Internal Audit Reports - Management Action Plan

Subject Matter
Accountability

The Internal Audit Report is a management tool used to improve the efficiency and effectiveness of the Commission’s activities, while demonstrating accountability and stewardship of resources. The Report also includes a Management Action Plan to implement recommendations.

Management Action Plan
Core Control Audit of the Canadian Human Rights Commission

Both myself as Secretary General and the Commission's Senior Management Committee (SMC) have reviewed the findings and recommendations of the Core Control Audit. As far as the review of the evidence used to support this audit, this report accurately reflects the state of control over financial management, contracting, travel & hospitality and human resources. It is important to note that while we agree and will implement corrective measures to address the findings and subsequent recommendations of this audit report, I believe it is also important to highlight the diligence and integrity of the work of the employees responsible for the day to day implementation and compliance with the range of Central Agency Policies and Directives tested within this audit.

Overall, I am of the opinion that the audit has determined that the Commission meets all the tested requirements with some exceptions. Each of these exceptions has been reviewed with the Director General of the Corporate Management Branch and I am assured that neither a lack of attention nor lack of training has been identified. In general, a stricter adherence to record keeping and information management within file control will improve our subsequent rating through the evaluation of the attached implementation measures and future audits.

Audit Entity Sign Off on the Management Action Plan

Karen Mosher
Secretary General
Canadian Human Rights Commission

Signed February 14, 2012

OCG Core Control Audit Recommendations
1. The CHRC should ensure that expenditure initiation and individual commitments are approved, prior to expenses being incurred, by an individual with the delegated authority to do so and recorded in the financial system.
Response and Planned Actions CHRC
Priority Level		 OPI Timelines
ACQUISITION CARDS: CRITERIA ii) NOT MET [67%] - Response: AGREED - - -
Planned Actions:

1.1 Administrative refresher training regarding Use of Acquisition Cards to be re-scheduled and delivered prior to March 31, 2012

 High Manager Procurement & Director F&A March 31, 2012
1.2 The existing CHRC Acquisition Card Policy will be reviewed based on the changes to the recently revised TBS Directive. High Director
F&A		 June 30, 2012
1.3 The employee Acknowledgement of Responsibilities and Obligations Form will be revised to include a specific reference regarding timelines. Following the refresher training (above item 1.1), each acquisition card holder will review the form and re-sign. High Director
F&A		 March 31, 2012
ACCOUNTABLE ADVANCES: CRITERIA iv PARTIALLY MET [80%] - Response: AGREED - - -
Planned Action:

1.4 When an accountable advance is received by the Financial Unit and does not meet all the required criteria, the item will be returned to the program area with a written explanation note (memo or e-mail) indicating the corrective measure required. This note will include a copy to the financial supervisory position and be retained on file with the claim.

 High Director
F&A		 October 2011
HOSPITALITY: Criteria ii) NOT MET [75%] - Response: AGREED - - -
Planned Action:

1.5 A reminder message will be posted on the Commission's employee intranet site (Infozone) to ensure that all amounts budgeted under line object 046 (Hospitality and Conferences) must be accompanied by a completed pre-authorization form. The reminder will include a link to the electronic form.

 High Manager,
Finance Policy		 March 31, 2012
1.6 This item will be specifically addressed during the next financial Administrative refresher training (see Action item1.1) High Manager,
Finance Policy		 March 31, 2012
FINANCIAL MGT OF PAY ADMINISTRATION: Criteria i) PARTIALLY MET [84%]
Response: AGREED		 - - -
Planned Action:

1.7 Instructions on how to complete the overtime form will be presented to the CHRC Committee of Senior Officers (COSO) at the October meeting to clarify use of the form and review manager obligations.

 High Manager,
HR		 October 26, 2011
1.8 In cases where overtime is pre-authorized by e-mail, a print copy of the authorization shall be filed with the overtime form; however, the preferred process is to have the form completed in accordance with the instructions that will be presented at the COSO meeting (above item 1.7). High Manager,
HR		 October 26 2011
OCG Core Control Audit Recommendations
2. The CHRC should ensure that account verification is performed by someone with the delegated authority to do so and on a timely basis.
ACQUISITION CARDS: CRITERIA iii) PARTIALLY MET [89%] - Response: AGREED - - -
Planned Actions:

2.1 One-on-one refresher training will be given with each card holder involved in the above five instances (involving four cardholders).

 High Director
F&A		 October, 2011
2.2 Refresher training regarding Use of Acquisition Cards to be re-scheduled and delivered prior to March 31, 2012 (see item 1.1 of this report) High Manager
Procurement & Director F&A		 March 31, 2012
2.3 Following the refresher training (item 1.1), each acquisition card holder will review the card holder form with an emphasis on the timeline inclusion, and re-sign. High Manager
Procurement		 March 31, 2012
ADVANCES: CRITERIA v) PARTIALLY MET [84%] - Response: AGREED - - -
Planned Action:

2.4 When an accountable advance is received by the Financial Unit and does not meet all the required criteria (including documentation), the item will be returned to the program area with a written explanation note (memo or e-mail) indicating the corrective measure required. This note will include a copy to the financial supervisory position and be retained on file with the claim.

 High Director
F&A		 October, 2011
CONTRACTING POLICY: Criteria vi) NOT MET [73%] - Response: AGREED - - -
Planned Actions:

2.5 Prepare a checklist of required action and documentation to be maintained with each active file regarding Section 33 and 34.

 High Manager
Procurement		 March 31, 2012
2.6 Implement the MAF Round IX questionnaire for AOM 7 (Finance) and AOM 11(Procurement) as an opportunity to self-evaluate and ensure that the proposed checklists are properly implemented and meeting documentation requirements. High Manager, Planning & IA June 30, 2012
2.7 Include file sampling against checklist requirements in the next Internal Audit and Evaluation Plan. High Manager, Planning & IA April 1, 2012
HOSPITALITY POLICY: Criteria iii) PARTIALLY MET [84%] - Response: AGREED - - -
Planned Actions:

2.8 This item will be specifically addressed during the next financial Administrative refresher training (see Action item1.1)

 High Manager
Finance Policy		 March 31, 2012
FINANCIAL MGT OF PAY ADMINISTRATION: Criteria ii) PARTIALLY MET [89%]
Response: AGREED		 - - -
Planned Actions:

2.9 Instructions on how to complete the overtime form will be presented to the CHRC Committee of Senior Officers (COSO) at the October meeting to clarify use of the form and review manager obligations.

 High Manager,
HR		 October 26, 2011
2.10 Include overtime file sampling against requirements in the next Internal Audit and Evaluation Plan. High Manager, Planning & IA April 1, 2012
OCG Core Control Audit Recommendations
3.The CHRC should follow established business processes, including checklists, and keep documentation to ensure:
  • justification for the contracting strategy chosen;
  • evidence of best value analysis;
  • evidence of contractor security clearance is on file;
  • contracts are issued before goods or services are received;
  • contract amendments are signed before the original contracts expire.
CONTRACTING POLICY STRATEGY: NON-COMP - NOT MET [38%]
Response: AGREED		 - - -
Planned Actions:

3.1 Prepare a checklist of required documentation to be maintained as evidence in supporting contracting decisions including the awarding of contracts.

 High Manager
Procurement		 March 31, 2012
3.2 All submissions to the Contract Review Committee (CRC) must have met the minimum criteria for: strategy chosen (including detailed justification); rating guide for best value analysis; and, security requirements, or the submission will be returned to the Program area for additional information. High Manager
Procurement		 September 2011
3.3 Provide refresher training to the CRC members with a focus on the requirements of a thorough justification of chosen strategy; understanding methods of best value analysis; and, amendment criteria. High Director
General - Corporate Mgt		 September 2011
3.4 Develop a checklist for the CRC members to indicate action required when returning a request for Services/Proposal for additional information. This form will assist and support the Procurement Staff in developing their expertise and preparing submissions that are more comprehensive for the CRC review. High Manager
Procurement		 March 31, 2012
3.5 Include file sampling against checklist requirements in the next Internal Audit and Evaluation Plan. High Manager, Planning & IA April 1, 2012
CONTRACTING POLICY MANAGEMENT - NOT MET [67%] - Response: AGREED - - -
Planned Actions:

3.6 A status regarding the implementation of items 3.1 - 3.5 will be presented at CHRC COSO and SMC committees.

 High Director
General - Corporate Mgt		 June 30, 2012
3.7 In terms of succession planning, the Senior Procurement Officer has provided his retirement plans and the replacement incumbent will meet the PG Certification requirements. High Director
F&A		 May 31, 2012
3.8 Procurement Officer to provide refresher training to the CRC members (item # 3.3 above). High Director
F&A		 Completed
3.9 Include file sampling against checklist requirements in the next Internal Audit and Evaluation Plan. High Manager, Planning & IA April 1, 2012
OCG Core Control Audit Recommendations
4. CHRC should ensure they use appropriate contracting vehicles, which includes using mandatory services as defined in the Treasury Board Common Services Policy.
CONTRACTING POLICY PROCUREMENT STRATEGY - NOT MET [78%]
Response: AGREED		 - - -
Planned Actions:

4.1 An information session will be delivered at COSO to ensure that delegated managers understand that all contracting requests received under “13 Commodity Codes” must be initially reviewed using the PWGSC mandatory tools.

 High Manager
Procurement		 March 31, 2012
OCG Core Control Audit Recommendations
5. The CHRC should ensure that contract files contain evidence of fair, open and transparent bid solicitation and selection methods. The CHRC should ensure any mandatory bid requirements are clearly tied to contract deliverables.
CONTRACTING POLICY STRATEGY: COMPETITIVE - NOT MET [73%]
Response: AGREED		 - - -
Planned Actions:

5.1 Prepare a checklist of required documentation to be maintained as evidence in supporting contracting decisions including the awarding of contracts.

 High Manager
Procurement		 March 31, 2012
5.2 Include file sampling against checklist requirements in the next Internal Audit and Evaluation Plan. High Manager, Planning & IA April 1, 2012
5.3 Refresher training to the CRC members will include a focus on evaluation criteria, bid selection and a review of mandatory requirements to ensure these elements are clearly tied to contract deliverables. High Manager
Procurement		 March 31, 2012
OCG Core Control Audit Recommendations
6. The CHRC should follow established business processes and keep documentation to ensure that accommodations respect the appropriate government limits or justification is documented on file for the use of above-the-limit suppliers.
TRAVEL, TRAVEL CARDS, TRAVELLERS CHEQUES - NOT MET [78%]
Response: AGREED		 - - -
Planned Action:

6.1 The recent introduction of the PWGSC Shared Travel Services Initiative (STSI) will address many of the above observations; however, given that the CHRC continually seeks to improve, a file sampling against Travel, Travel Cards and Travellers Cheques requirements will be included in the next Internal Audit and Evaluation Plan. The sampling will also ensure that justification for exceptional travel circumstances is documented and retained on file

 High Manager, Planning & IA June 30, 2012