March 2012
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The Canada Border Services Agency (CBSA) was created in December 2003 and is part of the Public Safety Portfolio. It is responsible for providing integrated border services that support national security and public safety priorities, and facilitate the free flow of persons and goods. As of July 1, 2011, the Agency employed 15,939 people, and in fiscal 2010-2011, carried out over 12,000 staffing transactions (including acting appointments, deployments, student bridging, etc.).
When the Agency was created in 2003, it incorporated resources from the Canada Revenue Agency, Citizenship and Immigration Canada, and the Canadian Food Inspection Agency. Consequently, the CBSA became subject to the Public Service Employment Act (PSEA) and was obliged to implement its requirements.
Through the Human Resources Branch (HRB), the Agency ensures that its human resources (HR) management policies, programs and processes align with Government of Canada human resources management policies, practices and initiatives, and with the CBSA's Business Plans, Annual Plans and Reports to Parliament.
In 2009, the Public Service Commission (PSC) carried out an audit of HR staffing for the period of January 1, 2006 through March 31, 2009. The audit objective was to ensure that the CBSA had appropriate frameworks, systems and practices for managing its appointment activities. The audit included six recommendations (see Appendix A) and a requirement for a follow-up audit to assess the Agency's compliance with the legislation and policies governing the making of appointments. In response to the PSC's audit report, the CBSA developed a Management Action Plan to address that report's recommendations.
The Agency launched the Staffing Accountability Improvement Strategy (SAIS) in April 2011. The Strategy is a "collection of related initiatives designed to support both managers and HR practitioners in delivering staffing excellence." The Strategy includes initiatives such as a new sub-delegation framework, a new staffing policy suite, a new guide for managers on staffing, and new tools and reference guides to aid managers in the staffing process.
This follow-up audit is significant because it provides assurance to senior managers and the PSC on progress the Agency has made in response to the Commission's six October 2009 audit recommendations, and the Management Action Plan developed in response to that audit.
The objective of this follow-up audit was to determine whether or not the Agency has adequately addressed the six recommendations in the PSC's October 2009 audit report, and appropriately implemented the Management Action Plan that it developed to respond to these recommendations.
The scope of this follow-up audit included testing the implementation of the Management Action Plan.
The period covered by this audit was October 2010 to December 2011.
The Canada Border Services Agency has adequately addressed the six audit recommendations made by the Public Service Commission in its October 2009 audit report. However, some opportunities for improvement still exist.
This translates into a minor risk[ 1 ] exposure for the Agency.
We found that the Agency has fully or substantially[ 2 ] addressed four of the six recommendations in the PSC's 2009 audit of staffing. These recommendations relate to: implementing the CBSA's action plan resulting from its 2008-2009 appointment file review; identifying training requirements for managers with sub-delegated staffing authority; clarifying the respective roles of Integrated Branch Business Services (IBBS) and HRB staff with regard to staffing activities; and validating staffing specialists' knowledge.
For the remaining two recommendations, we found that the Agency has partially[ 3 ] addressed the recommendations. They relate to: conducting human resources planning and carrying out monitoring and oversight activities.
More specifically:
The audit has made recommendations on:
This audit engagement was planned and conducted in accordance with the Internal Auditing Standards for the Government of Canada.
Management agrees that the findings of the Audit as presented are accurate, fair, and present a balanced view of the progress that has been made implementing the PSC Entity Audit recommendations from 2009. Of note, the Staffing Accountability Improvement Strategy, which is now well underway, was launched in April 2011 to fast-track the remaining initiatives required to respond to the original audit recommendations and specifically targeted improvements in staffing planning and file documentation for 2011-12. These targeted improvements were implemented and met in accordance with 2011-12 objectives and the intent of the PSC recommendations.
The Canada Border Services Agency (CBSA) was created in December 2003 and is part of the Public Safety Portfolio. It is responsible for providing integrated border services that support national security and public safety priorities, and facilitate the free flow of persons and goods. As of July 1, 2011 the Agency employed more than 15,939 people, and in fiscal 2010-2011, it made over 12,000 staffing transactions (including acting appointments, deployments, student bridging, etc.).
When the Agency was created in 2003, it incorporated resources from the Canada Revenue Agency, Citizenship and Immigration Canada, and the Canadian Food Inspection Agency. Consequently, the CBSA became subject to the Public Service Employment Act (PSEA) and was obliged to implement its requirements.
Through the Human Resources Branch (HRB), the Agency ensures that its human resources (HR) management policies, programs and processes align with Government of Canada human resources management policies, practices and initiatives, and with the CBSA's Business Plans, Annual Plans and Reports to Parliament.
In 2009, the Public Service Commission (PSC) carried out an audit of HR staffing for the period of January 1, 2006 through March 31, 2009. The audit objective was to ensure that the CBSA had appropriate frameworks, systems and practices for managing its appointment activities. The audit included six recommendations (see Appendix A) and a requirement for a follow-up audit to assess the Agency's compliance with the legislation and policies governing the making of appointments. In response to the PSC's audit report, the CBSA developed a Management Action Plan to address that report's recommendations.
The Agency launched the Staffing Accountability Improvement Strategy (SAIS) in April 2011. It is a "collection of related initiatives designed to support both managers and HR practitioners in delivering staffing excellence."[ 4 ] The Staffing Strategy includes initiatives such as a new sub-delegation framework, a new staffing policy suite, a new guide for managers on staffing, and new tools and reference guides to aid managers in the staffing process.
The CBSA Audit Committee approved the Audit of Human Resources Staffing as part of the Three-Year Risk-Based Audit Plan for Fiscal Years 2010-2013.
The preliminary risk assessment that we carried out for this follow-up audit to the PSC audit identified the following high-risk areas:
The current follow-up audit addressed the first risk identified above, while a subsequent compliance audit will address the second risk.
The objective of this follow-up audit was to determine whether or not the Agency had adequately addressed the six recommendations in the PSC's October 2009 audit report, and appropriately implemented the Management Action Plan that it developed to respond to these recommendations.
The scope of this follow-up audit included testing the implementation of the Management Action Plan.
The period covered by this audit was October 2010 to December 2011.
The follow-up audit was conducted in accordance with the Internal Auditing Standards for the Government of Canada. The examination phase used the following approach:
We based our criteria directly on the six recommendations flowing from the PSC's audit of HR staffing for the period of January 1, 2006 through March 31, 2009. Please see Appendix A for these recommendations.
This audit engagement was planned and conducted in accordance with the Internal Auditing Standards for the Government of Canada.
The Canada Border Services Agency has adequately addressed the six audit recommendations made by the Public Service Commission in its October 2009 audit report. However, some opportunities for improvement still exist.
This translates into a minor risk[ 5 ] exposure for the Agency.
Audit Criterion: PSC Audit Recommendation 1 - The CBSA should "ensure that its integrated HR plans provide direction to managers and HR professionals on how to make decisions concerning their staffing activities, by:
Conclusion: This criterion was partially met. Our follow-up audit indicated that the Agency has made some progress in addressing this recommendation.
The Agency developed its first three-year Human Resources Management Plan (HRMP) for fiscal years 2009-2012 and posted it on the intranet site (Atlas) in June 2010. All of the regions and branches prepared HR plans for 2009-2010. An Agency-wide Workforce Analysis was prepared in February 2011. As well, a mid-term review of the HRMP was discussed at the Directors General Forum in February 2011.
However, we found a number of deficiencies with regard to the HRMP. For example, we found no evidence that the HRMP had been updated annually, as originally stated in the plan. We also noted that the HRMP did not specify measurable expected results for staffing. Interviews with sub-delegated managers confirmed that guidance in the HRMP was at too high a level to be of practical use to them in making staffing decisions. They also indicated that some of the major problems posed to them in doing planning were frequent Agency reorganizations and requests to complete HR plans prior to knowing what the forthcoming budget would be.
More recent documents indicated that the Human Resources Branch has made changes to the HR planning process in the Agency that, once implemented, will significantly improve the process. Guidance and tools were provided to all the regions and branches so that, during June and July of 2011, each of them was able to develop Tactical Staffing Plans for fiscal 2011-2012. These plans included information such as the types of staffing planned and the timing for these staffing actions, official language and employment equity considerations, financial and accommodation issues, etc.
In the fall of 2011, the regions and branches prepared Integrated Business Plans for 2012-2015 that included business objectives and priorities, HR strategies and priorities, an environmental scan, a gap analysis and a requirement to monitor and measure progress and performance. These plans are intended to be used to develop Agency-wide HR strategies, such as maximizing the use of collective staffing to fill similar positions within the CBSA.
Recognizing that the first iteration of the planning cycle has not yet been completed, we support the HRB's intention to continue with this cycle of conducting specific tactical staffing planning in the spring of each year, and developing the Agency's corporate HR/business plan each fall. For the purpose of this audit, we concluded that the PSC's first recommendation on HR planning has been partially addressed. However, the recommendation still needs to be fully addressed through completion of the first cycle of the new HR planning process at the end of this fiscal year. Progress will be tracked by the Internal Audit and Program Evaluation Directorate of the CBSA through the regular follow-up process.
Audit Criterion: PSC Audit Recommendation 2 - The CBSA should "ensure that its Resourcing Monitoring Framework is fully implemented. This will assist the Agency in assessing its staffing management practices, performance and controls, and making adjustments, as required, to achieve the Agency's HR objectives."
Conclusion: This criterion was partially met. Our follow-up audit indicated that the Agency has implemented a monitoring framework; however, we noted some weaknesses with respect to monitoring practices and therefore concluded that the full intent of the recommendation has not yet been achieved.
To ensure that staffing is managed effectively and in compliance with legislative requirements, deputy heads are required to establish a governance and monitoring framework. Since the PSC's 2009 audit, the CBSA developed a Resourcing Monitoring Framework to provide "the Agency with a management tool to effectively monitor its staffing activities in accordance with the Staffing Management Accountability Framework indicators and to assist management in achieving their operational goals through an effective and efficient staffing regime."[ 6 ] Although the Monitoring Framework was developed in 2010-2011, it is intended to provide guidance on monitoring at the CBSA over the next few years.
Our review of the 2010-2011 Monitoring Framework indicated that it was clear and comprehensive, and met PSC requirements. Upon examining the monitoring activities that were carried out over 2010-2011, we concluded that the Agency had fully implemented its Monitoring Framework.
Monitoring Plans at the CBSA are developed each year. The 2010-2011 Monitoring Plan described the monitoring activities that were to be performed during that fiscal year and how the results were to be reported. We found that the Monitoring Plan was clear, comprehensive and appropriate. It covered all of the PSC monitoring requirements and focused on high-risk appointments. We found that most of the planned monitoring activities had been carried out and that quarterly reports had been sent to the regions and branches that were monitored. However, reporting of monitoring results consistently to senior management did not occur as planned.
Our review of the 2011-2012 monitoring practices and reporting showed considerable improvement. Monthly reports had been shared with the regions and branches, and a mid-year update had been provided to the Human Resources Standing Committee, as outlined in the 2011-2012 Monitoring Plan.
It would be an advisable practice to periodically table monitoring results at Executive Committee meetings, which are chaired by the CBSA President, potentially through the Agency's Performance Reports. This is important as the President is ultimately accountable for all staffing and appointment-related decisions in the Agency.
An effective monitoring program should be carried out by qualified staff. We found that all of the monitoring team members had the knowledge, skills, experience and competence necessary to perform monitoring activities. A strong monitoring program is also one that is independent of management. We concluded that all of the monitoring officers performed their work in an objective and unbiased manner.
However, we noted the following weaknesses with regard to monitoring practices.
To further test the effectiveness of monitoring in the CBSA, we reviewed a sample of files that the monitoring team had recently monitored. If the monitoring exercise covered all the required elements of the PSC Compliance Audit Program, and the monitoring team reached the same conclusions as did the internal audit team as to whether or not the files complied with relevant requirements, then we would determine that the monitoring done was sufficiently effective to be relied on.
We first reviewed a sample of files monitored over the period of October 2010 to March 2011 and found that the monitoring team's results were not always consistent with ours. We therefore concluded that we could not fully rely on the effectiveness of the monitoring done during that time period.
We then reviewed a sample of files monitored over the period of June to September 2011 and noted improvements with regard to the following matters:
Despite the improvements observed in the second sample reviewed, the weaknesses in the monitoring practices noted above (related to methodology, the procedures for selecting files for review, the lack of quality assurance review, and the lack of documentation of staffing notifications and posters reviewed) still need to be addressed to ensure that the monitoring activities are effective.
Given our findings, we will not rely on the monitoring conducted by the HRB in our compliance audit of staffing activities, starting in January 2012.
Recommendation 1:
The Vice-President of the Human Resources Branch should address the weaknesses noted with regard to its monitoring practices to ensure that monitoring activities are fully effective in addressing staffing issues and limiting the Agency's exposure to staffing-related risk.
Management Action Plan | Completion Date |
---|---|
Improve documentation of monitoring activities completed. |
April 2012 |
Strengthen sampling methodology, including selection of high-risk files by Corporate Resourcing. |
April 2012 |
Develop and implement the quality assurance process of the files monitored. |
June 2012 |
Strengthen monitoring criteria and methodology, and complete the development of tools to ensure the monitoring officers follow a consistent monitoring approach. |
September 2012 |
Audit Criterion: PSC Audit Recommendation 3 - The CBSA should "provide the PSC with the Agency's action plan resulting from its appointment file review (conducted in the fourth quarter of fiscal 2008-2009). This action plan should describe the actions to be taken, including corrective measures, accountabilities, timelines and how progress of implementation of the action plan will be monitored."
Conclusion: This criterion was met.
The original scope of the PSC Audit of the CBSA included a review of appointment files. However, during the audit, the PSC noted that the CBSA was completing an internal file review during the fourth quarter of 2008-2009, where various deficiencies in appointments and appointment-related decisions were noted. As a result, the PSC decided that a review of appointment files would be more appropriate as part of a follow-up audit. The deferral of the appointment file review resulted in the third recommendation in the Commission's October 2009 audit report, as noted above.
We found that each region, in response, had developed an action plan to address the internal file review recommendations and had later provided an update on the progress that they had made in implementing the plan. Each regional action plan specified accountabilities and timelines, and included comprehensive and appropriate corrective measures to address the issues found during the appointment file review. Both the plans and the progress updates, as reported by the regions, were submitted to the PSC. Further progress in implementing the regional action plans is measured through the Agency's monitoring process.
Audit Criterion: PSC Audit Recommendation 4 - The CBSA should "establish an evaluation process to help identify training requirements for sub-delegated managers to ensure that those who are sub-delegated are and remain competent to exercise their appointment and appointment-related authorities."
Conclusion: This audit criterion was substantially met. Our follow-up audit indicated that the Agency has made substantial progress in addressing this recommendation.
The Agency has significantly improved its mechanisms for providing sub-delegated managers and HR advisors with the tools they need to carry out their staffing responsibilities. Over 2009-2010 and 2011-2012, the Human Resources Branch issued a series of staffing policies, guides and bulletins that are available on the intranet site (Atlas). We found these tools to be comprehensive, accurate and appropriate for the users' needs.
As part of its Staffing Accountability Improvement Strategy, in April of 2011, the CBSA implemented a new Staffing Sub-Delegation Framework, including an updated instrument and policy. We found the new sub-delegation instrument and policy to be complete and up to date.
New sub-delegation training, developed over 2010-2011, comprises an online portion and a workshop portion. We found the training program to be thorough in providing information to prepare managers for their role in conducting sub-delegated staffing. The Agency is also implementing mandatory refresher training that sub-delegated managers will be required to take every two years.
Considerable improvements were made with respect to sub-delegation training. CBSA managers who had sub-delegated staffing authority prior to April 2011 have been advised that they must complete the refresher course and submit a certification request form to obtain their staffing sub-delegation authorities under the Staffing Accountability Improvement Strategy. However, we noted that the Agency has not set a deadline for them to do so. In our appointment file review, we were unable to find evidence that all of the managers who had signed letters of offer had a letter or a certificate signed by the President granting them official staffing sub-delegation. This is important as the letters of offer are the formal contractual documents for making appointments, and so would be considered null and void if not signed by a sub-delegated manager. This poses the risk that managers who have not officially received sub-delegated staffing authority may be making appointments that they are not technically authorized to make.
Recommendation 2:
The Vice-President of the Human Resources Branch should set a target date for managers to receive the required training and obtain the signed certificate from the President, in adherence with the current CBSA policy and the PSC's Appointment Delegation and Accountability Instrument. The Vice-President of the Human Resources Branch should monitor the completion of training and obtaining of certification.
Management Action Plan | Completion Date |
---|---|
Confirm the sub-delegated managers who require written verification of their authorities by the President. |
February 2012 |
Establish a deadline for completion of sub-delegation staffing training (i.e. online refresher course) by sub-delegated managers. |
August 2012 |
Confirm those sub-delegated managers have received certification by the President. |
October 2012 |
Audit Criterion: PSC Audit Recommendation 5 - The Agency should "clarify roles and responsibilities for appointment and appointment-related activities between Branch Management Service, now Integrated Branch Business Services (IBBS), units and HRB to help ensure that sub-delegated managers have timely access to appropriate HR advice."
Conclusion: This criterion was substantially met. Our follow-up audit indicated that the Agency has substantially addressed this recommendation, as roles and responsibilities between the IBBS units and the HRB have been clarified and are understood by both IBBS and HRB staff; however, confusion still exists on the part of hiring managers.
We found that the HRB had taken various steps to help clarify the roles and responsibilities regarding staffing and to improve client service. These steps included realignment of the Branch; signing an agreement with the Comptrollership Branch regarding the roles of HRB and IBBS staff; and developing revised service standards, policies, guides and bulletins.
Interviews with HR advisors and IBBS staff indicated that both parties clearly understood their respective roles and responsibilities with regard to staffing activities—i.e., HR advisors provide staffing advice and assistance to hiring managers, while IBBS staff provides administrative staffing services, such as sending staffing forms to be completed by managers.
However, we noted that managers are still experiencing some degree of role confusion with regard to the conduct of business processes for staffing. Each branch at CBSA Headquarters has its own Integrated Branch Business Services unit that provides the branch with various administrative services. The fact that each IBBS unit operates independently from the other IBBS units, combined with the fact that managers have to deal with both the HRB and the IBBS in conducting staffing, contributes to confusion on the part of hiring managers, as well as delays in the staffing process.
We acknowledge the initiative taken by some of the IBBS units in producing guides for their clients on staffing documentation requirements. However, due to the independence of the various units, these guides are not shared with the other units. This lack of communication among the units leads to inefficiencies in terms of duplication of work. Moreover, we found that some of the IBBS guides that we looked at contained outdated and incorrect staffing information. This poses a risk that managers could be misinformed about the documentation they need to prepare for a staffing action.
We therefore determined that measures should be taken to reduce the confusion that exists on the part of hiring managers with regard to provision of staffing services, and to increase the efficiency and effectiveness of staffing processes.
Recommendation 3:
The Vice-President of the Human Resources Branch should examine the current structure and functions of the Integrated Branch Business Services units with regard to the role they play in staffing processes, in order to determine the most efficient and effective way of providing staffing services to stakeholders across the Agency.
Management Action Plan | Completion Date |
---|---|
Review the structure and functions of the IBBS units with regard to the staffing process and report to senior management on changes required to improve efficiency and effectiveness of providing staffing services. |
September 2012 |
Audit Criterion: PSC Audit Recommendation 6 - The CBSA should "require successful completion of the Appointment Framework Knowledge Test (AFKT) within the Personnel Administration Development and Apprenticeship Program to support sub-delegated managers having access to an HR specialist whose expertise in the Appointment Framework has been validated by the PSC."
Conclusion: This criterion was met.
The PSC developed the AFKT to validate staffing specialists' knowledge of the Public Service Employment Act and the PSC Appointment Framework. The test is important to ensure that staffing specialists have the required knowledge to be able to provide sound staffing advice to hiring managers. We reviewed the CBSA Personnel Administration Development and Apprenticeship Program and found that it now includes successful completion of the AFKT as a mandatory requirement for PE-03s to graduate from the program in the staffing stream.
It is not mandatory that all HR advisors who provide staffing services have passed the AFKT, but the PSC does expect organizations to have enough HR advisors who have passed the test to ensure that hiring managers have access to sufficient staffing advice and assistance. The CBSA's 2010-2011 Departmental Staffing Accountability Report that was submitted to the PSC indicated that 81% of the HR advisors in the Agency who provided staffing advice had passed the AFKT.
The PSC made the following recommendations in its October 2009 audit of staffing.
Recommendation 1: Ensure that its integrated HR plans provide direction to managers and HR professionals on how to make decisions concerning their staffing activities, by:
Recommendation 2: Ensure that its Resourcing Monitoring Framework is fully implemented. This will assist the Agency in assessing its staffing management practices, performance and controls, and making adjustments, as required, to achieve the Agency's HR objectives.
Recommendation 3: Provide the PSC with the Agency's action plan resulting from its appointment file review. This action plan should describe the actions to be taken including corrective measures, accountabilities, timelines and how progress of implementation of the action plan will be monitored.
Recommendation 4: Establish an evaluation process to help identify training requirements for sub-delegated managers to ensure that those who are sub-delegated are and remain competent to exercise their appointment and appointment-related authorities.
Recommendation 5: Clarify roles and responsibilities for appointment and appointment-related activities between Branch Management Services units and HR Branch to help ensure that sub-delegated managers have timely access to appropriate HR advice.
Recommendation 6: Require successful completion of the Appointment Framework Knowledge Test within the Personnel Administration Development and Apprenticeship Program to support sub-delegated managers having access to an HR specialist whose expertise in the Appointment Framework has been validated by the PSC.
Acronym | Definition |
---|---|
AFKT | Appointment Framework Knowledge Test |
CBSA | Canada Border Services Agency |
HR | Human Resources |
HRB | Human Resources Branch |
HRMP | Human Resources Management Plan |
IBBS | Integrated Branch Business Services |
PSC | Public Service Commission or "the Commission" |
PSEA | Public Service Employment Act |