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MAF Assessment: Canada Border Services Agency - 2005


* An asterisk appears where sensitive information has been removed in accordance with the Access to Information Act and Privacy Act.

This document provides a Treasury Board Portfolio assessment of the department's performance against specific indicators only. It does not present an assessment of management quality beyond these indicators, nor does it reflect the level of effort a department may be making toward improving the quality of its management. The assessment may not reflect the latest information available.

Context

This is the Canada Border Services Agency's (CBSA) second Management Accountability Framework (MAF) assessment since its creation on December 12, 2003. Treasury Board Portfolio (TBP) observations on CBSA are generally positive as CBSA completes the transition to establish itself as a stand-alone agency. While CBSA has been successful on several fronts and has made good progress on a number of issues, some areas with opportunity for improvement remain. The Agency should be commended for its work in a number of areas including:

  1. Establishing an Effective Planning Function with a clear decision-making process through the successful integration of business and strategic planning. For instance, last year's assessment on this indicator noted a major concern while this year's level is acceptable. Similarly, the assessment on the Materiel Management indicator moved from major concern to acceptable;
  2. Successfully completing a number of IM/IT projects that received national and international awards; and
  3. Completing the transition of several employee groups formerly excluded or unrepresented to their new status under the Treasury Board (TB) as their employer.

The Agency has also responded positively to some of the areas identified for monitoring in last year's MAF and follow-up letter, notably:

  1. Establishing a new organizational structure and developing its Program Activity Architecture (PAA) to the sub-sub activity level;
  2. Establishing an effective internal audit and evaluation function; and
  3. Undertaking and completing Phase I of the A-base review for its Innovation, Science and Technology Branch.

While Treasury Board Portfolio observations are generally positive, there are nonetheless some areas where there are opportunities for improvement :

  1. In Financial Reporting, the Agency made visible improvements in integrating information from its three legacy organizations to ensure that financial statements conform to the TB Accounting Standards. However, more work needs to be done to eliminate any errors in Public Accounts related to the tax revenue.
  2. CBSA is encouraged to continue its efforts in complying with the Management, Resources and Results Structure (MRRS) Policy and in developing its Performance Reporting framework so that it includes a complete set of performance measures. This should support better linking of resources and results as they are outlined in the departmental Report on Plans and Priorities (RPP) and Departmental Performance Report (DPR). It should also provide CBSA with an opportunity to populate the Expenditure Management Information System (EMIS) with performance information.
  3. Despite efforts since the last review, integration of human resources and business planning and Official Languages (language of work and external service delivery) are areas that represent opportunities for improvement. Further efforts are also required in the promotion and implementation of public service values and ethics into every day practices and in satisfying the required measures in support of the Public Service Modernization Act.

Elements and Indicators

Public Service Values

Values and Ethics (V&E) - Leadership Opportunity for Improvement

Leadership recognized internally and externally as demonstrating strong ethics and values behaviour, as evidenced by:

  • Leadership communication with employees about expected ethical behaviour and public service values;
  • Selection, evaluation, promotion and discharge of leaders based on their conduct with respect to Public Serivce (PS) values and ethics.
The President of the CBSA has communicated the expectations of ethical behaviour and public service values to all staff. As well, values and ethics continue to be the topic of discussion at numerous senior management forums. The Agency’s Leadership Framework currently being developed includes a values and ethics component, in addition, upholding public service values and ethics is an integral part of the Performance Management Agreements of Agency senior managers. CBSA has integrated, and will continue to seek opportunities to integrate the promotion of ethical conduct and strong Public Service values within its management and training practices, as evidenced by the recognition of these elements in the performance development program and the recruitment training program. CBSA is encouraged to also consider the following:
  1. Implement activities and events where leaders can consistently communicate directly with employees on values and ethics.
  2. Continue to incorporate specific measures into the selection, evaluation, promotion and discharge of leaders based on values and ethics, by looking at what other departments or agencies have initiated in this area.


V&E - Organizational Culture Acceptable

Organizational culture reflecting public service values and ethics, as evidenced by:

  • Feedback from employees on fairness, respect, satisfaction and engagement;
  • Departmental benchmark results and implemented improvements;
  • Trends in management and program irregularities, regularly reported on and reviewed by management.
From a Public Service values and ethics perspective, the Canadian Border Services Agency (CBSA) is considered a high-risk organization due to the nature of its work. This being said, CBSA is commended for collecting employee feedback on its evolving organizational culture, through a CBSA-specific addendum to the 2005 Public Service Employee Survey that was recently conducted. Across the Agency, workplace processes and protocols have also been designed to provide regular monitoring to limit possible breaches. A focused review is currently being undertaken to identify vulnerabilities (such as coercion or penetration by criminal elements) with respect to CBSA operations, from recruitment to training to daily work. As well, the CBSA is one of the very few federal agencies that has established an Internal Affairs Section to investigate allegations or evidence of employee misconduct or malfeasance. Considering the department’s mandate, and the need to secure public trust and confidence in its ethical performance, CBSA must continue this positive work, and may also consider the following:
  1. Continue to conduct comprehensive monitoring in order to track and report on trends in management and program irregularities.
  2. Continue to identify areas within the organization that are particularly vulnerable to breaches in values and ethics.


V&E - Guidelines and Recourse Opportunity for Improvement

V&E policies, guidelines, standards, recourse and disclosure mechanisms in place and understood by all employees as evidenced by:

  • Customized codes of conduct, including standards of behaviour, consequences and rewards for exemplary behaviour;
  • Effective communication, learning and orientation strategies for the Code of Public Service Values, for customized organizational codes and guidelines and for Public Service values and ethics in general;
  • Appropriate, accessible avenues for: employee advice, reports of wrongdoing and resolution of conflicts.
CBSA has developed a customized code of conduct and has established an intranet values and ethics site where Agency managers and staff are kept abreast of developments in values and ethics, can review various ethical dilemmas and can receive guidance on internal and external disclosure mechanisms, strong public service values and ethical conduct. The CBSA also currently offers dispute resolution services through Internal Conflict Management System officers who can assist employees regarding matters of possible wrongdoing. Agency personnel can also report in confidence, on possible breaches of public service values and ethics to Director General-level officials through dedicated electronic mailboxes. CBSA has made positive strides in this area and is encouraged to consider the following:
  1. Assess how employees and managers, both new and existing, understand and are impacted by the Public Service Code and the Agency’s customized code of conduct.
  2. Track and monitor employee usage of the different avenues available for seeking advice or filing a report for potential wrongdoing or harassment.

Governance and Strategic Directions

Governance Legitimacy Unrated

A legal framework of powers, duties and functions related to the institution (or its Minister) reflective and enabling of its objectives, as evidenced by:

  • Programs and activities authorized by and in compliance with the law (e.g., constitutive legislation, the Financial Administration Act, the Charter of Rights and Freedoms, and other applicable statutes or regulations);
  • A corporate process to identify areas where legal authority may be lacking or issues of lawfulness, including:
    • A requirement that an assessment of the adequacy of legal authority and lawfulness for new programs and activities be incorporated into the decision-making process when these programs and activities are developed;
    • A process and work plan to review whether current programs and activities are authorized.
The CBSA believes that it has achieved at least Acceptable progress against this indicator. The CBSA was initially created on December 12, 2003 through Orders in Council P.C. 2003-2059 to 2003-2070 and functions from the Canada Customs and Revenue Agency (CCRA), Citizenship and Immigration Canada (CIC) and the Canada Food Inspection Agency (CFIA) were transferred to the new Agency. The Canada Border Services Agency Act (Bill C-26) came into force on December 12, 2005. The Act formally established the CBSA's legislative mandate, powers, duties and functions, and transferred the necessary authorities from the legislation of legacy organizations. As part of the development and introduction of Bill C-26, a review of existing authorities was done and any additional authorities needed to provide the CBSA with a solid foundation were identified. As new programs and/or policies are proposed, an assessment of the adequacy of the Agency's legislative and regulatory authorities to move forward will be done, in consultation with the Department of Justice, and any gaps are identified for consideration in submissions to senior Agency management and Cabinet.


Governance Structure Opportunity for Improvement

A stable Management Resources and Results Structure (MRRS), the foundation for results-based management, as evidenced by:

  • Clearly defined, measurable strategic outcomes that reflect the organization’s corporate mandate and vision;
  • Clear results outcome statements that are linked to corporate government-wide priorities;
  • Program Activity Architecture (PAA) sufficiently populated with results and financial information;
  • Defined governance structure outlining the decision-making, mechanisms, responsibilities, and accountabilities of the department.
The Canada Border Services Agency has one strategic outcome that does not give a clear indication of the Agency’s long-term commitment. As of March 31, 2005, the Agency had very little performance information, however this Agency was still relatively new at this time.


Effective Planning Function Acceptable

An effective planning function, as evidenced by:

  • Approved organizational strategy to integrate business and strategic planning, human resources planning, resource management, and performance monitoring;
  • Established process and calendar for corporate planning and decision making;
  • Operational plans and performance agreements aligned with and linked to strategic plans.
This is CBSA's second MAF assessment. The previous assessment noted that it was too early to determine the effectiveness of this function because CBSA was still a new organization. In the current round of assessment, it should be noted that CBSA made good progress in corporate planning by establishing a clear process for decision-making and by integrating its business and strategic planning. CBSA also has a well-defined governance structure with the Executive Committee driving its planning process. CBSA continues to keep TBS informed of the initiatives as they are being implemented. Some work is also underway to integrate Human Resource (HR) and business planning. With the significant capacity funding provided to CBSA through Budget 2005, the Agency will be able to augment its planning function. It is expected that by next round of assessment, CBSA will have a fully integrated planning and resourcing functions. In the Fall 2005, the Agency began developing its first three-year strategic plan. Through consultations and information sessions, the Agency has made significant progress in the preparation of operational plans for each Branch which, as well as performance management agreements (PMAs), are aligned with the Agency's priorities. The Agency communicates the corporate planning process and the corporate planning calendar through the CBSA Planning Network, which was created in the spring of 2005. The Network includes the planners from each branch.


Horizontal Initiatives Acceptable

Commitment and contribution to the results- based management of horizontal initiatives, as evidenced by:

  • Leadership where appropriate;
  • Active participation; and,
  • Responsibilities for horizontal initiatives reflected (including leadership) in performance agreements.
TBS is aware of significant progress made by CBSA on several horizontal initiatives such as Airport Security and Marine Security. For some of these activities (like document integrity), the CBSA is the lead, while for others, the Agency is an active contributor to the success of the OGD-led initiatives. The CBSA’s horizontal leadership is an important part of the President’s Performance Management Agreement, which includes a commitment identified by the Clerk of the Privy Council. While CBSA believes it has achieved a Notable rating, it seems a bit premature in the opinion of the Treasury Board Portfolio (TBP), and an Acceptable rating seems more appropriate. While CBSA has demonstrated leadership and was an active participant in various horizontal initiatives, the Agency did not have a lead on a major initiative such as the Security and Prosperity Partnership (SPP), one of the more complex government-wide horizontal programs involving several security-related initiatives.

CBSA will face serious challenges in delivering on the SPP commitments where the success will depend to a large degree on the cooperation from other government departments within and outside the PSEPC portfolio. * In the next round of assessments, both CBSA and TBS would be in a better position to assess CBSA performance in regards to the SPP, which will have a significant impact on the overall assessment of this indicator.



Portfolio Management Acceptable

An effective portfolio management structure and process in place, as evidenced by:

  • Clear direction, leadership and communications;
  • Information exchange, sharing of common best practices;
  • Structured consultations on: priority-setting and decision-making, resource allocation and budgeting, policy development and planning;
  • Committee processes and an organized governance structure;
  • Integrative operational mechanisms and shared services;
  • Graduated portfolio-based approval processes;
  • Integrated mandate and common objectives.
Previous assessment noted that TBS was unable to provide assessment of this indicator because CBSA was a new organization and there wasn't enough information. Since that time, CBSA has made progress in improving communications with its portfolio partners. It should be noted that CBSA is part of the Public Safety and Emergency Preparedness Canada (PSEPC) portfolio and that PSEPC plays a significant role in Portfolio Management. Within the PSEPC portfolio, CBSA actively participated in consultations and priority-setting on major PSAT initiatives such as SPP and others. CBSA also actively participates in consultations outside of PSEPC portfolio with other government departments.

Policy and Programs

Policy Framework Acceptable

A solid policy framework, as evidenced by:

  • Consistency with the departmental mandate;
  • Alignment with the government-wide policy agenda;
  • Appropriate horizontal linkages to the policy frameworks of other departments;
  • Clarity to central agencies and other departments; and,
  • Utility in managing competing demands and allocating scarce resources.
The CBSA believes that it has achieved at least Acceptable progress against this indicator. For example, CBSA HR policies are closely aligned with related central agency policies, which are either adopted in whole or modified to meet specific CBSA needs while still respecting the requirements of central agencies.

The Agency has clearly defined its policy priorities reflecting the direction of the government to enhance Smart Borders (the Agency is responsible for the majority of the 32-point action plan), and the Security and Prosperity Partnership for North America (the CBSA is the lead or co-lead for more than 100 of the 300 action items of the SPP security agenda) and articulated these to PSEPC and Privy Council Office (PCO).

The Agency is exploring the establishment of a dedicated group within the Strategy and Coordination Branch responsible for strategic policy coordination, overseeing the Agency’s comprehensive policy framework, ensuring alignment with the government-wide policy agenda, and providing a centre of expertise for policy analysis.

The CBSA has already established a research unit to carry out econometric research and analysis to support decision-making in the Agency. This will ensure that decisions taken are based on evidence and analysis, as well as enhance our overall capacity to provide policy advice to the Minister. This team is also working with the research units of other government departments to facilitate the exchange of information and methodologies.



Strategic Policy Capacity Acceptable

A solid strategic policy function and analytic capacity, as evidenced by:

  • Ability to anticipate challenges and respond in a strategic rather than a reactive manner;
  • Organizational model to harness distributed policy capacity;
  • Strong and sustainable community of analysts;
  • Policy development process grounded in fact-based analysis with reliable modeling and due regard for implementation and operational matters;
  • Outcomes-focused policy and program development informed by past performance;
  • Stakeholder engagement to effectively inform policy making without creating expectations that unduly constrain government decision-making.
It should be noted that as an Agency, CBSA is responsible for certain policies while PSEPC holds an overall responsibility for the strategic policy function for the portfolio. The last MAF assessment noted that this function was entirely new at CBSA and that not enough information was available. Since then, the Agency has made significant progress in developing its analytic capacity which was demonstrated by CBSA's input into numerous Memoranda to Cabinet. CBSA undertook to harmonize its internal management policies with TBS policies, with a list of such policies to be provided to TBS by April 1, 2006. In addition, CBSA improved cooperation with PSEPC in respect of policy development. The Agency consistently provided advice on policy issues to its Minister. However, more work remains to be done, particularly in improving CBSA's ability to anticipate challenges as opposed to reacting to them. Further coordination and cooperation with other government departments is expected as CBSA provides input into policy discussions.

Results and Performance

Evaluation Function Acceptable

An effective evaluation function, as evidenced by:

  • Capacity of the evaluation function;
  • The deputy head as Chair of an active evaluation (and audit) committee(s); 
  • Risk-based evaluation plans;
  • Management action plans to address evaluation findings/recommendations;
  • Evaluation reports submitted to TBS and posted in a timely fashion (three months);
  • Performance information regularly audited or evaluated;
  • Audit and Evaluation or other executive committee review of performance information.
The follow-up letter from MAF 2004 observes a requirement for the strengthening of both the internal audit and evaluation function.
  1. CBSA has made significant progress in establishing an evaluation function within the last fiscal year. In 2004-05, the evaluation function had no A-base funding; however, in 2005-06 a planned expenditure of $1.6M is noted.
  2. CBSA has a joint Audit and Evaluation Committee Chaired by the President.
  3. There is a risk-based evaluation plan that has been shared with TBS.
  4. Evaluation action plans are approved and monitored by the Audit and Evaluation Committee. Two evaluation reports were approved in 2004-05 with three completed but yet to be approved in 2005-06. Only one has been submitted to TBS for the public website.
  5. Although only one evaluation has been submitted for analysis, the report addressed the issue of relevance, but substantiation was not available. Value for money was not addressed by this evaluation.


Financial Reporting Opportunity for Improvement

Accounting and reporting of financial activities consistent with government policies, directives and standards, as evidenced by:

  • Timely and accurate financial reporting including accuracy of public account plates and improvements on the quality and timeliness of departmental financial statements;
  • Quality of Central Financial Management and Reporting System (CFMRS) trial balance submissions including materiality and number of errors and timeliness of corrections;
  • Quality presentation and accounting for specified purpose accounts.
The audit of the 2005 Public Accounts continued to find problems related to tax revenues. For Canada Border Services Agency, there was an unexplained difference for the customs stream between the general ledger and tax programs.

Departmental financial statements & Special Purpose Accounts: Overall, they conformed to Treasury Board Accounting Standards. Some items did not reconcile with Central Financial Management Reporting System. Some note disclosures could be improved. Signed financial statements have not been received.

Public Account Plates: Obtained a grade of B with 87% of plates submitted on time.

Trial Balance Submissions: Nineteen errors were reported during the year on submissions. It is noted that most of the errors occurred in the first three months of reporting and that by March 2005 only one error remained in the monthly trial balance submission.

Internal Audit Reports: No items related to financial reporting were noted.



Information and Decision-Making Acceptable

Access to and use of integrated information for corporate decision making, as evidenced by:

  • Integrated information from financial, human resources, payroll, and asset and real property management systems in support of senior management decision-making and related to the achievement of strategic objectives; and,
  • Regular Deputy Minister and senior management challenge of proposed investment decisions on the basis of integrated information from various sources linked to strategic objectives.
CBSA has made good progress in this area as demonstrated by the effective internal challenge function provided by its Comptrollership Branch on numerous funding proposals. The internal vetting process has been better defined and applied as reflected in the committee structure, embedded within the overarching Governance Structure at CBSA. CBSA was experiencing difficulties in integrating corporate information which came from various systems, inherited from three legacy organizations. In May, 2005, CBSA moved to an integrated information system. This system provides decision-making support to senior management on matters of financial and human resources. CBSA is further addressing this issue in the context of an A-base review. The first phase of this review has started with the analysis of IM/IT as part of an Innovation, Science and Technology Branch review. The A-base review is to be completed before the end of 2007, however, it is expected that in the meantime, CBSA will be able to strengthen its ability to integrate information and better link it with strategic objectives.


Performance Reporting Opportunity for Improvement

Planning and reporting systems to support executive decision-making, as evidenced by:

  • Reports on Plans and Priorities (RPPs)/Departmental Performance Reports (DPRs) reflective of information contained in Management, Resources and Results Structure (MRRS);
  • DPRs linked to RPPs;
  • Electronic, meaningful real-time data linking resources and results.
There is no clear link between the Departmental Performance Report (DPR) and Report on Plans and Priorities (RPP). The RPP contains no strategic outcomes and reports on priorities, while the DPR contains strategic outcomes and reports on program activities. Since the DPR uses a different reporting framework from the RPP, it is difficult to discern whether or not commitments made in the RPP are reported on in the DPR. In addition, the performance measures in the DPR are mostly at the output level. Overall it is difficult for a reader to assess the performance of the department.

Learning, Innovation and Change Management

Innovation and Change Management Unrated

Anticipation and management of significant organizational change, as evidenced by :

  • Change management strategies at the corporate and 'initiative' levels;
  • Change management function:
  • Assignment of responsibilities and support to change management practices.
“A new Policy on Learning, Training and Development came into effect January 1st, 2006. It applies to departments and agencies for which Treasury Board is the employer (Financial Administration Act Schedules 2 and 4). Monitoring of implementation in departments and agencies will begin in January 2007, allowing for gradual implementation throughout 2006. Implementation will be supported by directives, standards and guidelines and results will be reported annually starting in 2006-2007. This policy replaces the Policy for Continuous Learning in the Public Service of Canada. It supports employees at all levels by providing learning and training opportunities designed to foster excellence and a world-class workforce serving the needs of Canadians of today and for future generations.”

DEPARTMENTAL FEEDBACK: The Agency consistently applies innovation and scientific solutions to its business. Both GTEC and the Public Service Awards of Excellence recognized the CBSA as being a highly innovative Agency, with seven awards in total over the past year.

The CBSA has one of the largest developmental agendas in the government and, through continuous learning, is continuously transforming and modernizing its business by applying the latest technology solutions. The Agency provides analytical, research, forensic and scientific advisory services within the Agency and to our partners. Some examples of programs the Agency is transforming in response to changing business demands are:

  1. The API/PNR program was developed as a result of the events of September 11, 2001. It obtains information for the risk assessment of travellers in advance of their arrival in Canada.
  2. NEXUS Air is a program being piloted by the CBSA and the United States Customs and Border Protection (US-CBP) to offer expedited border clearance to pre-approved, low-risk international air travellers using automated kiosks equipped with iris recognition biometric technology.
  3. The FAST program is a bi-national initiative between Canada and the United States (U.S.) that offers pre-authorized importers, carriers, and commercial drivers, expedited clearance for eligible goods through dedicated FAST lanes, and/or FAST Primary Inspection Lines, where available.


Organizational Learning Unrated

The organization learns from its results, as evidenced by:

  • An organizational learning strategy incorporating regularly reviewed learning objectives, opportunities and requirements;
  • A strategy to determine organizational knowledge needs as well as to capture, manage and apply organizational knowledge to shape action and improve results.
“A new Policy on Learning, Training and Development came into effect January 1st, 2006. It applies to departments and agencies for which Treasury Board is the employer (FAA Schedules 2 and 4). Monitoring of implementation in departments and agencies will begin in January 2007, allowing for gradual implementation throughout 2006. Implementation will be supported by directives, standards and guidelines and results will be reported annually starting in 2006-2007. This policy replaces the Policy for Continuous Learning in the Public Service of Canada. It supports employees at all levels by providing learning and training opportunities designed to foster excellence and a world-class workforce serving the needs of Canadians of today and for future generations.”

DEPARTMENTAL FEEDBACK: The CBSA is working toward the building of a framework for learning in the agency in order to create high-performing employees and therefore a high-performing organization in a cost-effective and efficient manner; create the ability to plan and report on strong metrics; support CBSA priorities and initiatives; create a learning organization. The Learning Framework includes a three-year action plan. The Agency has implemented an organizational learning strategy for the implementation of the new Public Service Modernization Act (PSMA) incorporated with Training and Learning Directorate to engage and empower managers and HR professionals on the new Public Service Employment Act (PSEA).

The CBSA is moving forward in integrating Border Services Officer recruitment and basic recruit training.


Risk Management

Legal Risk Management Unrated

Adequate management of legal risk, as evidenced by:

  • Ongoing/regular scanning of programs for legal risks, in a manner commensurate with the nature of the department’s activities and mandate; 
  • Senior management engagement in Legal Risk Management (LRM), including the active review, avoidance, mitigation and management of legal risks;
  • Effective sharing of information on legal risks, including with the Department of Justice and central agencies (in large part to 'create' a whole on government perspective);
  • Contingency planning to respond to risks that have materialized.
The CBSA’s strong legal review and representation related to NEXUS programs, API/PNR, Land Pre-clearance and TITAN assesses the legal risks and provides advice on mitigation strategies for these and other program and project teams. The Legal Services Unit is represented and actively involved on Director General-level Innovation Committees as well as all senior management committees.

While discussions have begun on a process to more regularly monitor and review CBSA policies, programs and partnerships for legal risks, it will not be in place by the end of fiscal year 2005-2006.



Risk Acceptable

Risk as an active factor in decision-making processes, as evidenced by:

  • Evergreen Executive Committee assessment of corporate risks and the status of risk management (Corporate Risk Profile);
  • An integrated risk management function (organizational focus) linked to corporate decision-making;
  • Protocols, processes and tools to ensure the consistent application of risk management principles throughout departmental decision making and delivery; and,
  • Continuous organizational learning about risk management and lessons learned from risks successfully identified, mitigated or not.
CBSA provided up-to-date information on Risk. Consequently the rating was changed to "Acceptable".

An initial Risk Base Profile was completed for the Agency for use in building the Risk Based Audit Plan and the multi-year Evaluation Plan. An innovative approach was used to integrate the concepts of the MAF and the Program Activity Architecture (PAA) into the Risk Based plans.

As part of work on the Agency’s Management Control Framework, a Corporate Risk Profile is being developed, building on the initial Risk Base Profile as well as work done by legacy organizations. The new Corporate Risk Profile is an integral part of an Integrated Risk Management Strategy for the CBSA. The Strategy will include senior-level governance for Agency risk management and promote ongoing awareness efforts in order to contribute to continuous organizational learning on risk management, including the sharing of best practices and lessons.

Strong operational risk management methodologies and tools are in place in the Agency.

Highly integrated systems enable CBSA to provide comprehensive intelligence and analysis information to front line operations and Intelligence officers. Some of the systems that highlight the Agency’s commitment to risk management are:

  1. TITAN – An automated targeting and risk assessment of electronic cargo, conveyance and supplemental information.
  2. ACI – Marine - ACI is about getting the right information at the right time to make informed decisions about whether to examine shipments at the first point of arrival (or in the foreign port) in order to protect Canadian society from health, safety, security, terrorist and contraband threats.
  3. NEXUS – Provides simplified border crossing for pre-approved low-risk travellers. This assists in the risk management of the border. Once approved by both Canada and the United States as low-risk travelers, NEXUS members enjoy a simplified entry process while traveling across the Canada – US border. The NEXUS programs enable Canadian and United States customs and immigration authorities to concentrate their efforts on potentially high-risk travellers and goods, thereby upholding security and protection standards at the border.
  4. The Passenger Information System (PAXIS) enables the CBSA to perform risk assessments of air travelers prior to their arrival in Canada. The CBSA uses the data received to identify high-risk travelers * for closer examination upon their arrival in Canada.

These systems and tools were planned and implemented based on addressing the highest risk modes first, marine and air. The Agency believes that it has employed very sophisticated and innovative risk management approaches at its highest risk operations.


People

Workplace Unrated

A workplace that is fair, enabling, healthy and safe in order to provide best services to Canadians, as evidenced by:

  • Fair employment and workplace practices and effective labour relations;
  • Clear direction, collaboration, respect and support for employees' linguistic rights, diversity and personal circumstances in order to enable them to fulfill their mandate;
  • Healthy and safe physical and psychological environment.
Sick leave without pay (2.25%) is relatively low in comparison to public service averages. Data on absenteeism rate is not available given that it is a relatively new organization.

The CBSA has faced numerous classification challenges as a result of inheriting three regimes from the legacy organizations and has been working closely with the Public Service Human Resources Agency of Canada (PSHRMAC) on a classification reform initiative to develop a tailored classification plan and structure. The final standard has been approved. The CBSA unions, principally the Public Service Alliance of Canada (PSAC), have been engaged in this initiative.

The CBSA continues in a building mode and will work with PSHRMAC in developing its internal classification-monitoring program and in dealing with outstanding classification issues. One of the CBSA’s priorities is to continue to build and work on improving labour relations. CBSA continues to seek out opportunities to increase bargaining agent involvement in workplace matters.

CBSA's Language of Work project’s objective is to reinforce the respect and support of employees’ linguistic rights. The Official Languages Division is hopeful that funds will be allocated to launch the project prior to end of fiscal year 2005-2006. In accordance with the Directive on Staffing of Bilingual Positions, the CBSA is now staffing more bilingual positions on an imperative basis.

With Job Hazard Analysis (JHA) commitments for fiscal 2005-2006 on target for completion with minor exceptions, the CBSA is assuring a healthy and safe workplace. In the area of Policies and Procedures, the Agency anticipates 100% completion. In the area of Officer Training and Provision of protective and uniform equipment, the CBSA anticipates getting very close to 100%; any slippage in this area will be minimal. Facilities improvements will be completed as recommended. Health and Safety management and accountability systems and processes are on schedule for completion with no known barriers.



Workforce Unrated

A workforce that is productive, principled, sustainable and adaptable in order to provide best services to Canadians, as evidenced by:

  • The size, mix of skills and diversity of backgrounds to competently perform its duties;
  • Reflective of Canada’s population, respectful of Canada’s official languages and performs its duties guided by the values and ethics of the Public Service;
  • Renewable and affordable over time;
  • Versatile, innovative and engages in continuous learning.
Trends in tenure of workforce, transfer out rate and separation rates and retirement age are all similar to public service averages.

CBSA has an opportunity for improvement with regards to language of work.

Employment Equity (EE) representation levels will be confirmed following the current workforce self-identification campaign with a target date of early Spring 2006 for final results. Once representation levels are known, the 2005-2006 EE strategy will identify specific targeted strategies to address gaps. The CBSA Resourcing Program will allow managers increased flexibility to better target required skills for program delivery. The CBSA has committed to hiring from the EX-01 Visible Minority selection process currently being conducted by the Public Service Commission (PSC).

Employees in designated bilingual offices for services to the public are regularly reminded of their obligations under Part V of the Official Languages Act (OLA). An action plan is currently being implemented in response to audit findings.

The CBSA has developed a web-based learning product for employees who have face-to-face interactions with internal and external clients of the CBSA. This product will be on top of diversity concepts already imbedded into other training modules covering specific functions at a port.

The CBSA and the Canadian Human Rights Commission (CHRC) entered into a Memorandum of Understanding (MOU) on December 7, 2005 that describes how the CBSA and the CHRC will collaborate on preventative strategies, including training, aimed at reducing discrimination and ensuring complaints are resolved quickly.



Employment Equity Unrated

Embracing Change objectives for visible minorities met, and workforce availability targets met for designated groups, as evidenced by:

  • Demonstrated results in meeting Embracing Change targets for: 
    • recruitment;
    • promotions;
    • EX appointments.
  • Specific initiatives planned or underway to meet targets of Workforce Availability (WFA) for:
    • women;
    • persons with disabilities;
    • Aboriginal persons;
    • visible minorities.
This is a relatively new department so data are insufficient or not available for the purpose of assessment. The department has demonstrated an interest and willingness to excel in this area (i.e. management is engaged, PSHRMAC contacted for information, undertaking a self-id survey).


HR Planning Opportunity for Improvement

A well-developed Human Resources (HR) planning process integrated with its business planning, as evidenced by:

  • HR planning aligned with the organization’s strategic outcomes and integrated with business planning;
  • HR planning incorporating future needs, effective recruitment and retention, succession planning, learning and diversity.
The CBSA is developing an integrated HR planning process:
  1. Determining business goals (based on Discussion of the Speech from the Throne, TB priorities, CBSA’s Strategic Plan and RPP).
  2. Scanning the environment (Deliverables: External and internal scans and workforce analysis). The goal is to have a process that will integrate EE, OL, skills requirements and demographics for a comprehensive Agency plan.
  3. Conducting a gap analysis at the local, regional national and program levels.
  4. Measuring, monitoring and reporting on progress (Deliverable: integrated process).
  5. Setting HR priorities and developing strategies to achieve business goals (Deliverable: local, regional and national action plans).

An approved process and certain tools will be completed by end of fiscal year 2005-2006. In particular, one component of the HR planning process has been the development of a resourcing strategy that involves training, looking at attrition rates, succession planning and identification of future trends and changes to the business line. Workshops are near completion, which will assist managers in doing comprehensive HR planning. Horizontal integration is being achieved through a CBSA Planning Network at the Headquarters level. Vertical integration is being achieved through a Human Resources Regional/Branch Planning Consultation Network. The HR planning function has recently been integrated with the Resourcing and Employment Equity Division to facilitate better integration between the planning and resourcing functions and the development of integrated strategies which include recruitment, development, apprenticeship and learning.

Explicit consideration is being given by programs to the HR implications of achieving the Agency’s priorities, goals and objectives outlined in its Three-Year Strategic Plan, and this will be reflected in the Agency’s RPP.



Official Languages, language of work Opportunity for Improvement

Legislation and policy on Official Languages in the workplace respected, as evidenced by:

  • Composition of the workforce reflecting the presence of both official language communities of Canada;
  • Incumbents of positions with bilingual requirements meeting those requirements;
  • Use of the official language of their choice by employees in bilingual regions;
  • Availability of communications, tools and products in both official languages in bilingual regions;
  • Availability of training in both official languages.
CBSA is striving to make the workplace in a bilingual region conducive to the use of both official languages. The institution recognizes the fact that a great deal of work has yet to be done, particularly with respect to electronic communications in the two official languages. In general, tools and products are available in both official languages in the designated bilingual areas, and the employees have access to training in the official language of their choice. The CBSA reports in its official languages review that it has made major efforts to enhance the language capacity of its supervisors and employees who provide services to employees. Without official data from the Position and Classification Information System (PCIS), we cannot track the progress made. The CBSA has implemented a project to improve communications between the bilingual areas and Headquarters. The Agency agrees to examine the cultural and structural obstacles to employment in both official languages within the institution over the course of 2005. We do not have any official data on the representation of French-speaking and English-speaking Canadians.

Source: CBSA’s 2004–05 Official Languages Annual Review



Performance Review Acceptable

An effective performance assessment process, as evidenced by:

  • Performance agreements that:
    • Have specific outcomes and are results- based;
    • Clearly identify expectations in line with Clerk’s priorities;
    • Require sound financial and human resource management
  • Rigorous performance assessment process (e.g. quality and distribution of performance pay) and HR follow up.
The distribution of ratings was within expected distribution, including some "Did Not Meet" ratings. Organization expenditure for lump sums was within budget.

The percentage of EXs who received a bonus was slightly lower than for the rest of the public service.



Readiness for Public Service Modernization Act (PSMA) Implementation Opportunity for Improvement

New legislation and delegations of authority, policies and procedures in place, as evidenced by:

  • Collaborative labour relations;
  • Training, tool kits, guides and other supports available for managers and HR professionals;
  • Current and future needs identified leading to their use in clear staffing criteria;
  • Internal policies, procedures and monitoring to ensure consistent and fair implementation of new Act.
PSLRA:

Both LMCC and ICMS internal policy development were still underway in August (five months after CIF of legislation) although it was indicated that LMCC was holding meetings. Other elements not started as of August included Co-development, Two-tier bargaining (although interested), Exclusions, and Essential Services Agreement. Grievance and Adjudication policy was underway with intention to manage own cases. No training had been done of staff, either internally or at the school. Work had not started on the FAA policy and internal delegation.

PSEA:

An ADAI and sub-delegation arrangements have been approved, with all mandatory policies and processes also approved. Training has been provided to 90% of managers and 100% of HR. The establishment of mechanisms for PSEA monitoring and reporting are underway. A CBSA resourcing policy suite was approved by the CBSA President prior to PSEA Coming-Into-Force, after consultation with management, HR Professionals and union members. The resulting policies will be placed on the CBSA intranet site. As well, conferences to review staffing policies, receive information on the PSST, Official Languages and Employment Equity were held in Toronto and Montréal in November 2005 for HR professionals and HR Directors. HR Specialists have also attended Get Ready Phases 1 and 2. A majority of HR professionals have written the AFKT test and been successful. The Agency has been going through aspects of classification reform (implementation of new short form generic job description and a new classification standard - FB) that are aligned with the PSMA. Classification delegation instruments are in place at the Agency.


Stewardship

Capital Assets Acceptable

Effective investment planning in capital assets, as evidenced by:

  • Adequate information on condition and use of capital assets in support of investment planning;
  • A long-term plan that integrates all capital asset classes (real property, materiel and IM/IT); and,
  • A clear linkage between asset and program delivery.
From a fixed infrastructure perspective, CBSA engaged senior management in long-term infrastructure planning. The commitment of senior management is evidenced by the recently formed Infrastructure Committee, chaired by the President with all Vice Presidents as members. The committee has adopted an effective approach and principles for planning, funding and implementing infrastructure projects. As noted in the previous MAF assessment, CBSA is to present to TBS its Long-Term Capital Assets Plan (LTCP) in 2005-06. CBSA is set to comply and will seek TB approval in this fiscal year as previously directed. In addition, CBSA is involved in ongoing discussions with OGDs (TC, Infrastructure, PSEPC, RCMP, CSC) to ensure that CBSA is provided with adequate facilities pursuant to Section 6 of the Customs Act. * In summary, CBSA made good progress in this area but CBSA's LTCP remains a major outstanding deliverable.


Financial Analysis Acceptable

Solid financial analysis, as evidenced by:

  • Frequent and accurate year-end forecasts and variance reporting (most especially at mid-year) showing the organization’s true financial status;
  • Analyses of high-risk areas in relation to reference levels by program activity and major funding approvals (real and projected) including anticipated funding pressures and re-profiling trends; and,
  • A reasonable history of carry forwards and lapses.
While CBSA has reduced its lapses, particularly related to PSAT funding, the amounts of lapses and carry-forward are still significant. However, CBSA's legislation, allowing for a two-year appropriation, has come into force in December, 2005, meaning that the Agency will be able to manage its resources over two fiscal years. With this in mind, it is expected that CBSA's lapses will not be a concern. In addition, CBSA included regular audits of financial controls in its Internal Audit Plan in order to support accurate financial analysis and reporting. CBSA is consistently using a risk-based approach in their financial planning. Financial and corporate information at CBSA from three legacy organizations was integrated into one information system, which is hosted by CRA. In Budget 2005, CBSA received approval of significant capacity funding. While CBSA made good progress in staffing of financial advisors with this funding, some capacity issues in this area remain, mainly due to the increased demand on these resources to provide input into substantial government initiatives, such as the SPP. While the quality of the financial analysis provided by CBSA is good, there is often an issue of timeliness with CBSA reports, likely for the same reason. For instance, the deadline for the provision of the PSAT report was missed. * CBSA is making good progress towards meeting this deadline. In addition, CBSA undertook to harmonize its internal management policies with TBS policies, with a list of such policies to be provided to TBS by April 1, 2006.


Information and IT Management Opportunity for Improvement

An IM/IT vision and strategy supportive of the organization’s business strategy and government- wide directions, as evidenced by:

  • A governance structure that includes program representation and is effective in priority setting of IM/IT investments and resources;
  • IM/IT enabled projects that have effective governance and are executed well;
  • Strategy and approved plans that reflect a Government of Canada (GoC) Enterprise approach to common IT services;
  • Implementation of Management of Government Information (MGI) Policy strategy, based on an IM capacity assessment; and,
  • Integrated privacy and security measures.
CBSA has been mandated by TBS to complete an A-base review *. A governance structure is in place to oversee the review. * An IM/IT plan will arise from the A-base review.

CBSA is also in the nascent stages of doing an IM capacity check and will need to work to harmonize its IM strategy and practices.

CBSA likely will not comply with the standard on the Management of IT Security (MITS) by December 2006. CBSA has currently completed or almost completed 59% of its MITS requirements, and some fundamental organization and risk management requirements are lacking. The risk is exacerbated by the fact that the CBSA environment is complex, 80% of their systems are critical, and there are dependencies on shared services with the Department of Citizenship and Immigration and with the Canada Revenue Agency.



Internal Audit Function Acceptable

An effective internal audit function, as evidenced by:

  • An appropriate infrastructure to effectively discharge its internal audit responsibilities as outlined in the Internal Audit Policy (governance structure and appropriate level of resources);
  • A completed risk-based audit plan; and,
  • All reports including progress reports are submitted to TBS for follow-up activities.
Canada Border Services Agency was created in December 2003. Most elements of the infrastructure to discharge audit responsibilities are in place. Audit Committee is chaired by the President and meets three to four times annually (with two external members, one of whom is from another department). Risk-based audit plan received for 2005-2008. To our knowledge, all audit reports are submitted to Treasury Board Secretariat.


Management of Transfer Payments Not Applicable

Effective Transfer Payment Program management in place, as evidenced by:

  • Timely renewal of transfer payment programs;
  • Departmental internal audit plans include provision for the review of internal management policies, practices and controls of transfer payment programs;
  • Regular audit of transfer payment programs and follow-up.
CBSA makes no grants and contributions.


Materiel Management Acceptable

An appropriate materiel management framework in place, as evidenced by:

  • Clear accountabilities consistent with organizational capacity; and,
  • Reliable life- cycle cost and performance information that supports decision- making.
The CBSA practices life-cycle management for its assets. This includes an End User Replacement Plan for desktop computers, laptops and printers (as mandated by the TBS decision letter for the CCRA 2001 Resource Management Review). A similar plan exists for telecommunication assets such as PALS Radios. The CBSA Fleet Review is in its final stages. A vehicle matrix identifying type of vehicle against business line has been consulted on nationally and has been approved. Companion pieces to the Review, including a vehicle replacement formula, recommended vehicle maintenance guidelines and an ongoing monitoring regime have been developed. Most importantly, the entire CBSA fleet of 882 vehicles has been analyzed with respect to usage and a significant number of vehicles identified for reallocation which will result in optimal size and composition of the Agency's fleet requirements in a cost-effective manner.


Procurement and Contract Management Acceptable

Risk-based approach to procurement and contracting management, as evidenced by:

  • Clear delegations of authority are tied to knowledge and capacity;
  • Demonstrated compliance with delegated contracting authorities and conditions identified by Treasury Board policy; and,
  • Explicit oversight, monitoring and on- going review of procurement and contracting function and processes (e.g. Contracts Review Committee, quality of contracting data, timely completion of contracts over $10,000 disclosure information, implementation of audit recommendations where applicable, etc);
  • Methods for procuring demonstrating the most cost-effective end-to-end process.
CBSA , established in December 2003, is continuing to put the necessary management controls for the procurement function in place. CBSA headquarters has 11 personnel dedicated to contracting as well as six people working on policy, quality control and training.

Contracting at CBSA represents less than 1% of the Federal Government activity and volume. In 2004, CBSA awarded 1,987 contracts valued at $11,495K, 97% (1,934) of which were under $25K.

CBSA made 8,942 acquisition card purchases for a value of $2.2M, at an average transaction value of $248.

The CBSA has met its reporting requirements under the Proactive Disclosure of Contracts over $10K. CBSA reported 962 contracts under the Proactive Disclosure of Contracts Over $10K for a value of $44.8M, of which six contracts exceeded $261.3K for a value of $2.9M or 6.5% of contracts over $10K.

CBSA is identified as having low risk in relation to the USA Patriot Act.



Project Management Acceptable

Risk-based project management approach, as evidenced by:

  • An integrated, achievable up-to-date long-term capital plan or planning document in place that is being implemented (linked to the organization’s key priorities);
  • Explicit project management accountability framework, that addresses decision- making and oversight and effective monitoring and ongoing review;
  • Properly resourced projects (e.g. project management capacity, appropriately trained officials);
  • Demonstrated compliance with delegated project approval requirements and conditions identified by Treasury Board.
The CBSA is finalizing its LTCP, which will be submitted to TBS in March, 2006.

The DPR states that the Agency has “developed a systematic project management approach and implementation plan with reporting mechanisms to senior management.”

CBSA reports projects in their DPR (2003-2004) amounting to $239M in total estimated cost.

There are acknowledged delays in some of the projects and CBSA is working to resolve issues.

The CBSA has had success with a number of IM/IT projects, which have achieved national and international recognition.



Quality of Treasury Board (TB) submissions Acceptable

Quality TB submissions, as evidenced by:

  • Draft submissions regularly vetted through common departmental quality control to ensure consistency, clarity and conciseness; 
  • Accurate, substantiated and comprehensive financial components; and,
  • Frequency with which TB conditions are imposed.
The quality of CBSA's TB submissions has significantly improved since the last assessment. CBSA has put in place the necessary resources to ensure an internal vetting process by the Resource Management Directorate within its Comptrollership Branch.

CBSA has developed and has consistently applied its costing model in support of funding requests. There have been a number of TB conditions imposed but most of them were related to the standard PSAT funding conditions and to the upcoming CBSA A-base review. Having said that, CBSA could further improve the quality of TB submissions by providing more thorough options analysis and risk assessment, specifically on projects involving a technology component.



Real Property Acceptable

An implemented real property management framework to meet its obligations under TB Real Property policies, as evidenced by:

  • An organizational structure which includes clear accountabilities and appropriate delegations;
  • Integrated support systems; and 
  • An information management framework to provide complete and accurate inventory data.
The Canada Border Services Agency Act (Bill C-26) received Royal Assent on November 3, 2005 and came into force on December 12, 2005. Since CBSA is now in a position to take over custodianship of its real property assets, it has moved forward on the development of a long-term National Infrastructure Plan that will clarify policies, processes, roles and responsibilities and priority setting for the management of its assets. *


Treasury Board (TB) conditions Acceptable

Organizational compliance with conditions imposed by TB, as evidenced by :

  • Timely compliance;
  • Adequate engagement with TBS; and,
  • Appropriate reporting.
Since its creation, CBSA has not had many conditions imposed. *

Citizen-focused Service

External Service Delivery Strategy Opportunity for Improvement

Client centred external service delivery strategy that drives efficiencies, respects client privacy rights and reflects an enterprise view of government services and that results in effective external service delivery, as evidenced by:

  • Review of key public-facing services to achieve measurable improvements in responsiveness to client needs, effectiveness and value for money;
  • Partnerships with other programs, organizations or jurisdictions to achieve more client-centric or cost-effective service delivery or to align program rules and regulations (e.g., Memoranda of Understanding (MOUs)/service level agreements in place when partnerships established);
  • Measurement of the cost-effectiveness of delivery by channel and migration of clients to lower cost channels where appropriate; and
  • Measurement of client satisfaction in a transparent way (e.g., reporting to clients and Parliament) using the Common Measurement Tool, and use of the results to guide continued improvement in client satisfaction.
Rethinking Public-facing Services:
  1. The Border Services NEXUS highway program received the Gold Medal at 2005 GTEC for Innovative Service Delivery to Citizens and Businesses (CANPASS Air received Bronze in 2004 for the same category) and an APEX award (Leadership in Service Innovation) in May 2005.*

Pursuing Program Partnerships:

  1. The 2005 target for new partnerships was met.

Measuring Cost-effectiveness / Channel Migration:

  1. TBS is unaware of any specific activity undertaken by CBSA to measure the cost-effectiveness of service delivery channels.

Client-satisfaction:

  1. The Agency has registered for the Common Measurement Tool (CMT). The legacy work on service improvement (former CCRA service elements) continues to be excellent. Work on the development of a more comprehensive set of standards and improved information systems to support measurement against them did not advance over the past year. The Agency has not reported client satisfaction results or its performance in the development and publishing of service standards for the former Canadian Food Inspection Agency (CFIA) service element (Import Inspection Program). The Agency should broaden its service improvement activity as outlined in the Service Improvement Policy to include all applicable service offerings.

Horizontal Solutions (enterprise-wide initiatives): Not applicable



Government-wide Services Opportunity for Improvement

Internal service delivery supportive of enterprise- wide (Government of Canada-wide) approach (e.g. shared and common services and infrastructure in IT, HR, Finance, Materiel), as evidenced by:

  • Commitments met on using Secure Channel services (timing and transaction volumes);
  • Active participation in enterprise-wide initiatives and adoption of Shared service and systems.
Internal Services:
  1. CBSA prefers to participate in CA-SSO implementation at a time subsequent to CAS Wave 1.
  2. The agency is engaged in broad community discussions and provides input in dialogue on enterprise wide internal service delivery for Corporate Administrative Services (HR, Finance and Materiel Management) and IT services.

Secure Channel:

  1. All departments and agencies participate in common, core Secure Channel services: Data Network Service, Secure Application Key Management Service and Federated Infrastructure National Directory Service.
  2. There are no known plans to integrate program delivery applications with Secure Channel.


Official Languages for External Service Delivery Opportunity for Improvement

External communications in both official languages, as evidenced by:

  • Availability of communications, tools and products in both official languages, for external services to clients.
The institution indicates that it continues to work toward ensuring that its offices that are designated bilingual have a sufficient bilingual capacity to meet its language obligations. The Ontario Region reports that it has increased the number of the bilingual resources, and it is pursuing its efforts in this matter. Without data from the Position and Classification Information System (PCIS), we cannot track the progress made. However, according to the Office of the Commissioner of Official Languages which has audited some places of entry and whose final report was expected in late October, the situation in Ontario is such that there is room for improvement with respect to availability of bilingual service and active offer of service. The results of the 2003 telephone audit were good for the availability of service, but the active offer was not impressive for most of the provinces. No major deficiencies were identified with respect to the availability of tools and products for the public in both official languages.


Service Delivery and User Fees Opportunity for Improvement

Compliance with service delivery and user fee requirements, as evidenced by:

  • Performance information for all user fees to which the Act applies; it is based on the DPR (or an alternative report employed by the department) and observations of departmental compliance with the User Fees Act relative to the disclosure of service standards.
* Further to the parameters of this indicator, however, Treasury Board Secretariat will assess all Departmental Performance Report user fee information against the reporting requirements of the User Fees Act. Notwithstanding the application boundaries of User Fees Act requirements, performance information presented indicates opportunity for improvement: No performance standard or result information is included for any of the 15 listed fees. The department has noted its intent to establish standards and report performance pursuant to the Policy on Service Standards and according the timeline provided by that framework. Policy on Service Standards for External Fees requires compliance by 2005-2006 Departmental Performance Report. The department has indicated its intent to have service standards established within the prescribed timeframe.

Accountability

Authorities and Delegations Acceptable

Compliance with approved financial authorities and delegations, as evidenced by:

  • Issues identified through departmental contacts, Internal Audit reports, Office of the Auditor General (OAG) reports, by Program Sectors, and through review of media reports or other relevant sources of information.
Nothing has come to the attention of the Office of the Comptroller General that would suggest there is a performance issue. This conclusion follows a review of the Office of the Auditor General and the Office of the Comptroller General Internal Audit Sector databases, and departmental/agency internal audit sites for significant information related to events and/or activities related to financial management policies, which occurred in either fiscal years 2003-2004 and 2004-2005.