Audit of The Administration of the Resettlement Assistance Program

1.0 Introduction

The CIC risk-based audit plan is produced to coordinate the work of the Internal Audit and Accountability Branch on a multi-year basis and is designed to support the provision of an annual audit review on the state of governance, risk management and internal controls within the Department. The 2008–2009 risk-based audit plan identified the need for an audit of:

• the administration of RAP, and
• iCAMS – Phase II.

Due to the subject matter of these audits and the resources available within the IAA, the two audits have been combined for efficiency purposes. We also carried out an audit of the Settlement programs during the same period.

1.1 Background

In collaboration with its partners, CIC’s mission is to build a stronger Canada by:

• Developing and implementing policies, programs and services that:
  • facilitate the arrival of people and their integration into Canada in a way that maximizes their contribution to the country while protecting the health, safety and security of Canadians;
  • maintain Canada’s humanitarian tradition by protecting refugees and people in need of protection;
  • enhance the values and promote the rights and responsibilities of Canadian citizenship; and
  • reachout to all Canadians and foster increased intercultural understanding and an integrated society with equal opportunity for all, regardless of race, ethnicity and religion.
• Advancing global migration policies in a way that supports Canada’s immigration and humanitarian objectives.

CIC is responsible for the selection and processing of applications from people wishing to come to Canada on a temporary or a permanent basis (including refugees), and helping newcomers adapt to Canadian society and become citizens. Key legislation empowering the Department are the Department of Citizenship and Immigration Act (1994), the Immigration and Refugee Protection Act (2002), the Citizenship Act (1977) and the Canadian Multiculturalism Act (1988).

1.1.1 Resettlement Assistance Program Background

RAP is a contribution program that falls under CIC’s second strategic outcome, namely to provide protection to refugees and others in need of resettlement.Once they are in Canada, RAP provides income support and a range of immediate and essential services for government-assisted refugees. RAP funding is divided into two activities, as follows:

• Funds provided to protected persons (Income Support) – These funds are used to support a refugee’s income for up to one year or until that person becomes self-sufficient, whichever comes first. Support levels are based on provincial social assistance amounts and national RAP standards. In exceptional circumstances, income support can be extended up to an additional 12 months.
• Funds provided to service provider organizations (SPOs) – Contribution agreements are established to engage SPOs to deliver initial services to certain categories of protected persons arriving in Canada. These services include airport reception, temporary accommodation, basic orientation and links to broader-based services, and they are provided for the first four to six weeks after the recipient’s arrival.

RAP services are provided in all the provinces and territories across Canada except Quebec (see Appendix A). All settlement and resettlement assistance services in the province of Quebec are governed by the Canada-Quebec Accord, signed in 1991, under which Quebec receives an annual federal grant and has the sole responsibility for selecting immigrants (except refugees) and providing settlement services, including resettlement assistance, to newcomers.

Total contributions funding available to SPOs for the Resettlement Assistance Program (outside of Quebec) has grown from approximately $40.4 million in 2003–2004 to $56.5 million in 2009–2010. Most of the RAP funds have gone to income support (approximately 75% in the last three fiscal years).

Table 1: Actual Spending for 2007–2008 to 2009–2010

1.1.2 CIC Organization with Respect to the Resettlement Assistance Program

Within the Department, the responsibility for RAP is shared between the Strategic and Program Policy Sector and the Operations Sector. At the time of our audit, the Refugees Affairs Branch within the Strategic and Program Policy Sector developed and oversaw the implementation of policies and programs for the resettlement of refugees from abroad, and the Operational Management and Coordination (OMC) Branch established operational guidelines and standards to support the national implementation of programs in the domestic regions. It also shares the same governance committee structure as the Department’s other grants and contributions (G&C) programs, such as the settlement programs. However, these responsibilities were revised after our audit and are described below in section 3.1.

Regional and local CIC offices manage the program, in the case of income support, by determining the level and duration of support, processing payments, monitoring clients, re-evaluating as a result of changes in the client’s status, and reporting potential fraud or recovering overpayments when detected.

Under RAP, service provider contribution agreements are established to deliver immediate services directly to government-assisted refugees within their first four to six weeks in Canada. SPOs enter into CAs with local Citizenship and Immigration centres to deliver these services on the Department’s behalf except in the province of Quebec, as mentioned above.

1.1.3    Previous Audits

In 2001, the Office of the Auditor General reported that CIC’s financial and management controls of its settlement contributions program (including RAP) were adequate, but that on-site monitoring of SPOs and financial training for program officers required improvement. The audit also noted that while the Department had not been measuring the results of the program, it had started to make progress in capturing data for this purpose.

The IAA Branch within CIC then conducted audits of the Resettlement Assistance Program as follows:

• RAP audit in 2005
• iCAMS audit in 2007

1.1.4    Environmental Context

This section of the report highlights some of the environmental issues which the program faces. They are presented here for information purposes only and do not reflect any particular order.

• Introduction of the updated Treasury Board (TB) Policy on Transfer Payments (effective October 1, 2008) following the report of the Independent Blue Ribbon Panel Review which called for greater flexibility, a risk-based approach and a reduction of the administrative burden;
• Evolving roles and responsibilities from departmental reorganizations add complexities to roles and responsibilities in terms of program design, delivery and ownership;
• Funding levels for RAP have not changed since 1998, the first year in which RAP support was provided to resettled refugees;
• The growth of programs to support the integration of newcomers to Canada has caused CIC to focus more on the development of these programs;
• Greater needs of refugee clients from diverse backgrounds have placed greater demands on services;
• Increased interest of the provinces and other non-traditional stakeholders (e.g., municipalities) in areas related to immigration creating a more complex operating environment;
• SPOs delivering services to meet the needs of not only clients of CIC programs but those of other departments and agencies, which are not necessarily the same people;
• Increased public scrutiny and larger and more vocal community and stakeholder advocacy groups; and
• Stand-alone information systems used to manage the programs, which do not share information and in some instances duplicate or contradict information in other systems. These systems, designed to serve individual purposes, face limitations when used to manage the programs.

1.2 Audit Objectives

The objective of the audit was to assess the adequacy of:

• the governance framework for RAP;
• the performance measurement framework for RAP;
• internal controls in the administration of resettlement transfer payment programs to ensure compliance with applicable policies; and
• progress toward the implementation of recommendations from previous RAP audits.

1.3 Audit Criteria

The criterion for the audit was the Management Accountability Framework for the governance framework and performance framework lines of enquiry. The criterion used to determine the adequacy of internal controls was derived from the following sources:

• Financial Administration Act;
• TB Policy on Transfer Payments;
• TB policies on financial management;
• CIC policies and manuals on settlement and RAP; and
• CIC financial policy manuals.

The recommendations, management action plans and responses provided as part of our regular follow-up activity constituted the criteria for our last line of enquiry, the enhanced follow-up of our previous audit recommendations in this area. The detailed criteria for the audit are presented in Appendix C.

1.4 Audit Scope

The audit scope was comprised of resettlement activity in 2008–2009 for all lines of enquiry except follow-up, which reviewed the activity from the time of the recommendation to the end of this audit. As part of our audit’s examination of internal controls, we visited the regions where CIC is responsible for delivery to examine how contributions and income support payments are managed.

1.5 Audit Methodology

The audit included four lines of enquiry: governance framework, performance measurement framework, internal controls and an enhanced follow-up.

The audit of the governance and performance measurement frameworks involved interviews with senior management and reviews of relevant documents primarily at national headquarters (NHQ) and in the Ontario Region. The file review (described below) was also used to gather information in support of our findings on performance measurement.

We reviewed samples of contribution agreements and income support files to examine the controls in place and ensure compliance with the TB Transfer Payments Policy, as well as applicable departmental policies. The results of these file reviews were also used to support our review of performance measurement and our follow-up work. In total, we looked at 13 CAs and 204 income support files. The actual samples were selected through a judgmental approach as follows:

• CA: The sample was determined by choosing the offices across the country that managed the largest CAs in each respective domestic region. Agreements were chosen based on size and accounted for 60% of committed RAP CA funds for the offices visited.
• Income support: The sample of income support payments was drawn randomly from the income support payments issued by offices selected as part of our sample selection process for contribution agreements. A 10% sample of income support files was selected from files where a payment was made to an applicant during the sample period. The 10% threshold was used as this was the expected level of monitoring of income support files, established by management, to be done on an annual basis.

The follow-up to recommendations involved interviewing NHQ and regional staff to determine the actions taken, as well as obtaining documents to validate the information gathered during interviews. The file review described above also gathered information to ensure that follow-up actions had taken place.

An audit of the settlement program was conducted concurrently and is referred to periodically throughout this report.

The audit was conducted to be in accordance with the Government of Canada’s Policy on Internal Audit and the professional practice standards of the Institute of Internal Auditors.

1.6 Audit Risk Assessment

The audit risk assessment was based on reviews and analysis during the planning phase and took into account the applicable elements of the Treasury Board Secretariat’s Management Accountability Framework and the CIC Core Management Controls Framework. This assessment identified the following key risks:

• Governance, accountability and risk management: There is a risk that governance structures and accountabilities may not be clearly defined, and that risk management practices may not be fully in place for the management of these programs.
• Performance management: There is a risk that performance information for the settlement programs may not be complete and available to inform managerial decision making.
• Internal control: There is a risk associated with the control framework as these programs have grown substantially since our last review.

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