Audit of the Immigration Program at the Canadian Trade Office in Taipei

Audit Report
Internal Audit and Accountability Branch
Citizenship and Immigration Canada
July 2008

Table of Contents

• Acronyms used in this report
• 1.0 Introduction
  • 1.1 Background
  • 1.2 Audit Objectives
  • 1.3 Audit Criteria
  • 1.4 Audit Scope
  • 1.5 Audit Methodology
• 2.0 Audit Conclusions
• 3.0 Observations and Recommendations
  • 3.1 Management Framework
  • 3.2 Integrity of the Immigration Program
  • 3.3 Internal Control Framework
• Appendix A: Organizational Chart of the Canadian Mission in Taipei
• Appendix B: Detailed Criteria for the Audit
• Appendix C: Management Action Plan
• Appendix D: Audit Time Line

Acronyms used in this report

1.0 Introduction

The Citizenship and Immigration Canada (CIC) Risk-Based Audit Plan for 2007–2010 calls for the conduct of mission audits. The Canadian Trade Office in Taipei was selected in consultation with the International Region (IR) Branch at CIC national headquarters (NHQ). The selection was based on an assessment of the mission’s operations in relation to other offices, taking into consideration the processing volumes. The on-site field work was conducted October 15 to 19, 2007.

1.1 Background

1.1.1 Operations

CIC is responsible for the recruitment, selection and processing of foreign nationals who wish to come to Canada on a temporary or permanent basis and who will stimulate economic growth and enrich Canada's social and cultural environment. Within the Department, this responsibility has been assigned to the Operations Sector, which is divided into domestic and overseas operations. Overseas operations fall under the responsibility of the IR Branch, which accomplishes this through its network of visa offices (or missions) abroad. These are broken down into regional program centres (RPCs), full-service centres, satellites and specialized offices. RPCs and full-service centres are responsible for the delivery of the full range of immigration services for the countries they serve. The distinction between the two is that RPCs are responsible for overseeing satellite offices. Satellites and specialized program offices do not deliver the full range of immigration services.

The Taipei mission has been a full-service visa processing office since April 2003 and is responsible for the delivery of all immigration services. It is a medium-sized full-service centre, of which there are 32 located around the world. The Visa Section has 20 full-time employees: three Canada-based officers (CBOs), including one migration integrity officer (MIO), and 17 locally engaged staff (LES), including one designated immigration officer, one immigration program officer and four non-immigrant officers (NIO).

Except for the most junior clerical positions, there is minimal LES turnover. (Section removed) The office is comprised of four teams: the immigrant team, the non-immigrant team, the Migration Integrity Unit (MIU) and the registry/front counter team. The immigrant and non-immigrant teams are responsible for processing immigrant applications and non-immigrant applications, respectively. The MIU performs interdiction duties and the registry/front counter provides corporate support to the entire immigration program. Appendix A presents the Taipei immigration program organizational chart.

Taipei processes applications for permanent residence from citizens and residents of Taiwan. The mission also processes applications for temporary residence made in Taiwan. In 2007, the mission’s overall visa target for permanent resident applications was 2,580, including a target of 365 for federal investors, which is the third highest in the world. The inventory of applications awaiting a decision at the mission on November 2, 2007, was 7,555, of which approximately 62% were skilled workers. On the temporary resident side, the office issued 70,718 visitor visas, 2,003 student visas and 611 temporary worker visas in 2006. This represented the highest level of temporary resident visas (TRV) issued in the world by a visa office. Mission statistics for 2007, 2006 and 2005 are summarized in the Table 1 below.

Table 1. Taipei Statistics

1.1.2    Environmental Context

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

Taipei is one of the biggest visa-issuing offices within CIC’s network of overseas offices. The mission management indicated that it faced the following challenges:

• Large temporary resident volumes. For a number of years, Taipei has been CIC’s largest TRV-issuing office. The huge TRV volumes during the peak season of April to October put a particular strain on resources given the number of labour-intensive steps involved in TRV processing, such as creating a file, assessing each case, entering case notes and issuing the visa, including printing and affixing counterfoil labels and seals. Motivation of staff can be a challenge given the very high volumes and repetitive nature of the temporary resident work, especially during the peak seasons.
• Changing work. Taipei became a full-service visa office in April 2003. However, no adjustments were made to the structure of the office or the classification of the staff to take into account the additional processing for permanent resident applications until 2006. Permanent residence processing entails more complex lines of business and therefore requires more steps. This led to an uneven distribution of work and affected productivity.
• Staff reductions. A decline in the number of TRV cases in recent years resulted in LES cuts in 2006. The cuts also reduced the mission’s ability to add any resources to more complex lines of business, such as permanent resident processing and, in particular, federal investor processing. In 2008, Taipei has the second highest target for federal investor cases.
• Revised organizational structure. Since 2006, there have been several upward reclassifications of key LES as well as a reorganization of the office teams and the lines of authority. These changes provide a better structure and should allow for better and more effective management of the program. Adjustments are still occurring as LES take on enhanced job packages and, in some cases, learn totally new skills related to permanent resident processing.

1.2 Audit Objectives

The audit objectives are to assess:

• the management framework in place at the mission to administer the immigration program;
• the degree of compliance of practices and procedures with applicable legislation and policies associated with the delivery of the immigration program; and
• the internal control framework in place to support operational delivery at the mission and safeguard assets and revenues.

1.3 Audit Criteria

The criteria used in the audit are based on applicable Treasury Board and CIC legislation, policies and directives. The detailed criteria are presented in appendix B.

1.4 Audit Scope

The audit only involved operations at the Canadian mission in Taipei. The scope covered all significant aspects of CIC operations at the mission. This included the full range of immigrant and non-immigrant program activities, with associated financial and administrative components typically found in a full-service centre. The audit examined the activities of the mission from July 1, 2006, to the end of the on-site examination period of October 19, 2007.

1.5 Audit Methodology

Three lines of enquiry were undertaken: management framework, integrity of the immigration program and the internal control framework.

As part of our examination of the management framework, we interviewed immigration staff as well as other embassy staff with links to immigration operations; reviewed documents; observed processes; documented controls; tested information; and reviewed samples of management files to test for compliance.

As part of our examination of program integrity we examined all decisions related to permanent resident determination travel documents, temporary resident and permanent resident cases and temporary resident permits finalized over the period of July 1, 2006, to June 30, 2007, to test compliance with delegated authorities. We also conducted interviews with immigration staff and other embassy staff with links to immigration operations, we reviewed documents, we observed processes and we documented controls. The audit also examined a judgmental sample of 20 temporary resident cases and 20 permanent resident cases that were finalized between July 1, 2006, and June 30, 2007, in order to assess compliance with legislation, regulations and policy requirements of the case file. The sample size was judgmentally determined taking into consideration mission processing volumes. Individual sample cases were randomly selected from the population. The file review of sample cases was done to validate our observations from interviews, our observation of the procedures in place at the mission, and our documentation reviews.

As part of our examination of the internal control framework, we examined controls over the Computer-Assisted Immigration Processing System (CAIPS), controlled documents, cost recovery, and travel and hospitality expenditures. To this end, we interviewed immigration and other embassy staff with links to immigration operations, reviewed documents, observed processes, documented controls, tested information and reviewed samples of management files to test for compliance. Specifically, we examined CAIPS user profiles, tested CAIPS inventory controls, samples of controlled documents inventory transactions and cost-recovery revenue controls, and reviewed a sample of travel and hospitality claims to assess compliance with applicable legislation, policies and procedures and conclude on the state of controls in place.

The audit was conducted in accordance with the Government of Canada’s Policy on Internal Audit and the auditing standards set out by the Institute of Internal Auditors.

2.0 Audit Conclusions

The audit found that:

• the management framework was appropriate to manage the mission resources;
• the immigration program was compliant; and
• the internal control framework to support the operational delivery at the mission and safeguard assets and revenues was appropriate for CAIPS, for cost recovery and for travel and hospitality, but controls needed improvement for controlled documents.

Our detailed observations and recommendations are discussed in the next section of the report. Management’s responses and action plan, along with the proposed implementation dates for our recommendations, can be found in appendix C.

3.0 Observations and Recommendations

3.1 Management Framework

The audit examined seven areas of the management framework: governance and strategic direction; public service values and ethics; people/human resources management; client-focused service; risk management; results and performance; and learning, innovation and change management. We expected to find that accountabilities were appropriate, values and ethics were promoted and reinforced, the office was managed to ensure an effective work place, services delivered by the office met the requirements of its clients, risk management was employed by the office, information on results was gathered, used to make decisions and reported, and learning and development activities were in place.

The audit found that the management framework was appropriate to manage mission resources. Specifically, we found that governance structures were appropriate; values and ethics were promoted and reinforced; the human resources function was operating as intended; client service was managed appropriately; and risk management practices were appropriate given the mission’s operating environment. However, due to staff turnover, we found that at the time of our audit, the mission had lost some of its performance measurement capabilities. We also found that the mission management had taken steps to address this by establishing an appropriate course of action to reacquire this capability.

3.2 Integrity of the Immigration Program

The audit of program integrity examined the degree of compliance of practices and procedures with applicable legislation and policies associated with the delivery of the immigration program at the Taipei mission. To this end, immigrant and non-immigrant processing was examined. We expected to find that application decisions were adequately documented, that processes and procedures complied with the applicable legislation and policies, that appropriate controls were in place at the mission to ensure that admissibility requirements were met, and that delegated authorities for decisions were appropriate and in compliance with departmental policy.

The audit found that the immigration program at the mission was generally compliant. It also found that admissibility requirements were met and that decisions were entered by staff with delegated authority.

However, we found that the documentation of procedures was not done as consistently or as thoroughly as we would have expected. As part of our review of a sample of applications for permanent and temporary residence, we found that in some instances, the office was not notating some of the procedures that were carried out. We found that in 15 of 16 temporary visitor visa applications examined, there were no notes at all. In addition, document retention policies in place at the mission are such that many documents that would have been considered as part of the decision-making process are disposed of without being documented in the notes. Discussions with staff and further observation and review of operating procedures at the mission found that procedures were in place to ensure the completion of all steps. However, unless the mission retains certain documents or makes a note of them or other procedures, it may not be able to demonstrate that it completed all the processing steps.

The overseas processing manual states that officers should ensure that case notes not only document any decisions taken during case evaluation, but also clearly indicate the process the officer followed in reaching those decisions. The manual also sets out guidance on document retention and notes that while offices must ensure efficient space management, documents essential to the decision-making process should be retained. However, they may be disposed of, with certain exceptions, provided they are sufficiently documented in CAIPS notes. Good case notes are of critical importance as a record of what transpired at an interview or of the processing steps followed to reach a decision. Case notes are used to prepare refusal letters or to respond to enquiries, or as a record in the case of an appeal or a court challenge. Lastly, staff in other offices in the Department have direct access to individual electronic files and may call upon these records for various reasons.

The mission management was aware of the office’s weakness in documentation and had taken steps to address this issue prior to our arrival on site by issuing further guidance on new documentation procedures and offering training. We found that these new documentation requirements were reinforced through staff meetings and other office communications. While we acknowledge that these steps are likely to improve documentation procedures, we would encourage the mission management to further reinforce its documentation requirements.

Recommendation 1
Mission management must ensure that all processing steps are consistently documented in CAIPS notes.

Management Response
Taiwanese permanent resident cases present relatively few risks in terms of the integrity of documents or issues such as misrepresentation. While it is acknowledged that case processing must be well documented on each file, the low level of fraud in the Taipei office resulted, over time, in the failure of some staff to enter complete notes in CAIPS.

Taipei has historically been an extremely high-volume visitor visa office with a refusal rate of less than 1% and few enforcement problems with the temporary resident movement to Canada. During peak processing periods in the summer months, it is not unusual for each NIO to be expected to review and finalize one hundred or more temporary resident cases every day. In order for the clerks and NIOs to be able to process this high volume of cases, the practice developed to enter CAIPS notes only for temporary resident cases that were refused or where there was an unusual factor. In other, more routine cases, it was not considered necessary to enter notes to state that all the requirements had been met.

3.3 Internal Control Framework

As part of the audit of the internal control framework, we examined the controls in place over CAIPS, controlled documents, cost recovery, and travel and hospitality expenditures.

The audit found that the internal control framework to support the operational delivery at the mission and safeguard assets and revenues was appropriate for CAIPS, for cost recovery, and for travel and hospitality. However, the controls in place to safeguard controlled documents were weak and needed improvement. Our observations are discussed in the following sections.

3.3.1 CAIPS

As part of the audit of the internal control framework, controls over CAIPS were examined. We expected to find that there were appropriate controls in place to ensure the appropriate use of CAIPS at the mission and that CAIPS assets were safeguarded.

The audit found the control framework surrounding CAIPS to be appropriate. Specifically, we found that appropriate review was occurring to ensure that CAIPS use and access were controlled and in accordance with delegated authorities. We also found that inventory controls were appropriate to safeguard the CAIPS physical assets. Our testing in both areas found no issues, and it confirmed that the controls in place over CAIPS in Taipei were adequate and functioning as intended.

3.3.2 Controlled Documents

As part of the audit of the internal control framework, controls over controlled documents were examined. The audit expected to find that roles and responsibilities (duties) were appropriate and that there was an effective control framework in place for the custodianship, safeguarding and control of controlled documents.

Overall, the audit found that the controls in place to safeguard controlled documents needed improvement. However, progress had been made both prior to and during our on-site examination to improve these controls.

The audit found that some practices in place at the mission during the period examined may not ensure the safeguarding of controlled documents. We also found that the mission did not have tools in place to appropriately track document use. Consequently, we found several instances of errors in controlled document inventory transactions and of inventory reporting not being in accordance with policy. The audit notes that the mission had made some progress in addressing some of these issues in advance of our on-site examination and while the team was there. However, there was still room for improvement.

Guidance for controlled documents is fragmented over several policy manuals and responsibility overseas is divided between two branches at NHQ (the International Region and Information Management and Technologies). As part of our audit planning, and in light of our experience in past mission audits and in-Canada audits, we have identified NHQ management of this function as an area to be audited and we will be doing this in the near future.

Recommendation 2
The mission must ensure that controlled document procedures are appropriate to safeguard documents and that tools are in place to accurately record document use at the mission to facilitate inventory reporting in accordance with departmental policy.

Management Response
The Visa Section in Taiwan adheres to all document control procedures, with only CBOs authorized to access deep storage where controlled documents are stored. When removed from deep storage, controlled documents are at all times in the physical possession of authorized LES or forms control CBOs. During lunch breaks or when forms are not in the physical control of authorized LES, controlled forms are stored in a day safe whose access is restricted to only one LES at a time.

Controlled forms are signed out to an LES printing clerk and an LES sealing officer every morning after a physical count and a check of these forms. They are signed back in to the forms control officer (FCO) at the end of the day after counting and recording and reconciling the numbers of the forms used.

A quarterly report of the inventory is made at the end of every quarter, as required.

3.3.3 Cost Recovery

The mission accepts the payment of immigration fees in certified cheques for payments made in Canadian dollars or direct deposit for payments made in Taiwanese dollars. Cost-recovery revenue collected by the mission totaled $9.6 million and $8.7 million in fiscal years 2005–2006 and 2006–2007 respectively.

The audit expected to find that roles and responsibilities (duties) were in accordance with departmental policies for cost recovery, that adequate controls were in place to safeguard the cost-recovery revenues, and that an adequate monitoring regime was in place.

Overall, the audit found that the cost-recovery control framework at the mission was appropriate to ensure that funds collected were appropriately collected, properly accounted for and adequately safeguarded while in the Immigration Section. We found that roles and responsibilities were clear and appropriately assigned, that adequate physical controls were in place to safeguard the cost-recovery system, and that monitoring was occurring to ensure that funds collected were appropriate and properly accounted for.

3.3.4 Travel and Hospitality

Controls over travel and hospitality expenditures were examined as part of the audit of the internal control framework. The audit expected that controls would be in place to ensure that travel and hospitality transactions were processed in compliance with applicable policies and regulations.

The audit found that internal controls were in place to ensure that travel and hospitality expenditures were appropriate, but noted that some procedural practices should be adjusted to ensure that they are more accurately recorded in order to improve reporting.

Appendix A: Organizational Chart of the Canadian Mission in Taipei

Text version: Organizational Chart

Appendix B: Detailed Criteria for the Audit

Objective 1: Management Framework

The adequacy of the management framework will be assessed against the following criteria:

• Governance structures are in place to ensure that accountabilities are adequately discharged.
• Public service values and ethics are promoted and reinforced.
• The office is managed to ensure an effective workplace for staff to successfully contribute to the work objectives.
• Services delivered by the office reflect the requirements of its clients.
• Processes are in place at the office for the identification and development of risk mitigation strategies.
• Relevant information on results is gathered, used to make decisions and reported.
• The office employs learning and development activities to promote innovation and change management in order to learn from its performance.

Objective 2: Program Integrity

The degree of compliance of practices and procedures with applicable legislation, regulations and policies associated with the delivery of the immigration program will be assessed against the following criteria:

• Decisions are adequately documented, and the required supporting documentation is maintained.
• Delegated authorities for decisions are appropriate and in compliance with departmental policy.
• Appropriate controls are in place at the mission to ensure that admissibility requirements are met.

Objective 3: Internal Controls

The adequacy of the internal control framework in place to support operational delivery at the mission and safeguard assets and revenues will be assessed against the following criteria:

• CAIPS Management
  • Appropriate controls are in place for the management and use of CAIPS user accounts at the mission.
  • Appropriate controls are in place to safeguard CAIPS assets at the mission.

• Controlled Documents
  • Roles and responsibilities (duties) are appropriate for the custodianship, safeguarding and control of controlled documents.
  • Adequate controls are in place for the custodianship, safeguarding and control of controlled documents.

• Cost Recovery
  • Roles and responsibilities (duties) assigned and procedures performed are in accordance with departmental policies for cost recovery.
  • Adequate controls are in place to ensure that the physical environment is in place to safeguard the cost-recovery system.
  • An adequate monitoring regime is in place to ensure that controls are working and that funds collected are appropriately and properly accounted for and safeguarded while in the Immigration Section.

• Travel and Hospitality
  • Internal controls should be in place to ensure that travel and hospitality transactions comply with policies and regulations to protect against fraud, financial negligence and other violations of rules and principles.

Appendix C: Management Action Plan

Appendix D: Audit Time Line

Audit planning — August/September 2007

On-site examination — October 15 to 19, 2007

Clearance draft to IPM and IR for comments — February 20, 2008

Management action plan finalized — March 17, 2008

Report approved by Audit Committee — July 3, 2008