQ staff hold brainstorming sessions from time to time to identify areas for improvement. However, no national or regional monitoring is conducted of local office practices to assess consistency in client service.
Recommendation 3
To strengthen program monitoring, the following measures should be taken:
- Fraud Deterrence and Verification Division, OMC, should ensure that the QA methodology for the TR Program is reviewed and extended to local TR decisions, and that its results are conveyed to senior departmental management and are followed up on appropriately.
- TR Program Delivery Division, OMC, in consultation with the Fraud Deterrence and Verification Division, should clarify expectations regarding the consistency of delivery practices, including identifying the responsibility for monitoring of local procedures and practices with the goal of achieving uniformity, as appropriate.
Management response
Fraud Deterrence and Verification Division will review the existing QA methodology for the Temporary Resident Program, and extend it to local Temporary Resident decisions. Outcomes of the Temporary Resident QA exercises will be communicated to senior management, and monitoring will be undertaken jointly with TR Program Delivery Division.
TR Program Delivery Division will ensure that expectations regarding consistency of program delivery, and responsibility for monitoring local procedures and practices are clarified.
4.2.3 Performance management
In assessing performance management, we expected to find that relevant information on results is gathered and used to make decisions. In particular, we expected to find clear linkages between resources and results.
At local offices, operational statistics on the TR Program are reported regularly, usually monthly. In most cases, these statistics do not indicate the actual level of resources dedicated to the TR Program. Some regions prepare reports on performance at the local level, which provide productivity information. Most offices use regional systems for statistical reporting. Data is compiled and used for workload, inventory, and production (WIP) reports. WIP reports are also compiled at the regional and national levels and are used to prepare performance reports that are discussed at the monthly meeting of the DG Steering Committee on Production Management and Processing Capacity. One such report is the Dashboard Report, which is compiled by Performance Management Division. The Dashboard Report provides information on trends relating to permanent and temporary resident decisions.
Statistics on complaints are not formally collected and reported. The WIP reports are not regularly reconciled with FOSS. The WIP report is a point‑in‑time report produced primarily from local or regional systems, whereas the FOSS database is constantly updated. FOSS is used to report statistics on landings and documents issued.
More focus needs to be given to performance reporting and performance management in the TR Program. Local offices report that it is difficult to plan for and obtain resources to properly administer the program. Some inland offices do not have specific resources allocated to the TR Program except for TFW Program. There is a lack of detailed performance information on the TR Program, including information on trends throughout the year, on resources, on refusal rates, and on CPC‑V referral volumes. Some offices have tried to adapt by combining TR processing in units with other lines of business to help balance workload.
Recommendation 4
OMC should develop a process for the systematic reporting and analysis of performance with respect to TR decisions.
Management response
Agree. Recent improvements to operational performance monitoring and performance management provide for sufficient performance information, including intake, output (including decisions, acceptance rates, documents issued and admissions processed) and processing time across all key business lines, including temporary residents. The data is intended to support operational planning and analysis, and to enhance decision‑making. It is used to prepare performance reports that are discussed at the monthly meeting of the DG Steering Committee on Production Management and Processing Capacity. Since that steering committee is responsible for reviewing the Department’s performance information, OMC will assess the requirements for additional performance information, and integrate it into the Dashboard to provide a better overview of the TR Program.
4.2.4 Risk management
In assessing risk management, we expected to find that program management actively identifies and manages risk.
Operational managers in regional and local offices and at NHQ provided us with their understanding of the key risks with regard to Inland TR Program processing. The risks identified vary among program managers, depending on local challenges.
Generally, except for the TFW Program, the inland delivery of the TR Program had not encountered major issues from a regional management perspective. The TFW Program has much higher visibility in western provinces.
While several fundamental elements are in place for managing risk in connection with Inland TR Program delivery, there are two significant gaps. First, there is no single risk assessment / risk register prepared for the TR Program. In a mature risk management environment, we would have expected to find a risk register that identifies the key risks relative to the TR Program and that includes an assessment of the likelihood and impact of those risks. Program managers are sensitive to risk considerations; however, in the absence of a common identification and understanding of risks for the TR Program, program‑specific risks may not be understood and addressed in a coordinated and consistent manner across the country. Second, it was not clear where the responsibility for risk oversight for the TR Program lies.
Recommendation 5
OMC should ensure that :
- A specific risk assessment / risk register is compiled for the Inland TR Program.
- Accountability for the monitoring of risk oversight for the Inland TR Program is clearly defined.
Management response
Agree. In response to an audit of Ontario Region governance, OMC committed to developing a risk register for all regional offices. OMC will ensure that the register incorporates risks specific to the TR Program. OMC will continue to build on existing corporate planning cycles and to leverage information already available to manage risk. Accountability for the monitoring of risk oversight will be defined.
4.2.5 Staff training
In assessing staff training, we expected to find that staff are properly trained and informed of their roles and responsibilities.
During the interviews, staff at local offices indicated that they had a good understanding of their roles and responsibilities and of their delegated authorities. However, as noted in Section 4.1—Compliance, significant improvements are required with regard to the quality of documentation in the files and in FOSS.
CPC‑V conducts its own training. It has a well‑developed approach to training and a formal mentoring program. Immigration Officers and Immigration Counsellor Assistants receive basic national training when they are initially appointed to their positions. This training covers processing TR applications. Several interviewees had received this training quite a while ago. There is no national course specifically for the TR Program, and formal training in local offices on the TR Program has been limited. One local office provided a one‑day training session on the TR Program in February 2008 at the initiative of local management. Most staff reported that the FOSS training they received was a long time ago and/or was given informally by a colleague. CPC‑V staff indicated that they needed a refresher course and a course for service delivery specialists.
National training can improve consistency at local offices and at CPC‑V, and it is particularly important for staff at local offices who work on multiple business lines. Training is one of several elements in the performance management spectrum. Our discussions with representatives of the Learning and Development Division and the Temporary Resident Program Delivery Division, revealed that a needs analysis should be conducted before specific national TR Program training is developed.
Recommendation 6
TR Program Delivery Division, OMC, in consultation with the Learning and Development Division, should conduct a training needs analysis for staff who deliver the Inland TR Program and should take appropriate action based on that analysis.
Management response
Agree. TR Program Delivery Division, OMC, and the Learning and Development Division (LDD) will work together to develop a framework for a performance gap analysis. OMC will draft a proposal to seek organizational support to implement the performance gap analysis and ensure that appropriate actions are taken based on the assessment. Training may be one solution to the problem, in which case LDD will take the lead on a training agenda.
4.2.6 Relationships with program delivery partners
In assessing relationships with program delivery partners, we expected to find that effective liaisons and relationships with partner agencies are established and maintained. We also expected to find that there is effective oversight and/or monitoring of permits issued by the CBSA on behalf of CIC, as outlined in the CIC/CBSA Memorandum of Understanding.
CIC’s relationship with the CBSA is governed by a detailed MOU that contains business process annexes identifying the responsibilities of each party. There is a CIC-CBSA Joint Management Committee chaired by CIC DG OMC and CBSA DG People Programs Division. At the operational level, the relationships with partners are good and effective. Staff members liaise regularly with the CBSA and with Canadian Security Intelligence Service and the Royal Canadian Mounted Police on security and removal issues, with local Human Resources and Skills Development Canada and Service Canada offices on labour market opinions as they relate to TFWs, and provincial social services departments with regard to social assistance matters. There are also formal forums at the regional and NHQ levels. In some provinces, CIC officials liaise with provincial officials who have been designated to deal with immigration issues from the provincial perspective. At NHQ, good relationships exist between the Case Management Branch and CBSA, between the Service Improvement Office and the CBSA’s People Processing Division, as well as between OMC and the CBSA’s People Processing Division.
With regard to the monitoring of TRPs issued by the CBSA on behalf of CIC, CIC and the CBSA have reviewed the existing procedures and have agreed on the need for clearer policy direction, enhanced training, and a monitoring framework to improve on the quality of the program. Implementation is under way.
Appendix A: Lines of Enquiry and Criteria
Compliance
- Processes and standard operating procedures are designed to ensure compliance with legislation, regulations and policy; are in line with departmental guidance; and are operating as intended.
- Records and information are properly maintained.
Oversight and risk management
- Functional authority is clearly established, implemented, and understood.
- Operational guidance is comprehensive and up to date.
- The program is monitored to ensure the integrity of decisions and processes in accordance with legislation, regulations, and policies.
- The program is monitored to ensure consistency of program delivery across the regions.
- Program management actively identifies and manages risk.
- Effective liaisons and relationships with partner agencies are established and maintained.
- Relevant information on results (internal, service and program) is gathered and used to make decisions.
- Staff are properly trained and understand their roles and responsibilities.
- There is effective oversight and/or monitoring of permits issued by the CBSA on behalf of CIC as outlined in the memorandum of understanding between CIC and the CBSA.
Appendix B: Roles, Responsibilities and Accountabilities
Immigration Branch
- Designs and develops policies and programs that are aligned with CIC’s mandate and objectives.
Operational Management and Coordination Branch
- Coordinates all of CIC’s operational activities, domestically and internationally.
- Develops operational guidelines, manuals, training material and publications.
- Provides national oversight and functional advice and guidance to the field through regional program advisers.
- Works with the policy sector on program design and development and conducts quality assurance programs for the TR business line.
Case Management Branch
- Liaises with the Minister’s office on the issuance of TRPs.
- Responds to field requests on criminal equivalency and on issues related to rehabilitation.
- Responds to field requests for case‑specific advice.
Centralized Processing Region
- Provides oversight and support in the delivery of CIC’s centralized processing functions (e.g. CPC‑Vegreville).
CPC‑Vegreville
- Processes applications from all in‑Canada foreign nationals applying for permanent residence and extensions to temporary resident status. Applications processed include temporary residence applications such as extensions of visitor status; new and extended work and study permits; temporary resident permits; immigrant applications for permanent residence; right of permanent residence fee loan and protected person status documents. CPC‑V refers applications to local offices for further information or clarification, if required.
Regional Program Advisers
- Provide day‑to‑day functional advice to field officers or managers in their region.
- Participate in TR Working Group teleconferences and face‑to‑face meetings organized by OMC.
- Play a key role in conducting QA exercises across all business lines.
- Lead or work on national teams for specific initiatives, under the guidance of OMC.
Local CIC offices
- Process TR applications referred by CPC Vegreville.
- Some local offices accept applications at the front counter or on a walk‑in basis if it is determined that exceptional circumstances exist.
Appendix C: Management Action Plan
| # | Recommendation | Action Plan | Responsibility | Target Date |
|---|---|---|---|---|
| 1. | TR Program Delivery Division, OMC, should develop appropriate guidance for CIC offices, including CPC-V, to strengthen file documentation and to clarify the criteria for emergency processing. The guidance should address areas such as the standards for documentation in FOSS and case files with respect to TR decisions, definition of “emergency” for walk-in service, and clarification/reminder regarding the application of medical requirements to TR extensions. |
The TR Program Delivery Division will provide additional guidance in the areas specified, either by updating manuals or by issuing appropriate operational bulletins. | Director, TR Program Delivery, OMC | April 2010 |
| 2. | TR Program Delivery Division, OMC, should strengthen the Division’s functional guidance role by updating manuals, providing timely responses to program inquiries, establishing relevant service standards, and facilitating access to program changes on the Intranet through a tool such as a portal. | The TR Program Delivery Division is implementing an aggressive schedule for updating manuals and training packages. |
Director, TR Program Delivery, OMC | Gap analysis of training packages to be conducted by January 2010. Material revisions to be conducted over 2010–11. All TR manuals to be updated on an ongoing basis. |
| It will continue to hold regular working group meetings with the regions in order to raise awareness about program changes. | Regional working groups have been set up. | |||
| OMC will engage areas that have responsibility over Intranet/Internet products to relay user requirements. | Commencing this fall; to be undertaken on an ongoing basis. | |||
| 3. | To strengthen program monitoring, the following measures should be taken: a) Fraud Deterrence and Verification Division, OMC, should ensure that the QA methodology for the TR Program is reviewed and extended to local TR decisions, and that its results are conveyed to senior departmental management and are followed up on appropriately. |
Fraud Deterrence and Verification Division will review the existing QA methodology for the Temporary Resident Program, and extend it to local Temporary Resident decisions. Outcomes of the Temporary Resident QA exercises will be communicated to senior management, and monitoring will be undertaken jointly with TR Program Delivery Division. |
a) Director, Fraud Deterrence and Verification, OMC |
Review of methodology by April 2010 Extension of QA to local offices over 2010–11, in consultation with the TR Program Delivery Division; reporting of results and monitoring to follow the implementation of the TR QA exercises |
| b) TR Program Delivery Division, OMC, in consultation with the Fraud Deterrence and Verification Division, should clarify expectations regarding the consistency of delivery practices, including identifying the responsibility for monitoring of local procedures and practices with the goal of achieving uniformity, as appropriate. | TR Program Delivery Division will ensure that expectations regarding consistency of program delivery, and responsibility for monitoring local procedures and practices are clarified. | b) Director, TR Program Delivery, OMC (in consultation with Director, Fraud Deterrence and Verification, OMC) | Consultations with RPAs will begin in the fall of 2009: to be completed by March 2010. Clarification of consistency of program delivery will be further reinforced by the QA process as it moves forward. |
|
| 4. | OMC should develop a process for the systematic reporting and analysis of performance with respect to TR decisions. | Since that steering committee is responsible for reviewing the Department’s performance information, OMC will assess the requirements for additional performance information, and integrate it into the Dashboard to provide a better overview of the TR Program. | DG, OMC | Performance information to be integrated into the Dashboard by April 2010 |
| 5. | OMC should ensure that : a) A specific risk assessment/risk register is compiled for the Inland TR Program. |
In response to an audit of Ontario Region governance, OMC committed to developing a risk register for all regional offices. OMC will ensure that the register incorporates risks specific to the TR Program. |
DG, OMC |
April 2010 |
| OMC will continue to build on existing corporate planning cycles and to leverage information already available to manage risk. Accountability for the monitoring of risk oversight will be defined. | December 2009 | |||
| 6. | TR Program Delivery Division, OMC, in consultation with the Learning and Development Division (LDD), should conduct a training needs analysis for staff who deliver the Inland TR Program and should take appropriate action based on that analysis. | OMC’s TR Program Delivery Division and the Learning and Development Division will work together to develop a framework for a performance gap analysis. OMC will draft a proposal to seek organizational support to implement the performance gap analysis and ensure that appropriate actions are taken based on the assessment. Training may be one solution to the problem, in which case LDD will take the lead on a training agenda. | Director, TR Program Delivery Division and Director, Learning and Development Division |
Framework for performance gap analysis to be developed by April 2010. |
| Implementation of gap analysis to be undertaken over 2010–11, and appropriate actions to be taken subsequently. |
Appendix D: Audit Time Line
Audit planning — August 2008
On-site examination and off-site file review — March 2009
Clearance draft to management — September 2009
Management action plan finalized — October 2009
Report recommended by Audit Committee for Deputy Minister approval — October 23, 2009
Report approved by Deputy Minister — October 23, 2009
Footnotes
- Date Modified:
