Final Audit Report - Audit of Kyiv Immigration Program

Final Audit Report
Citizenship and Immigration Canada
Internal Audit and Disclosures
March 2004

Table of Contents

• 1. Background
• 2. Audit Findings and Recommendations
  • 2.1 Management Function
  • 2.2 Managing the Caseload
  • 2.3 Program Integrity and Compliance
    • 2.3.1 Document Retention Policy
  • 2.4 Cost Recovery
    • 2.4.1 Monitoring
  • 2.5 Control Documents
    • 2.5.1 Quarterly Inventory of Immigration Control Forms
    • 2.5.2 Deep Storage Security for Immigration Control Forms
  • 2.6 Human Resources Management
  • 2.7 Risk Management and Quality Assurance
• 3. Conclusion
• Appendix A: Management Action Plan

1.0 BACKGROUND

We carried out the audit of the Immigration Program at the Kyiv Mission between October 27 and November 6, 2003.

The objectives of the audit were to assess the strength of the management control framework and the degree of compliance with legislation, policies and procedures associated with the delivery of the Immigration Program.

The audit scope included the management function, caseload management, program integrity and compliance, cost recovery, control documents, human resources management, and risk management and quality assurance.

In carrying out the audit, we reviewed files and documentation and interviewed the Immigration Program Manager (IPM), Canada-based officers (CBOs) and locally engaged staff (LES). We also met with the Head of Mission, the Mission Consular Officer and several other Department of Foreign Affairs and International Trade (DFAIT) representatives with links to Immigration operations.

The Kyiv Mission is a full-service centre and offers all immigrant and non-immigrant services. The Immigration Program employs three CBOs, including the IPM (who started at the Mission in late August 2003), one locally engaged officer (LEP) and nine LES.

Ukraine’s difficult economic conditions raise concerns about fraud, corruption, criminality and misrepresentation and about their impact on the Mission’s operating environment. Cost-recovery revenues in Kyiv during the 2002‑03 fiscal year were largely received as cash and totalled $1.9 million. The immigrant visa target for 2003 was 2,155, and 67 percent of this consisted of skilled workers. In 2002, Kyiv received 178 student cases, 272 temporary worker cases and 5,994 visitor cases in the temporary resident program.

2.0 AUDIT FINDINGS AND RECOMMENDATIONS

2.1 MANAGEMENT FUNCTION

The Immigration Program at the Kyiv Mission was well managed by the new IPM, who, within a few months, had initiated a number of measures to improve operations and strengthen controls. These included looking at the cost recovery, control forms and Computer-Assisted Immigration Processing System (CAIPS) management support functions to ensure that the necessary training, tools and controls were in place; and beginning the process to staff a crucial local officer position that has been difficult for the Mission to stabilize. The IPM attended a formal IPM training workshop at national headquarters (NHQ) in early December 2003.

Kyiv’s work plans and objectives reflect the planning priorities of Citizenship and Immigration Canada’s (CIC’s) International Region (IR) and the Department’s strategic objectives. Progress reporting is done on work-plan objectives. Good working relations exist with other embassy programs, outside stakeholders and the CIC IR Geographic Desk. The IPM monitors operational productivity closely and is developing strategies to ensure that the targets for 2004 are met. One of these strategies is to review all staff responsibilities and update job descriptions.

One challenge which is facing the Immigration Program at the Kyiv Mission and which is beyond the Program’s control is the physical limitations of its office environment. This has presented difficulties for the Program for a number of years, because the planned expansion of the DFAIT chancery has been delayed. For example, the waiting room and interview booth capacity does not fully accommodate the volume of client traffic. Efficient processing of client files is hindered by the cramped conditions in the chancery basement, where the Immigration LES work. The IPM’s concerns about the physical office environment were reflected in the 2003-04 IR Immigration Management Plan. We were informed that DFAIT is continuing negotiations to address the physical structure needs of the Immigration Program.

Immigration Program management in Kyiv is well aware of the program’s challenges and priorities, and it demonstrated the capability, with the IR’s support, to address them. We have no recommendation with respect to the management function; however, we share the Immigration Program staff’s concerns about their inadequate office environment.

2.2 MANAGING THE CASELOAD

We reviewed the CAIPS management function and found that it was competently administered. Controls such as user profiles and authority levels over the staff’s visa-processing ability were appropriate. The IPM and the CAIPS Manager had a good knowledge of their CAIPS responsibilities; moreover, the IPM received some CAIPS statistical report training at the December IPM workshop.

The work processes were generally appropriate to the working environment and client base. Our file review indicated that immigrant and non-immigrant cases were very well managed. A well-established system was in place to ensure that all applicable admissibility procedures were properly completed. Document verification was thorough and was integrated into routine processing. In addition, the range of form letters for immigrant processing was appropriate.

We did, however, observe some potential for improving case processing through the following: enhancing waiting room space for clients, examining alternatives to having all categories of clients come to the office at once, reviewing job responsibilities with a view to redistributing tasks, and staffing the two vacant office positions. Plans were in place to undertake improvements in all these areas.

2.3 PROGRAM INTEGRITY AND COMPLIANCE

Overall, the sample we reviewed for immigrant and non-immigrant cases met integrity and compliance requirements. The decisions in all visa cases we examined for the period from September 1, 2002 to August 31, 2003 complied with delegated authorities. The selection criteria were applied consistently, and decisions met requirements. The case notes were generally clear and organized, and showed that staff had a good understanding of procedures. All cases in our sample had processing times similar to or better than the global mission averages.

Although, at the time of our audit, it was too early for us to assess how the Mission was applying the new selection criteria for skilled workers under the Immigration and Refugee Protection Act (IRPA), the limited information available at the time was positive.

2.3.1 Document Retention Policy

Our review of files and work processes revealed that the Kyiv Mission was following the pre-IRPA guidelines on retaining paper documentation on immigrant files. Although we found no inappropriate consequences of this, we are concerned that these pre-IRPA guidelines have not been included or replaced in the IRPA operations manuals. Consequently, officers assessing IRPA cases do not have an accurate reference to help them decide what documentation to retain, return to the client or destroy. IR Operational Coordination is aware of this need for guidelines and plans to review the document retention policy so that missions will be able to apply a consistent approach.

Recommendation

(1) Information Management Branch, in co-ordination with IR, should incorporate a document retention policy into the CIC Overseas Processing Manual.

Management Response

(1) Management agrees with this recommendation, and appropriate action is being taken to remedy the situation. The new guidelines on the document retention policy will be incorporated into the Overseas Processing Manual (OP1) by June 30, 2004 for all missions to follow.

2.4 COST RECOVERY

Our audit showed that the cost recovery (CR) function at the Kyiv Mission is generally functioning well. We found no indication of incorrect fees, loss of public funds or misuse of documents. However, we suggested some measures which could improve controls and reduce risk and which could be implemented at the mission level.

2.4.1 Monitoring

One issue to be resolved is the lack of periodic monitoring of the CR function to ensure that revenue transactions correspond with the number of visa services and that they are being properly accounted for. The Cost Recovery Officer (CRO) is required to monitor the CR process to ensure that all Immigration Program fees are properly accounted for. Our audit found that periodic verification of Immigration deposits was not performed because the DFAIT Mission Accountant did not provide formal bank deposit forms or excerpts from the general ledger.

In addition, the monitoring procedures outlined in the 2001 joint DFAIT/CIC message on revenue controls were not carried out nor was any other form of monitoring. However, the new IPM and new Mission Consular Officer had identified this weakness and agreed to implement revenue monitoring procedures immediately.

Recommendation

(2) The CRO should carry out periodic monitoring to reconcile the daily totals of funds collected with a copy of the monthly transactions from the Integrated Management System (IMS).

(3) The IPM should ensure that appropriate periodic monitoring procedures are carried out to determine whether the Immigration cost-recovery fees collected are in line with the amounts that the Mission should be recovering for the period.

Management Response

(2) The new IPM, who had recently arrived at the Kyiv Mission before the audit, has undertaken to work with the Mission Administration Officer (MAO) to make all the necessary corrections to the verification and accounting of daily reports. Action has been taken, and the IPM has briefed the CRO. Procedures are now followed dutifully.

(3) The IPM has undertaken to follow the instructions sent by DFAIT in June 2003 on the monthly verification of CAIPS reports and IMS transactions. This process is under way.

2.5 CONTROL DOCUMENTS

Establishing appropriate management controls over control documents such as visitors’ visas and immigration seals is essential at the mission level. Since her arrival, the IPM has made a concerted effort to improve the processes for managing control documents. We have suggested some measures that could be implemented at the mission level to further improve controls and reduce risk. However, two control weaknesses need attention.

2.5.1 Quarterly Inventory of Immigration Control Forms

At the time of our audit, we confirmed that the quarterly inventory reports (IMM 5392B) for 2003 were based on estimates rather than on actual amounts obtained from taking a physical inventory. The IPM had noted this weakness earlier and brought it to our attention. The practice of using estimates instead of actual amounts creates the risk of documents going missing and remaining undetected. Because of these inaccuracies in quarterly inventory reporting, we could not carry out our standard audit test to reconcile the inventory of control forms on hand with the last quarterly report. Our audit testing of the serial number sequence for control forms over several months revealed no gaps in the control forms issued. Finally, we found that the Kyiv Mission’s quarterly inventory reports showing rounded amounts (estimates) were not queried by NHQ Forms Management or reported to the IR Geographic Desk.

Recommendations

(4) The Forms Control Officer (FCO) should take an inventory of all control forms on hand as soon as possible and ensure that an accurate count is used to complete the quarterly inventories of control forms.

(5) The IPM should periodically monitor the quarterly inventory process to ensure that the procedures followed result in the use of actual amounts.

(6) NHQ Forms Management should monitor quarterly inventory reports (IMM 5392B) for rounded amounts, especially the reports of missions where the FCO has changed recently.

Management Response

(4) In January 2004, the FCO completed an accurate physical inventory under the supervision of the IPM. Corrective action has been taken. The quarterly reports compiled by the FCO now reflect actual physical inventory of control forms.

(5) This matter has been discussed with the IPM, and appropriate action has been taken to ensure that procedures are followed. The IPM has discussed the matter with the FCO. Random checks have been instituted and are performed by the IPM.

(6) Forms Management, which is responsible for implementing this recommendation, has taken action and will work closely with the FCO in Kyiv and all others in Immigration missions abroad to ensure uniformity in accounting for control forms.

2.5.2 Deep Storage for Immigration Control Forms

During our audit, we observed that the deep storage (security) cabinet for immigration control forms was accessible to an unauthorized CBO because of shared deep storage space between DFAIT and Immigration. Control forms in deep storage are to be kept in a high-security zone in a secure filing cabinet to which only the FCO, the CBO/FCO backup, the Mission Security Officer and the IPM have access.

Recommendation

(7) The IPM should arrange to have the deep storage of immigration control forms accessible to only the FCO, the CBO/FCO backup, the Mission Security Officer and the IPM.

Management Response

(7) Management agrees with this recommendation. Corrective action has since been taken to ensure that only authorized staff have access to the Immigration deep storage safe. The safe combinations have been changed, and only designated officers know them.

2.6 HUMAN RESOURCES MANAGEMENT

We reviewed human resource management practices relating to training and development, annual performance appraisals, security requirements and conflict of interest guidelines for LES.

Generally, training needs were identified as part of the performance appraisal process or as operational requirements arose. At the time of the audit, the IPM was participating in the development of an overall training plan for the Mission. LES appraisals were updated in the spring and summer of 2003. The Mission Security Officer performs the LES security screening and confirmed that Immigration LES records were up to date. LES were informed of the Code of Conduct and Conflict of Interest guidelines and were required to sign that they understood the guidelines.

The Kyiv Mission has had two incumbents in the Non-Immigrant Officer position since the creation of this position two years ago, and at the time of the audit, the position had been vacant for several months, reducing the Mission’s decision-making capacity and efficiency. The IPM recently launched a competition to fill the vacancy. She anticipates that the process will be completed within the next few months.

2.7 RISK MANAGEMENT AND QUALITY ASSURANCE

Our audit examined the Kyiv Mission’s risk management and quality assurance practices. Ukraine’s difficult economic conditions have raised concerns about fraud, corruption, criminality and misrepresentation. Accordingly, the Mission performs telephone, Internet and/or written checks of all material documentation that immigrant clients submit. It also regularly verifies the documents of many visitor clients and can track whether non-immigrant clients are repeats. Both of these practices are time-consuming and labour-intensive, but they are considered essential to program integrity. Risk management practices were also in place in the allocation of non-immigrant processing tasks and access to CAIPS functions for LES.

In addition, as part of its quality assurance initiatives, in 2001, the Kyiv Mission began conducting employer site visits in cases where fraud was suspected. Fraud was found in most suspected cases. The IPM plans to further enhance quality assurance by conducting more document verifications and site visits. The Mission has an effective set of internal procedures and well-trained staff to carry them out. For example, our file review showed that verification of the education and experience documents of skilled worker immigrants was standard practice.

3.0 CONCLUSION

We concluded that the management control framework in place at the Kyiv Mission has been strengthened through a number of actions taken by the IPM, with the support of staff. We also found that decisions regarding immigrants and non-immigrants complied with the applicable legislation, policies and procedures. Continued attention needs to be paid to ensuring that appropriate monitoring occurs in the control documents and cost-recovery functions.

Appendix A: Management Action Plan