Audit of Expanding Market Opportunities in CFS (AU1702)
Audit Branch
Natural Resources Canada
Presented to the Departmental Audit Committee (DAC)
December 15, 2016
TABLE OF CONTENTS
EXECUTIVE SUMMARY
INTRODUCTION
Budget 2012 provided $240M over five years to help the forest industry innovate, diversify, and expand markets. An additional $43M was made available through Budget 2015 to extend funding until the end of fiscal year (FY) 2017/18. Two programs within the Canadian Forest Service (CFS) of Natural Resources Canada (NRCan) were selected to deliver on this initiative: the Expanding Market Opportunities Program (EMO, the Program) and the Forest Innovation Program. The focus of the audit was on the EMO Program.
The objectives of the EMO Program are to diversify Canada’s forest products export markets; expand wood use in the North American non-residential and mid-rise construction; and position Canada as a preferred source of sustainable forest products. The intended outcome of the Program is to increase economic opportunities for the Canadian forest sector.
The EMO helps to increase and diversify market opportunities for Canada's forest sector by enabling stakeholders to deliver activities that promote broader use of Canadian wood products. Serving a wide range of stakeholders in offshore and North American markets, the activities include hands-on technical training and demonstrations of Canadian wood-frame construction techniques, branding, and outreach as well as technical support to address market access and regulatory issues limiting the trade of Canadian wood products. The Program also supports an industry presence within key offshore markets in Shanghai, Beijing, Tokyo, Seoul, London, and Toulouse. In addition, EMO supports a trade commissioner in the Middle East and is cost-sharing market development activities across India with the government of British Columbia. Under the North American component of the Program, EMO contributed to the construction of two tall wood buildings (greater than 10 storeys) and associated research via the Tall Wood Building Demonstration Initiative, and supports the WoodWORKS! program, providing education and awareness activities and technical support to promote the use of wood in non-residential applications.
The annual expenditures of the Program ranged from $19.2M in FY 2012-13 to $13.5M in FY 2015-16. The majority of EMO funding is used to allocate contribution agreements to the Program’s proponents. Eligible recipients include not-for-profit forest products associations, manufactured housing associations, provinces, provincial crown corporations, and not for profit organizations engaged in forest product research.
The objective of the audit was to provide reasonable assurance on the overall adequacy of the management processes supporting EMO operations, in accordance with the Program’s terms and conditions, and in compliance with relevant aspects of the TBS Policy on Transfer Payments, the Financial Administration Act (FAA), and relevant departmental requirements.
STRENGTHS
Overall, management exercises oversight to enable the achievement of EMO objectives and priorities through the Program’s assessment committees, as well as through the leadership of the Program’s management and senior management. Control processes have been implemented to ensure consistent and equitable treatment of Program participants in the solicitation, assessment, and approval of project applications. The Program has also established standardized processes for program management, performance measurement, and reporting.
AREAS FOR IMPROVEMENT
Opportunities exist to review current measures in place relating to the identification and management of potential or perceived conflict of interest; strengthen the planning process for significant amendments to contribution agreements; and streamline and improve the measurement of Program performance reporting and the monitoring of service standards. Furthermore, the Program should collaborate with CIOSB to ensure compliance with NRCan and Government of Canada Information Management and Information Technology requirements.
INTERNAL ADUIT CONCLUSION AND OPINION
In my opinion, overall, the Program has established management processes to support its delivery. Opportunities exist to strengthen certain elements of the Program planning, monitoring and reporting processes.
STATEMENT OF CONFORMANCE
In my professional judgement as Chief Audit Executive, the audit conforms with the Internal Auditing Standards for the Government of Canada, as supported by the results of the Quality Assurance and Improvement Program.
Christian Asselin, CPA, CA, CMA, CFE
Chief Audit Executive
December 15, 2016
ACKNOWLEDGEMENTS
The audit team would like to thank those individuals who contributed to this project and particularly employees who provided insights and comments as part of this audit.
INTRODUCTION
Budget 2012 provided $240M over five years to help the forest industry innovate, diversify, and expand markets. An additional $43M was made available through Budget 2015 to extend funding until the end of fiscal year (FY) 2017/18. Two programs within the Canadian Forest Service (CFS) of Natural Resources Canada (NRCan) were selected to deliver on this initiative: the Expanding Market Opportunities Program (EMO, the Program) and the Forest Innovation Program. The focus of the audit was on the EMO Program.
The objectives of the EMO Program are to diversify Canada’s forest products export markets; to expand wood use in the North American non-residential and mid-rise construction; and, to position Canada as a preferred source of sustainable forest products. The intended outcome of the Program is to increase economic opportunities for the Canadian forest sector.
The Program is comprised of the following two components:
- the Offshore Component (approx. 58% of EMO Program expenditures); and
- the North American Component (approx. 42% of EMO Program expenditures). This includes research and information products to address science and information gaps for the Canadian Boreal Forest Agreement (CBFA) (approx. 9% of EMO Program expenditures).
The EMO Offshore Component of the Program aims to assist Canadian wood producers diversify and expand export opportunities for their products in traditional and emerging oversea markets such as Europe, Japan, China, South Korea, India, and the Middle East. Funded activities of this component include the provision of in-market staff and offices, demonstration buildings, trade show participation, education and promotional missions as well as technical support to address market access, building code, and regulatory issues in offshore markets.
The EMO - North American Component of the Program supports activities to further awareness of the benefits of wood products and technologies in non-residential applications such as schools, shopping centers, and hospitals. The Program funds initiatives aimed to further the application of wood products in modern construction and to foster the commercialization of innovative wood-based building solutions for structures greater than 10 stories in order to expand North American market opportunities.
The CBFA, signed in 2010, is intended to secure the health and long term future of the Canadian forest sector, by balancing environmental responsibility and economic interests. The Research and Information Products to Address Science and Information Gaps for the CBFA Component of the EMO Program provides financial support for the implementation of CBFA science and outreach programs, and for complementary science and research work.
The majority of EMO Program funding is provided through contribution agreements, with cost-sharing arrangements that fund up to 50% of eligible project costs (up to 100% for contributions to market studies, demonstration projects, and the CBFA). Eligible recipients include not-for-profit forest products associations, manufactured housing associations, provinces, provincial crown corporations, and not for profit organizations engaged in forest product research.
The annual expenditures of the Program ranged from $19.2M in FY 2012-13 to $13.5M in FY 2015-16. In FY 2015-16, EMO Program expenditures included $11.5M in Grants and Contributions. The remaining $2M consisted of Salary and Employee Benefit Plan ($1.2M) and Operation & Maintenance expenses ($0.8M).
AUDIT PURPOSE AND OBJECTIVES
The objective of the audit was to provide reasonable assurance on the overall adequacy of the management processes supporting EMO operations, in accordance with the Program’s terms and conditions, and in compliance with relevant aspects of the Treasury Board Secretariat’s (TBS’) Policy on Transfer Payments, the Financial Administration Act (FAA), and relevant departmental requirements.
Specifically, the audit assessed whether:
- Adequate governance processes have been established for the EMO Program;
- Design and delivery of the EMO Program is adequate, in accordance with the Program’s terms and conditions, and in compliance with key aspects of the NRCan and TBS policies on transfer payments, and the Financial Administration Act (FAA); and
- EMO Program planning, monitoring, and reporting processes have been established and are operating as intended to inform senior management decision making.
AUDIT CONSIDERATIONS
A risk-based approach was used in establishing the objectives, scope, and approach for this audit engagement. A summary of the key underlying areas of risk taken into consideration includes the following:
- The EMO governance structure, which includes roles, responsibilities, and accountabilities, may not effectively support the Program to achieve its objectives;
- Adequate processes may not be in place to support management of Program activities;
- Perception of a lack of fairness and transparency in the administration of the Program may have a negative impact on the Program; and
- Information necessary for informed decision making and reporting may not be available or provided to NRCan senior management in a timely manner.
SCOPE
The audit focussed on relevant processes and activities of the EMO Program, including governance and oversight; program management; and monitoring and reporting. The audit focussed on the period from January 1, 2014 to September 30, 2016.
The Audit of Expanding Market Opportunities was approved by the Deputy Minister as part of the Risk-Based Audit Plan for 2016-2017.
APPROACH AND METHODOLOGY
The audit methodology was based on the TBS’ Policy on Internal Audit and the Government of Canada’s Internal Auditing Standards, and included the following:
- Interviews with key personnel with respect to the management of EMO and related activities;
- Review of key documents, including Program authority documents, policies, directives, guidance, contribution agreements, planning, monitoring, and reporting information as well as performance measurement data;
- Detailed examination of a sample of contribution agreements, including related agreement governance and management processes; and
- Review of the recently completed Evaluation of Forest Products Market Access and Development by the Strategic Evaluation Division and exclusion of areas covered by the Evaluation to minimize duplication of efforts, wherever possible, between the audit and evaluation functions.
The conduct phase of this audit was substantially completed in September 2016.
CRITERIA
Please refer to Appendix A for the detailed audit criteria. The criteria guided the audit fieldwork and formed the basis for the overall audit conclusion.
FINDINGS AND RECOMMENDATIONS
PROGRAM GOVERNANCE
Summary Finding
Management exercises oversight to enable the achievement of EMO objectives and priorities, primarily through the Program’s assessment committees as well as through the leadership of the Program’s management and senior management. Opportunities exist to clarify appointment tenure and COI declaration requirements for external assessment committee members; and to ensure proper segregation of roles, per NRCan's Departmental Policy on Transfer Payments.
Supporting Observations
Effective governance processes allow for management to exercise oversight and enable the achievement of program objectives and priorities. Governance bodies provide leadership and oversight, while also monitoring the overall state of a program, including compliance with the Treasury Board Secretariat’s (TBS’) Policy on Transfer Payments and relevant NRCan policies. The EMO Program mainly provides funds to proponents through contribution agreements, in order for these proponents to perform work enabling the achievement of the EMO Program’s objectives and priorities. The EMO Program has established two regional governance committees, to assess proposals for Eastern and Western Canada. These committees, including subject-matter experts, review the proposals’ activities and costs, and ultimately provide their recommendations and advice to program management as to which of these activities should be funded for a specific fiscal year. The program management then reviews the committees’ suggestions. Following this review, the program management recommends the proponents’ activities and total funding for Assistant Deputy Minister, Canadian Forestry Service (ADM CFS) approval, through a memorandum for signature. Once the ADM CFS has reviewed and approved the memorandum, the contribution agreements are signed by the proper delegated authority. If required, the contribution agreements are reviewed and endorsed by the Grants and Contributions Center of Expertise, NRCan’s Legal Services Unit, and the Transfer Payments Review Committee prior to their approval.
The audit noted that external members, such as industry advisors, representatives of a Provincial Crown Corporation, and provincial members, were present on the Program’s assessment committees. Collaborative efforts with external stakeholders are common for programs across the Department to benefit from the additional expertise and perspectives that such partners can provide. While beneficial, these collaborative activities can present an inherent risk of real, apparent, or potential conflict of interest (COI). NRCan employees are required to fill out an assessment to help them identify any real, apparent, and potential COI in the exercise of their duties with any activities external to the Department. Additionally, they must agree to comply with both the Values and Ethics Code for the Public Sector and the NRCan Values and Ethics Code. The audit observed; however, that while a COI clause is contained in their contracts, external committee members were not required to fill out an assessment regarding COI, and that there was no fixed tenure for committee membership. In a context where the number of potential proponents is limited, this situation could enhance the risk of familiarity with the proponents, and could ultimately result in a potential COI, perceived or real. While the audit did not identify any specific cases of wrongdoing regarding the distribution of contributions, the audit noted one instance where there could be an appearance of a COI.
NRCan has a departmental policy on transfer payments to support Program compliance with related TBS policies and to provide consistency in the management of Grants and Contributions (Gs&Cs) programs across the Department. The Policy requires a segregation of duties between the review of an application/proposal and the approval/signing of a funding agreement. However, the audit noted that for two out of the 12 contribution agreements reviewed, the NRCan signatory of the contribution agreement was also a member of the evaluation committee responsible for reviewing and evaluating the proposal. This practice is non-compliant with the NRCan Departmental Policy on Transfer Payments.
RISK AND IMPACT
Situations where a COI exists or is perceived to exist, may compromise stakeholder relationships. Similarly, improper segregation of roles may result in the Program’s non-compliance to departmental policies.
RECOMMENDATIONS
- It is recommended that the Assistant Deputy Minister Canadian Forest Service (ADM CFS) formally define appointment tenure and conflict of interest (COI) declaration requirements for external members as well as ensure compliance with the NRCan's Departmental Policy on Transfer Payments by segregating the review and approval functions.
MANAGEMENT RESPONSE AND ACTION PLAN
Management agrees. In response to recommendation 1:
The program will develop and implement an Evaluation Committee Terms of Reference that will clarify appointment tenure and Conflict of Interest declaration requirements for external review committee members. The program will also ensure appropriate segregation of review and approval functions.
Position Responsible: Director General, Policy, Economics and Industry Branch, CFS
Timing: for implementation by the 17/18 Project Evaluation Committee meetings (January 2017)
MANAGEMENT PROCESSES
Summary Finding
Overall, management processes have been implemented to ensure consistent and equitable treatment of Program participants in the solicitation, assessment, and approval of project applications. Opportunities exist to strengthen the planning process for significant amendments to contribution agreements; and to consult with the CIOSB for guidance regarding the use of the shared online application system currently in place to ensure compliance with NRCan and Government of Canada Information Management and Information Technology requirements.
Supporting Observations
The audit sought to determine if control processes were in place to ensure consistent and equitable treatment of applicants; information provided in the solicitation, assessment, and approval of project applications was adequately safeguarded; and contribution agreements were consistently developed through a process tailored to address recipient and departmental requirements, in accordance with the Program’s terms and conditions, the TBS Policy on Transfer Payments, the Financial Administration Act (FAA), and relevant departmental policies.
Contribution Agreements and Amendments
The audit sampled and reviewed twelve out of a population of 54 contribution agreements, covering the three fiscal years within the scope of the audit to determine whether the agreements were administered in accordance with key aspects of Government of Canada policies. Overall, it was determined that the Program has implemented management process to ensure consistent and equitable treatment of Program participants in the solicitation, assessment, and approval of project applications, in accordance with key aspects of Government of Canada policies. However, the audit found one instance where a significant amendment was made in the last quarter of the fiscal year to fund a larger portion of a project’s costs than was initially approved. Upon further inquiry with Program personnel, it was determined that the purpose of the amendment was to provide additional funding to cover a larger proportion of expenses than initially committed, thereby enabling the proponent to preserve funding from other sources for planned expenses beyond NRCan’s funding horizon.
The amendment was reviewed and supported by the Grants and Contributions Centre of Expertise and by NRCan’s Legal Services Unit. Although this practice is permitted within the Terms and Conditions of the Program and the TBS Policy on Transfer Payments, it would have been preferable to identify such needs earlier in the Program year to provide more time to review options for the allocation of additional funds to proponents and to consult with subject-matter experts if required.
Multi Year Funding Agreements
The audit noted that a limited number of proponents participated in the Program, consisting of industry trade organizations and forest products associations. Market development work is inherently long-term and complex, spanning multiple years. However, the program design requires applicants to prepare and submit proposals annually for these long-term projects. The audit noted that the timelines for the submission, review, assessment, and approval of proponent projects occur in a condensed time period. This situation places considerable administrative burden on both Program and proponent personnel. The adoption of multi-year funding agreements, where appropriate, may provide program personnel and proponents with some relief from the administrative compliance burden currently being experienced. This consideration is consistent with findings from the recently completed Evaluation of Forest Products Market Access and Development by the Strategic Evaluation Division.
Service Level Agreement with a Program Delivery Partner
The vast majority of the EMO Program funding applications are received and managed through an online funding application system. The functionalities of this system have been recognized by the Department as a best practice to solidify partnerships. This system is also used for the management of proponent progress reporting for approved projects throughout each funding year. The responsibility for the management and maintenance of this online system has been shared with a Program delivery partner since fiscal year 2009-10. At that time, NRCan and the Program delivery partner contracted a third party assurance provider to perform an independent review and evaluation of the online project application and reporting system. NRCan and the Program delivery partner also entered into a Letter of Agreement to formalize their arrangement regarding the hosting, ongoing maintenance, and support of the online system. NRCan’s contribution towards the annual expenditures for the ongoing maintenance and support for the joint online application system are covered under a separate Letter of Agreement, renewed on an annual basis.
The Corporate Information Office and Security Branch (CIOSB) within NRCan is mandated to perform threat assessment and security scans of all NRCan websites, portals, and applications, including those housed and managed by third party service providers. CIOSB provides guidance, support, and services to help the Department meet its Information Management (IM) and Information Technology (IT) responsibilities. The audit expected that the EMO Program would have consulted with the CIOSB prior to contracting with a third party for the online system review. As well, CIOSB has the requisite expertise to provide appropriate guidance and review of any Letters of Agreement that include maintenance and security components relating to IT and/or IM. This practice would provide greater assurance that such agreements adequately address departmental and Government of Canada IM/IT requirements in a cost-effective manner. The audit noted; however, that the EMO Program did not consult with CIOSB with regards to the online system review or the technical components within the Letters of Agreement.
RISK AND IMPACT
In the event that significant amendments are not identified early in the fiscal year, the Program’s solicitation and project applications processes may be negatively impacted and may not allow sufficient time to review all funding options.
Not consulting with CIOSB for guidance on technical IM/IT aspects of program delivery may result in the use of IT systems that do not address departmental and Government of Canada IM and IT requirements.
RECOMMENDATIONS
- It is recommended that the Assistant Deputy Minister Canadian Forest Service (ADM CFS) ensure that sufficient planning and monitoring processes are established for the early identification and management of significant amendments to contribution agreements.
- It is recommended that the ADM CFS consult with the Corporate Information Office and Security Branch (CIOSB) for guidance regarding the use of the online application system currently in place to ensure compliance with NRCan and Government of Canada Information Management and Information Technology requirements.
MANAGEMENT RESPONSE AND ACTION PLAN
Management agrees. In response to recommendation 2:
The program will develop planning and monitoring processes to ensure the early identification and management of significant amendments to contribution agreements.
Position Responsible: Director General, Policy, Economics and Industry Branch, CFS
Timing: December 2017
Management agrees. In response to recommendation 3:
The program will consult with the CIOSB for guidance with respect to the use of the online funding management system.
Position Responsible: Director General, Policy, Economics and Industry Branch, CFS
Timing: Prior to entering into the next Letter of Agreement for system maintenance (July 2017)
PROGRAM PLANNING, MONITORING AND REPORTING
Summary Finding
The EMO Program has established processes for program management, performance measurement, and reporting. Opportunities exist to improve the timeliness of program reporting to senior program management to support informed decision making; increase the frequency of program service standards reporting to senior management; and to strengthen and streamline performance measurement.
Supporting Observations
Program Planning
The audit sought to determine whether the Department has adequate and effective controls in place, including monitoring of program performance and timely reporting to senior program management to facilitate informed decision making. The audit also examined program activities to determine compliance to relevant Government of Canada and departmental policy instruments.
The audit found that the EMO Program performs sufficient program planning on an annual basis. Program personnel create detailed briefings for both the Offshore and the North American component of the program. These briefings are a valuable source of information for senior management to consider when determining annual funding decisions for program applicants. The audit noted; however, that the ADM CFS approved annual proponent funding decisions prior to receiving these briefing materials regarding the annual program work plans. Management advised the audit team that the ADM CFS did receive the necessary information through informal debriefs prior to approving the annual funding decisions.
Program Performance Measurement and Reporting
Providing an accurate, reliable flow of program information to senior program management is critical to facilitate informed program decision making. The TBS Policy on Transfer Payments requires each Gs&Cs program to design a Program Management Strategy Framework (PMSF) to facilitate the effective performance measurement of each program. This Framework is one component of the Program Risk Management Strategy (PRMS). The PMSF identifies the indicators required to monitor and gauge the performance of a program. Its purpose is to support program managers in continuously monitoring and assessing the results of programs as well as the efficiency of their management; making informed decisions and taking appropriate, timely action with respect to programs; providing effective and relevant departmental reporting on programs; and ensuring that the information gathered will effectively support an evaluation. The Policy requires that a new or revised PRMS be designed and implemented at the beginning of each funding cycle for all Gs&Cs programs administered by the federal government.
The audit observed that the PMSF for the EMO Program was incomplete. The Framework contained 58 performance metrics; however, only three of these measures were assigned a performance target to assess actual program performance. The audit also noted that the 58 performance measures far exceeded the number of measures employed by other programs in the Department, and that improvements were required for the use of the PMSF. Although performance data was collected from proponents in the online system, the performance data was not always aligned with the PMSF. In addition, there was no evidence that the performance data collected from the proponents was synthetized or communicated to program management in order to support the administration of the Program as required by the TBS Policy on Transfer Payments requirements. The audit identified many alternate program metrics reported through a variety of mechanisms serving many different internal departmental stakeholders and needs. However, these metrics were not aligned with those stated in the Program’s Terms and Conditions and the Program Risk Management Strategy, which is a requirement of the TBS Policy on Transfer Payments. Previous audits have identified similar issues in other programs within the department and additional attention may be warranted to strengthen this area.
Program Service Standards Measurement and Reporting
Service standards commit the Government of Canada to provide understandable and consistent levels of service to applicants and recipients. They state the level of performance that program proponents can reasonably expect from federal departments under normal circumstances. The TBS Policy on Transfer Payments requires federal organizations to establish service standards for all new and continued Gs&Cs programs approved or renewed after March 31, 2010.
The EMO Program has established the following three service standards:
- NRCan will review applications and inform applicants of funding decisions within 75 calendar days of receipt or application deadline, whichever is later, 90% of the time;
- NRCan will have signed agreements / amendments in place within 75 calendar days of advising applicants of funding decisions, 90% of the time; and
- NRCan will issue advance payments within 45 calendar days of signature of contribution agreement or receipt and approval of valid claims for payment, 90% of the time.
These service standards are distributed to prospective Program applicants annually within the Program Application Guidebook that accompanies the Request for Proposal (RFP).
The audit determined that the Program did not collect sufficient, accurate data to calculate and monitor the three service standards for two of the three fiscal years examined. In the current fiscal year, the audit found that sufficient and accurate service standards data is collected and measured appropriately, but there was no evidence of these results being reported to Senior Management at the time of the audit.
RISK AND IMPACT
There is a risk that formal Program funding decisions may occur without the benefit of all relevant and available information.
There is a risk that performance information is not reported to Program management on a timely basis, thereby compromising effective program delivery and resulting in non-compliance with Government of Canada and departmental policy instruments.
RECOMMENDATIONS
- It is recommended that the Assistant Deputy Minister Canadian Forest Service (ADM CFS) ensure that a standardized reporting mechanism is implemented; that Program performance measurement is aligned with the Performance Measurement Strategy Framework (PMSF); and that the PMSF is streamlined for future program funding cycles.
MANAGEMENT RESPONSE AND ACTION PLAN
Management agrees. In response to recommendation 4:
The Program will introduce a standardized and timely mechanism for reporting and making funding recommendations to senior management.
Should the program be renewed beyond 2017/2018, the program PMSF will be updated and streamlined in order to strengthen program performance measurement. This will include the alignment of the performance measurements with the PMSF, as well as the development of a systematic approach to ensure the consistent calculation and comparison against performance measures.
Position Responsible: Director General, Policy, Economics and Industry Branch, CFS
Timing: Reporting mechanism in place by September 2017
APPENDIX A – AUDIT CRITERIA
The audit criteria were derived from widely recognized control models (e.g. Management Accountability Framework, CICA Criteria of Control – CoCo) and relevant Acts, legislation, and policies. Actual performance was assessed against the audit criteria, resulting in either a positive finding or the identification of an area of improvement.
The objective of the audit was to provide reasonable assurance on the overall adequacy of the management processes supporting EMO operations, in accordance with the Program’s terms and conditions, and in compliance with relevant key aspects of the of the Treasury Board Secretariat’s Policy on Transfer Payments, the Financial Administration Act (FAA), and relevant departmental requirements.
The following audit criteria were used to conduct the audit:
| Audit Sub-Objectives | Audit Criteria |
|---|---|
| Sub-Objective 1: To determine whether adequate governance processes have been established for the EMO Program. |
1.1 Management exercises oversight to enable the achievement of Program objectives and priorities. |
| 1.2 Roles, responsibilities, and accountabilities are clearly defined, documented, and communicated to Program stakeholders. | |
| Sub-Objective 2: To determine whether design and delivery of the EMO Program is adequate, in accordance with the Program’s terms and conditions, and in compliance with relevant key aspects of the Treasury Board Secretariat’s (TBS’) Policy on Transfer Payments, the Financial Administration Act (FAA), and relevant departmental requirements. |
2.1 Control processes are in place to ensure consistency, equitable treatment of applicants, and adequate protection of information in the solicitation, assessment, and approval of project applications. |
| 2.2 Funding agreements are consistently developed through a process tailored to address key recipient, TBS, and departmental requirements. | |
| 2.3 Agreements are administered in accordance with the Program’s terms and conditions, and in compliance with key aspects of the TBS Policy on Transfer Payments and the FAA, including amendments and payments to recipients. | |
| Sub-Objective 3: To determine whether EMO Program planning, monitoring, and reporting processes have been established and are operating as intended to inform senior management decision making. |
3.1 Adequate Program planning, monitoring, and reporting processes are in place and functioning as intended. |
| 3.2 Information necessary for internal decision making and reporting is available and provided to senior management in a timely manner. | |
| 3.3 Service standards have been developed and implemented by Program management. | |
| 3.4 Adequate Program performance measurement processes are in place and functioning as intended. |
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