Audit of Governance – Quebec Region

Audit Report
Internal Audit and Accountability Branch
Citizenship and Immigration Canada
October 2009

Table of Contents

• Acronyms
• Executive summary
• 1. Introduction
  • 1.1 Background
    • 1.1.1 About the Department
    • 1.1.2 Quebec Region – organization
    • 1.1.3 Environmental context
  • 1.2 Audit objectives
  • 1.3 Audit criteria
  • 1.4 Audit scope
  • 1.5 Audit methodology
• 2. Audit conclusion
• 3. Observations and recommendations
  • 3.1 Governance framework
    • 3.1.1 Governance and strategic direction
    • 3.1.2 Accountability
    • 3.1.3 Values and ethics
    • 3.1.4 Results and performance
  • 3.2 Risk management
• Appendix A – Quebec Region Organization Chart
• Appendix B – Summary of Quebec Region Productivity versus CIC Network
• Appendix C – Detailed Audit Criteria
• Appendix D – Quebec Region Committee Structure
• Appendix E – Committee Membership
• Appendix F – Management Action Plan
• Appendix G – Audit Timeline

List of acronyms

Executive summary

The Risk-Based Audit Plan 2008-09 of Citizenship and Immigration Canada’s (CIC’s) Internal Audit and Accountability Branch (IAA) included an audit of governance of the Quebec Region. This audit focussed on governance and risk management frameworks in place. The Quebec Region was selected as a result of our analysis of operations and risk factors from an audit perspective. The on-site fieldwork was conducted on November 27 and 28, 2008.

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.

In simple terms, the Department is responsible for the selection and processing of applications to come to Canada on a temporary or permanent basis and for helping newcomers adapt to Canadian society and become citizens. The Operations sector, through the Assistant Deputy Minister, Operations, is responsible for the delivery of CIC programs. The Quebec Region is one of five domestic regions in the Operations sector that are involved in program delivery.

The objective of the audit was to assess the adequacy of the governance framework in the Region. The audit scope covered all significant aspects of Quebec Region operations and examined governance processes and risk management practices in the Region.

The audit concludes that the Region has an adequate governance framework in place to manage its operations. Governance processes partially met our expectations, as we identified some areas where practices should be strengthened. Risk management practices met our expectations

The key recommendations of the audit are that the Regional Director General do the following:

• Ensure that an operational plan is developed to guide the Region in achieving its priorities
• Improve the current regional intranet site to make it a more up to date and complete communication tool that is useful to all regional staff
• Document the results of risk monitoring on behalf of the Region to ensure that risk information is more up to date and that a common understanding exists in the Region

The report provides detailed observations and recommendations. Management responses and an action plan are included, along with proposed implementation dates for the recommendations.

1. Introduction

Citizenship and Immigration Canada’s (CIC’s) Risk-Based Audit Plan includes the conduct of audits of governance. These audits focus on governance and risk management frameworks in place. The Department’s Internal Audit and Accountability Branch selected the Quebec Region for audit as a result of an analysis of operations and risk factors from an audit perspective. The on-site fieldwork for the audit was conducted on November 27 and 28, 2008.

1.1 Background

In 2003, the Treasury Board Secretariat (TBS) introduced the Management Accountability Framework (MAF) to provide a basis for bilateral discussions between deputy heads and the Secretary of the Treasury Board to identify and agree on management issues requiring priority attention. This framework sets out expectations for management on how to manage towards the achievement of intended results.

1.1.1 About the Department

In simple terms, the Department is responsible for the selection and processing of applications to come to Canada on a temporary or permanent basis and for helping newcomers adapt to Canadian society and become citizens. Key statutes empowering the Department are the Department of Citizenship and Immigration Act (1994), the Immigration and Refugee Protection Act (IRPA, 2001) and the Citizenship Act (1977).

Through the Assistant Deputy Minister, Operations, the Operations Sector is responsible for the delivery of CIC programs. The Quebec Region is one of five domestic regions in the Operations sector that are involved in program delivery. Domestically, this translates into five operational business lines: the Immigration Program, the Temporary Resident Program, the Refugee Program, the Integration Program and the Citizenship Program. All of these programs are discussed in greater detail in the following sections.

1.1.1.1 Immigration Program

Permanent residents

IRPA lists four specific classes (live-in caregiver, permit holders, protected persons and spouses/common-law partners) under which a person may apply for permanent residence from within Canada.

Any foreign national in Canada who does not meet the criteria to be eligible 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.

Applications for permanent residence in Canada are submitted through the Case Processing Centre in Vegreville (CPC-V). When CPC-V cannot process or conclude on a case, it is referred to a CIC local office in one of the five domestic regions for processing, based on specific referral criteria. In most cases, all fees are paid by the applicants when they send their applications to the CPC, but local offices accept payment in the form of cash, credit card or money order.

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 domestic regions. The selection of entrepreneurs is done overseas, while the monitoring of conditions imposed on entrepreneurs is done by inland offices in domestic regions. Entrepreneurs are granted permanent residence but must meet the conditions imposed on them for a period of at least one year. Once the conditions have been met, the entrepreneur is required to apply to have the conditions cancelled.

Currently there are both pre-IRPA and post-IRPA cases being monitored in Canada. Pre-IRPA cases have two years to meet the terms and conditions, whereas post-IRPA cases have three years to do so.

Permanent resident cards

Since IRPA came into effect on June 28, 2002, new permanent residents of Canada have been provided with a PR card within weeks of becoming permanent residents. New immigrants selected under IRPA are automatically processed for a PR card as part of their application for permanent residence. Permanent residents who were landed before the new Act came into effect (pre-IRPA) are required to apply for a PR card.

Applications for PR cards are sent to CPC Sydney, Nova Scotia (CPC-S), where they are processed. A separate Card Production Facility produces the actual card. Once the application has been processed and the card is produced, it is sent directly to the permanent resident in the case of “post-IRPA” applicants, while PR cards of “pre-IRPA” applicants and PR card renewals are sent to the local CIC office for distribution to the client. The local CIC offices in the regions are responsible for distributing PR cards to clients as well as photo retakes and signature corrections for cards with errors. CPC Sydney also refers cases to the local office for residence obligation decisions whenever the applicant’s eligibility for permanent residence is questionable and follow-up with the applicant is required.

1.1.1.2 Temporary Resident Program

Temporary residents

Temporary residents include workers, students, visitors and temporary resident permit holders. Individuals may apply to extend or change their status as a temporary resident in Canada beyond the initial period of stay that was granted.

Applications for temporary resident extensions are processed by CPC-V, and only those cases requiring further clarification are referred to local offices in the regions.

1.1.1.3 Refugee Program

Inland refugee processing

A claim for refugee protection can be made at any port of entry or any CIC office in Canada. The role of the CIC officer (when the claim is presented inland) 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, while referring ineligible persons 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 towards permanent residence in the same fashion as all other applicants for permanent residence.

Pre-removal risk assessment (PRRA)

The PRRA process is triggered by a removal order issued by the CBSA. A CBSA officer sends a notification regarding PRRA to the individual facing the execution of a removal order, 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.

PRRA is used to evaluate the risk that faces an individual upon returning to his or her country. Any person awaiting removal from Canada who alleges risk of persecution, torture or cruel and unusual treatment or punishment if returned to his or her country of nationality or former residence will not be removed prior to a risk assessment.

PRRA decision-makers are responsible for assessing the risk an applicant would face upon return to his or her country of origin. If the PRRA officer determines that there are no risks for the individual to return to his or her country, the person will be removed. In the case of a positive determination, PRRA offers the same protection as the IRB process.

1.1.1.4 Integration Program

Because of agreements between the federal government and certain provinces, there is variation in the extent to which each domestic region delivers these programs.

The Canada-Quebec Accord is the most comprehensive of the provincial agreements. Signed in 1991, it gives Quebec selection powers and control over its own settlement services. Canada retains responsibility for defining immigration categories, setting levels, and enforcement. The Canada-Quebec Accord specifically gives Quebec sole responsibility for selecting all independent immigrants and refugees abroad who are destined for Quebec. Those selected by the province receive a Certificat de sélection du Québec (CSQ). The federal government ensures that statutory admission requirements (medical, criminal and security checks) are met before issuing a visa.

1.1.1.5 Citizenship Program

Applications for 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 CPC-S, which ensures that all required documentation and fees are submitted with the application. Once the application is processed, it is forwarded onto the local CIC office in the region closest to where the applicant lives. The local office reviews the application to determine whether the applicant meets residence, criminality and security requirements. In addition, the office administers language and knowledge tests and, when necessary, arranges interviews with the citizenship judge. 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 citizenship.

1.1.2 Quebec Region – organization

Quebec Region comprises a regional headquarters and a network of local offices that offer a variety of services across the province. Appendix A shows the Region’s organization chart, while Table 1 below provides an overview of the Region by management area.

• ^{[Note 1]} Salary Management System for 2008–09 year end
• ^{[Note 2]} Financial system (SAP) for 2008–09 year end

The CIC structure in the Quebec Region includes a regional headquarters, centralized Operations offices in Montréal and offices in Québec, Sherbrooke, Gatineau and Trois-Rivières.

Regional headquarters comprises the following directorates, which support regional operations:

1. Office of the Regional Director General
2. Executive Services and Strategic Planning (ESSP) – Handles a wide range of activities, but leads the planning and accountability cycle for the Region.
3. Communications – Supports the Region’s communications needs.
4. Finance, Administration and Public Rights – Supports regional operations by providing integrated corporate services in the areas of finance, administration and privacy.
5. Information Technologies and Telecommunications – Provides information technology services to the Region.
6. Human Resources – Provides human resources services to the Region, including the Call Centre.
7. Programs and Partnerships – Provides policy expertise and refugee claims assistance. It also provides support and advice on all programs except settlement, which is not a CIC responsibility in the Quebec Region. It provides service through the Multiculturalism Program and the Client Services Unit, including the Temporary Foreign Worker and Temporary Foreign Student units.
8. Operations – Provides a full range of immigration and citizenship services to the public except settlement as described in Section 1.1.1 – About the Department.

1.1.3 Environmental context

This section of the report highlights some of the operating environment issues facing the Region. They are presented here for information purposes only and are not in any particular order.

The Quebec Region strives to provide quality immigration and citizenship services to everyone in its service area. In so doing, it must balance the achievement of operational results with sound risk management to ensure that program integrity is maintained. Balancing the budget in a context of uncertainty over B-base budget funding is also a significant challenge.

From an organizational standpoint, in addition to the core services provided by the CIC Call Centre, a wide range of customer services tailored to the needs of the general public is offered in the Quebec Region. For instance, the Temporary Foreign Student Unit provides an advisory service for our partners in the education sector that is designed to improve service to students. In addition, the Temporary Foreign Worker Unit makes recommendations on the issuance of work permits before worker arrival for all ports of entry in the Quebec Region and answers employers’ questions on hiring foreign workers.

The Region’s Client Services Unit also works to maintain a strong partnership with constituency offices, non-governmental organizations (NGOs) and other partners. It arranges regional tours to raise awareness among stakeholders from federal constituency offices and to provide sound complaints management. Further, as a member of the advisory committee on service quality, the Region works with NGOs, the Canadian Bar Association, the Association québécoise des avocats et avocates en droit d’immigration (AQAADI), the Ministère de l’Immigration et des Communautés culturelles [Quebec department of immigration and cultural communities] and the United Nations High Commissioner for Refugees in order to improve service quality.

The Quebec Region also has effective partnerships with the CBSA, the IRB, Justice Canada, Service Canada and the Royal Canadian Mounted Police.

From an operations standpoint, reducing the backlog (particularly on the Citizenship side) and processing times, and thereby meeting service standards, is a constant concern. Also, turnover is high because of retirements and interdepartmental staff movements.

The Quebec Region has a major challenge in the day-to-day delivery of immigration services under the Canada-Quebec Accord on Immigration. The Accord gives Quebec significant selection powers and full responsibility for integration services. Respecting the Accord requires ongoing consultation, liaison and partnership to ensure effective delivery of programs and services. The Region must ensure that the Accord is implemented seamlessly from an operational standpoint.

Because the Montréal area is a bilingual region for the purposes of the Official Languages Act, promotion of and respect for bilingualism is also a key issue.

1.2 Audit objectives

The objective of the audit was to assess the adequacy of the governance framework in the Region.

1.3 Audit Criteria

The criteria that were used in the audit are based on the Management Accountability Framework produced by the Treasury Board of Canada, as well as relevant Treasury Board and CIC legislation, policies and directives. The detailed criteria for the audit are presented in Appendix C.

1.4 Audit scope

The audit scope consists of activity in the Quebec Region under two lines of enquiry. The audit covered all significant aspects of Quebec Region operations and examined governance and risk management activities in the Region.

1.5 Audit methodology

The audit covered two lines of enquiry: governance processes and risk management practices.

As part of our examination of the governance framework and risk management, we interviewed staff, reviewed and analysed key governance and risk documentation and documented processes.

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. Audit conclusion

We found that the Region had an adequate governance framework in place to manage operations. Specifically, we found that:

• Governance processes partially met our expectations. We identified some areas where practices should be strengthened.
• Risk management practices met our expectations.

Our detailed observations and recommendations are discussed in the following sections of the report.

3. Observations and recommendations

3.1 Governance framework

The audit examined four areas of governance: governance and strategic direction, accountability, values and ethics, and results and performance. We expected to find that a clearly articulated plan was in place, accountabilities were appropriate, values and ethics were promoted and information on results was gathered, used to make decisions and reported.

Overall, the governance processes in place in the Region partially met our expectations.

3.1.1 Governance and strategic direction

3.1.1.1 Operational plans

In reviewing governance and strategic direction, we expected to find that operational plans would be in place to achieve objectives.

We found that, while the Region has an Integrated Business and Resource Plan, no formal operational plan has been developed. The Integrated Business and Resource Plan is a high level document that outlines the Region’s priorities, and those priorities are in line with the Department’s strategic outcomes and priorities. The plan is produced as part of the departmental integrated corporate planning process. It does not provide details on which activities will be undertaken to achieve the priorities, by whom, when, or how achievement will be measured.

The Region considers the management performance agreements of the Regional Director General and the directors to be the operational plan. However, the agreements are not specific enough in terms of performance measures, timelines and accountabilities to be used to monitor the Region’s progress toward its goals.

An operational plan, or work plan, is needed for guidance, accountability, monitoring and measurement of progress on the Region’s priorities. This observation also impacts our conclusion in Section 3.1.2 – Accountability.

3.1.1.2 Communication protocols

As part of our review of governance and strategic direction, we also expected to find that protocols would be in place for internal and external stakeholders.

We found that appropriate communication protocols existed for internal and external stakeholders. However, one of the means of internal communication needs improvement.

Externally, there is ongoing communication with key partners through meetings and working groups. Some of these meetings are formalized (required by the Canada-Quebec Accord) and have agendas and minutes; others are informal and are held when needed. The communication protocols with external partners are adequate for the Region’s needs.

Internally, communication is disseminated through management committees and down through the directorates via meetings. Other means of communication are also used (e.g. e-mail).

One of the means of communicating policies, procedures and other information internally across the Region needs improvement. The regional intranet site is out of date and incomplete. For example, there is no recent strategic planning information on the General Directorate and Strategic Planning folder. As well, the folder for one of the most important directorates in the Region, Operations, is almost empty. The regional intranet site could be both a tool for communication and a repository of information that is useful to all regional staff. The Region is looking into either updating or replacing the current intranet site but has not yet made significant progress in this area.

3.1.2 Accountability

In reviewing accountability, we expected to find that a clear organizational structure was established and documented, and that processes would exist to ensure that accountabilities and responsibilities are clearly delegated and communicated and adequately discharged.

A clear organizational structure is in place in the Region to manage operations (see Appendix A). Furthermore, the Region had supplemented this structure with the establishment of a corporate committee structure (see Appendix D). The structure, membership (see Appendix E), terms of reference and accountabilities of the main committees of the Quebec Region are appropriate.

In our review of processes to support accountabilities, we looked at the orientation information available on the Region’s intranet site, and at the training and workshop schedules. We also interviewed management to determine how accountabilities were ensured. Performance agreements, training plans, targets and regular monitoring reports are used to help staff to understand their accountabilities and responsibilities. However, we observed some weaknesses in the processes for ensuring that accountabilities and responsibilities are clearly delegated and communicated and adequately discharged. First, many links in the orientation material on the intranet site are broken, which means that users cannot access useful information. This is a similar observation to that in Section 3.1.1.2 – Communication Protocols. Second, as discussed in Section 3.1.1.1 – Governance, the Region has no operational plan, which is a key element for ensuring that accountabilities and responsibilities are clearly delegated and communicated and are adequately discharged.

In short, the Region has some processes in place to ensure that accountabilities and responsibilities are clearly delegated and communicated and adequately discharged.

3.1.3 Values and ethics

As part of our audit of values and ethics, we expected to find that management promoted values and ethics.

We found that management supported the promotion of values and ethics in the Region. The Region has a values and ethics champion, who has formed a values and ethics committee and led the development of a draft framework and a communications plan. The champion has also presented values and ethics cases for discussion at management meetings. These cases are then discussed with staff during regular team meetings.

We found some gaps or weaknesses, similar to those outlined in Section 3.1.1.2 – Communication Protocols that need to be rectified. For example, the information on values and ethics on the regional intranet site is buried and is not readily visible. In addition, there is no information on the site with respect to the communications plan or the draft framework; and there is no evidence of regular meetings of the values and ethics committee. No meeting notes have been posted on the intranet site.

3.1.4 Results and performance

We expected to find that processes would exist to ensure that planned results and outcomes are linked to organizational objectives, that management has identified appropriate measures linked to planned results, and that management monitors performance against planned results and makes any necessary adjustments.

The Region developed a monthly report, in the form of a spreadsheet, for tracking processing numbers, time (where applicable) and inventories. This report is discussed at regular management meetings. The Region also produces monthly and quarterly Workload, Inventories and Priorities reports and provides them to Headquarters. Financial position and human resource management information is also captured and shared within the management team periodically. This information is reviewed by the management team during various management committees, and adjustments are made accordingly.

While the Region does monitor its performance by collecting and reporting statistics, without an operational plan in place, it is unclear whether all appropriate measures have been monitored and reported on.

3.2 Risk management

As part of the audit of regional governance in the Quebec Region, we examined the adequacy of risk management processes and practices in place to support the achievement of the Region’s objectives. We expected to see that processes were in place to identify, assess, mitigate and monitor risks, that management appropriately communicated risk and risk management strategies to key stakeholders and that planning and resource allocation considered risk information.

We found that risk management practices met our expectations. Each year, at the beginning of the business planning process, the Region identifies risks that could affect its operations, assesses their potential impact on achievement of objectives and develops mitigation strategies. Risks are monitored throughout the year, but the monitoring process is not always formally documented. Regional management holds many different meetings throughout the year at which operational issues and risks are discussed. These include meetings of the Executive Committee, the Management Committee, the Case Management Committee, bilateral and trilateral management meetings, and team meetings. Not all meetings have formally documented minutes, so risk monitoring is not always documented. In addition, there appears to be no central repository for risk information. Such a repository would allow for more systematic analysis and monitoring and for the transmission of corporate risk knowledge in the event of staff turnover.

The Integrated Risk Management Framework produced by the TBS and the Integrated Risk Management – Reference Guide produced by CIC set the expectation that managers:

• identify risks and opportunities in the environment
• assess the risks to estimate the probability of occurrence and the likely impact
• prioritize risks in terms of importance to allow the organization to establish risk tolerance levels and identify when management action is required
• develop a plan of action to reduce risks in areas that exceed risk tolerance levels
• monitor and review the environment to ensure that risk information is still current

While our audit found that risk management practices in the Region do meet these expectations, the process could be further strengthened by documenting the monitoring and review process in a central repository, as this would allow for more systematic assessments, improved prioritization and development of mitigation strategies. As the Region manages as a team, this would also ensure that a common understanding exists with respect to not only the areas deemed to be of interest, but also related topics such as risk tolerance in the Region. It would also serve as a means to retain corporate risk knowledge in the Region in the event of staff turnover.

Appendix A – Quebec Region Organization Chart

As of March 5, 2009

 

Text version: Organizational Chart

Appendix B – Summary of Quebec Region Productivity versus CIC Network

• ^{[Note 1]} Data is as per calendar year
• ^{[Note 2]} Data is for renewed cards and does not include first-time applicants
• ^{[Note 3]} Data is as per fiscal year (April 1 to March 31)
• ^{[Note 4]} Data is up to September 30, 2008
• ^{[Note 5]} Data is up to July 31, 2008
• ^{[Note 6]} Percentage of domestic total

Appendix C – Detailed Audit Criteria

Appendix D – Quebec Region Committee Structure

Text version: Committee Structure

Appendix E – Committee Membership

Appendix F – Management Action Plan

Appendix G – Audit Timeline