Audit of the Moscow Immigration Program

Audit Report
Internal Audit and Disclosures Branch
Citizenship and Immigration Canada
October 2005

Table of Contents

• 1.0 Background
  • 1.1 Audit Objectives
  • 1.2 Audit Scope
  • 1.3 Audit Methodology
• 2.0 Conclusion
• 3.0 Observations and Recommendations
  • 3.1 Management Function
    • 3.1.1 Organization of Activities
    • 3.1.2 Performance Information
  • 3.2 CAIPS Management
  • 3.3 Program Integrity and Compliance
    • 3.3.1 Admissibility Framework
  • 3.4 Cost Recovery
    • 3.4.1 Physical Security
  • 3.5 Controlled Documents
    • 3.5.1 Quarterly Inventory Reporting to NHQ
  • 3.6 Human Resources Management
  • 3.7 Risk Management
• Appendix A: Management Action Plan
• Appendix B: Audit Time Line

1.0 Background

The Internal Audit and Disclosures Branch (IAD) of Citizenship and Immigration Canada (CIC) periodically audits the delivery of the immigration program in missions abroad. Mission audit locations are identified in consultation with the International Region (IR) and in accordance with the IAD’s Risk-Based Audit Plan for Assurance and Advisory Services.

The Moscow mission is a regional program centre (RPC) that offers all immigrant and non-immigrant services. It is responsible for applications from Armenia, Kazakhstan, Kyrgyzstan, Russia, Tadjikistan and Uzbekistan. Its satellite office, the Consulate General in St. Petersburg, provides joint immigration services. The RPC also processes refugee applications, primarily from Afghan nationals located within the Moscow processing area.

The Moscow mission has eight Canada-based officers, including the immigration program manager (IPM), a deputy program manager (DPM), two migration integrity officers (MIO), employees of the Canada Border Services Agency (CBSA) and four immigration officers. It also has two locally engaged program officers at the immigration program officer (IPO) level, and 30 additional locally engaged staff. Temporary duty officers and emergency employees are periodically engaged.

In 2003, the Moscow mission received 1,412 applications for permanent residence: 746 in the family class, 378 in the economic class, and 288 in the refugee class. During the same period, the mission also received 10,195 applications for a temporary resident visa, 322 for a student permit and 300 for a work permit. The acceptance rate for temporary resident applications finalized in 2003 was 84 percent. Cost-recovery revenues in Moscow during the 2003–04 fiscal year totaled $2.5 million.

The unusual delay in releasing this report is due primarily to the unforeseen departure of key audit staff during the examination and reporting phases of the audit. While the release of this audit report has been delayed, the significant findings were transmitted to officials at NHQ and the Moscow mission. The majority of corrective actions have already been taken to improve operations at the mission.

1.1 Audit Objectives

The objectives of the audit were to assess the effectiveness of the management control framework and the degree of compliance with legislation, policies and procedures associated with the delivery of the immigration program.

1.2 Audit Scope

The audit scope included the management of the mission’s immigration functions, management of the Computer-Assisted Immigration Processing System (CAIPS), program integrity and compliance, cost recovery, control documents, human resources management and risk management.

1.3 Audit Methodology

We carried out the audit of the immigration program at the Moscow mission between September 2004 and June 2005. The audit was conducted in accordance with generally accepted auditing standards set out by the Treasury Board Secretariat and the Institute of Internal Auditors.

In carrying out the audit, we reviewed files and documentation (both paper and electronic) and interviewed the Canada-based officers and locally engaged program officers and staff. In addition, we attended staff meetings, observed operational activities, and met with the ambassador, the management and consular officer and other mission staff with links to immigration operations.

2.0 Conclusion

We concluded that the IPM has an effective management control framework in place that is well suited to the environment of the Moscow mission and responsive to its changing conditions. Risk management practices were prevalent in the mission’s operations. We also found that an effective control framework extended to the safeguarding of cost-recovery revenue and control documents. Immigrant and non-immigrant programs were compliant with the applicable legislation, policies and procedures. We identified some areas for improvement that the IPM can implement locally.

3.0 Observations and Recommendations

3.1 Management Function

The focus for this line of inquiry was on the Moscow IPM’s activities and practices to manage operations. We conducted interviews with staff at all levels, reviewed documents and reports and observed processes.

We expected to find that the roles and responsibilities facilitate the efficient and effective management of the program, that the organization of activities and work processes supports the achievement of mission objectives, and that performance information is reported and used for decision making.

The IPM has more than (section removed) years of experience in the immigration program, and Moscow is his (section removed) assignment. He is backed up by an equally experienced DPM. The IPM maintains responsibility for all CIC and CBSA program activities and expenditures at the mission. The DPM is responsible for operations and human resources issues, and is directly responsible for the non-immigrant unit.

We found that roles and responsibilities were clearly communicated by management and understood by staff. The IPM attends weekly meetings with the head of mission (HOM) and other program directors at the embassy, and enjoys good relations with the mission administration and NHQ. Weekly management meetings involving the IPM, DPM, Canada-based officers (CBOs) and IPOs are held to share information and discuss emerging issues and challenges. The IPM initiated the development of the mission’s website and promoted the use of seminars for potential applicants, both to enhance client services. The IPM often responds personally to client enquiries as well. Overall, we determined that communications were a strong point in the management of the immigration program.

The operating environment presents a challenge in terms of accommodations, which are considered inadequate in many respects. Insufficient space results in staff using interview booths as work stations, and visitor and immigrant processing staff are housed in trailers separate from the clients they serve. In addition, the three-floor layout in the Immigration Annex building is not optimal. The IPM oversaw the recent renovation of the reception areas, which made the area more comfortable for clients, but other improvements are not foreseen until the embassy moves to new premises.

3.1.1 Organization of Activities

We noted there is a heavy reliance on the DPM for the workload in the Immigration program at the mission. This is partly attributable to the fact that the other four immigration officers are in the Foreign Service Officer Development Program (FSDP) and (section removed) of them are on a first posting. As well, the locally engaged staff did not have the same authority to make decisions as CBOs.

Our review of the decision maker statistics for cases finalized between July 1, 2003, and June 30, 2004, underlined the key role of the DPM in case processing. The review showed the DPM’s extensive involvement in immigrant processing for final decisions, and selection and security decisions. He also finalized many of the non-immigrant cases in that period. The DPM plays a large role in the supervision and training at the mission and is involved in the quality control over the casework prepared by other officers. Although the DPM is to be commended for the considerable contribution he makes to mission productivity, we are concerned about this reliance. The DPM will eventually be posted elsewhere and a succession and contingency plan would reduce the mission’s vulnerability in this area.

Recommendation 1

The IPM should have a plan in place to ensure that the DPM’s workload is risk-managed appropriately.

Management Response

The Moscow mission has recognized that the number of new officers (FSDP) on staff caused a significant caseload shift to the DPM. To alleviate this pressure and to prepare for the departure of the DPM, Moscow has already reorganized CBO staff to take advantage of the FSDP officers with more experience. These second-year officers have filled two newly created FS-2 positions: “Refugee Processing Supervisor” and “Immigrant Processing Supervisor.” A third position, “Non-Immigrant Processing Supervisor,”is seen as the next logical step, but will require training of a suitably qualified officer and reclassification to FS-2.

3.1.2 Performance Information

At the time of the audit, the mission was above target in its immigrant visa output, demonstrating an ability to reach and even exceed this key objective. We noted the mission had strategies to reach its goals, such as changes in its interview waiver policy, the development of new monitoring reports and the participation of the St. Petersburg satellite office in immigrant processing. We found that monthly statistical reports were initiated at the mission in 2003 and our review of the mission website showed the mission has excellent coverage of processing times and other standard client information.

We concluded that the mission was generating and using appropriate performance information to monitor the program and adjust to workload fluctuations, and to make estimates of processing times available to its clients and stakeholders.

3.2 CAIPS Management

The Computer-Assisted Immigration Processing System is essential for supporting mission operations and is a tool to distribute, process and monitor the caseload. As part of our examination of this area, we analysed decision maker statistics for cases finalized in the period July 1, 2003, to June 30, 2004. We expected that CAIPS-related equipment would be used properly, that staff would be trained, that adequate controls over CAIPS user accounts existed, that user profiles were in accordance with delegated authorities, and that CAIPS played a role in processing efficiency.

We found that the CAIPS manager was adequately trained to perform his functions effectively and that overall, CAIPS accounts were well controlled. All decisions entered over the period we examined were in compliance with ministerial delegated authorities.

We noted some best practices that used CAIPS functionality, which contributed to processing efficiency. File locator features were used extensively to allocate and monitor the caseload, particularly in the registry section, and good use was made of CAIPS features for admissibility screening, notably for visitor security checks.

We concluded that the CAIPS system was well managed and ran effectively and efficiently. We noted some areas for improvement and discussed them with mission staff while we were on site. We are satisfied that the mission management can deal with these areas locally.

3.3 Program Integrity and Compliance

We examined a sample of 30 immigrant and 20 non-immigrant cases finalized between July 1, 2003, and June 30, 2004. The sample represented all types of immigration processing undertaken by the mission.

Our examination revealed that applications processed by the mission were compliant with the legislation, regulations and policies associated with the immigration program. However, we noted some areas where the documentation of decisions and related procedures could be strengthened and we are satisfied that the mission will address them.

3.3.1 Admissibility Framework

Legislation stipulates that applicants must meet security, criminality and medical requirements in order to come to Canada. We expected the admissibility framework in place at the mission to ensure compliance with authorities, and staff to be able to obtain the information required to discharge their responsibilities.

We found that the IPM was ably assisted in security and criminality screening by the DPM and the senior MIO. The DPM provided oversight for all caseload screening whereas the MIO support unit provided intelligence, investigated or interviewed referred cases, and assisted in training CBOs. Moreover, the unit kept effective screening tools in its custody, used sound referral channels, and received excellent cooperation from key strategic partners.

The roles and responsibilities for screening were clear and effective. Each CBO made admissibility decisions, while the locally engaged staff (LES) provided support by applying their knowledge of the cultural, social and financial environment. We found that all delegated authorities for security and criminality decisions and temporary resident permits were appropriate over the review period. In addition, the mission provided accessible and standardized information about all admissibility requirements to its clients on its website, in local form letters and in application kits. In Moscow, medical admissibility is decided by the London Regional Medical Office. Our sample file review revealed no concerns regarding medical admissibility.

We concluded that an appropriate admissibility framework was in place to ensure the availability, use and integrity of admissibility information at the mission level.

3.4 Cost Recovery

We examined the controls surrounding the cost-recovery (CR) function at the mission by interviewing staff, reviewing files, documenting the process and work flows, and conducting tests to ensure the integrity of the CR program. We expected to find that the control framework for the CR program was adequate to ensure the proper recovery of immigration fees for services, and that duties and procedures were in compliance with the Department’s polices for cost recovery.

In general, we found the CR function was well managed and functioning as intended. However, we noted some areas where the CR control framework could be strengthened at the mission to improve efficiency and reduce risk. The majority of these were addressed while the audit team was on site.

3.4.1 Physical Security

Departmental policy stipulates that cost-recovery activities be conducted in an isolated area where only those performing such duties have access. In restricting access, the Department wishes to avoid potential compromise or theft of funds. We expected that cost-recovery duties at the Moscow mission would be conducted in a restricted-access area.

We found that the cost-recovery clerk (CRC) works in an open concept booth shared with staff at the front line of immigration reception. Thus, anyone entering the booth has access to the cost-recovery area. Discussions with several individuals at the mission, including the Foreign Affairs asset manager, occurred while on site to consider possible resolutions to this issue. All were determined to be inadequate or likely to result in an occupational health or safety hazard.

3.5 Controlled Documents

We examined the control framework for the controlled forms function at the Moscow mission. We interviewed staff, examined files, documented processes and work flows, and conducted tests to ensure the integrity of the controlled forms program. We expected to find that the control framework for the controlled forms program was adequate to ensure the safeguarding of controlled assets, and that duties and procedures were in compliance with the Department’s polices for controlled forms.

In general, we found the controlled forms function was well managed and functioning as intended. However, we noted some areas where the control framework could be strengthened at the mission to improve efficiency and reduce risk. The majority of them were addressed while the audit team was on site.

3.5.1 Quarterly Inventory Reporting to NHQ

At the end of each quarter, missions must report on their inventories of controlled forms to the forms management officer (FMO) at Information Management, NHQ. We expected that the FMO would bring any mathematical errors and discrepancies contained in the quarterly inventory reports to the forms control officer’s attention at the mission in order to clarify or correct the information.

(Section removed)

3.6 Human Resources Management

Our review of human resources management covered both CBOs and LES. We expected to find staff suitably trained to carry out their responsibilities, that annual performance appraisals were conducted, and that training needs were identified and addressed. For LES, we expected that they met the security requirements for their positions, and that they were aware of the Code of Conduct and the Conflict of Interest Guidelines. We conducted interviews with immigration staff, the mission security officer and the personnel officer, and we examined a sample of files that we chose randomly.

We found that the mission had a set cycle for performance evaluations. The files we reviewed were up to date. The IPM meets with each new LES to discuss the Code of Conduct and performance expectations. The file review confirmed that staff received the updated LES Handbook (April 2004) and that the training needs of staff were routinely identified. Training on a variety of topics is offered frequently. Security files are kept separately and our review verified that all LES had undergone a security clearance in the past five years. Staff is cross-trained and rotated regularly.

We concluded that human resources practices in the immigration program at the Moscow mission were sound.

3.7 Risk Management

Since May 2003, the IR’s risk management strategy emphasizes quality assurance and anti-fraud. We expected risk management practices to be applied at all appropriate levels and activities. At the Moscow mission, we observed numerous examples of risk management applied at all stages of operational delivery. These included supervision of staff, safeguards against conflicts of interest, random file assignment to officers, segregation of complementary duties, and a streamlined interview waiver policy. Moreover, our file review for the period July 1, 2003, to June 30, 2004 , showed a number of risk management practices in place for caseload management and work distribution.

The IPM informed us that quality assurance was a recent activity applied largely to immigrant cases subject to the Immigration and Refugee Protection Act requirements. The mission developed some tools for quality assurance interviews and file information verification. We found the tools well designed and suited to the clientele.

Anti-fraud activities such as telephone verifications and detection training for staff were concentrated in the Migration Integrity support unit at the mission. We found good collaboration and information sharing. Our file review noted that document verification was done on a case-by-case basis depending on the assessed level of risk. Overall, we concluded that appropriate risk management practices were applied at the mission.

Appendix A: Management Action Plan

Appendix B: Audit Time Line

Audit planning — September 2004

Site visit to Moscow mission — November 1–11, 2004

Clearance draft to IPM and IR for comments — June 1, 2005

Management Action Plan finalized — July 29, 2005

Report approved by Audit Committee — October 26, 2005