Core Control Audit of the Commission for Public Complaints Against the RCMP

April 2011
Office of the Comptroller General

Objective and scope

The objective of this audit was to ensure that core controls over financial management within Commission for Public Complaints Against the RCMP (CPC) are effective and result in compliance with corresponding legislation, policies, and directives.

The scope of this audit included an examination of a sample of transactions from each of the policies and directives indicated in appendix 1 of this report. The transactions were taken from April 1, 2009 to March 31, 2010.

The scope was limited due to memorandum of understandings with other Canadian Federal Institutions who are responsible on behalf of the Commission for Public Complaints Against the RCMP for certain requirements in these policies and directives.

This audit was conducted in conformance with Government of Canada Internal Auditing Standards and the International Standards for the Professional Practice of Internal Auditing.Footnote 1

Audit findings

The Commission for Public Complaints Against the RCMP has complied with the legislation, policies, and directives in the areas of financial management. More effective controls are needed to ensure that commitments are approved by someone with the delegated authority to do so and are recorded at the time of expenditure initiation. There is a need to ensure that documentation exists to support contracting decisions and that contract amendments are appropriately justified and accomplished prior to the expiry of the original contracts. There is also a need to ensure that travel files contain justification for any exceptions to the National Joint Council Travel Directive.

Conclusion

Core controls over financial management within the Commission for Public Complaints Against the RCMP are effective and are generally executed in compliance with corresponding legislation, policies, and directives.

Areas of non-compliance were brought to the attention of management in the Commission for Public Complaints Against the RCMP. Management has acknowledged the audit findings and has resolved to take action. The Commission for Public Complaints Against the RCMP has provided the Office of the Comptroller General with the management action plan to address actions taken towards the findings. The Office of the Comptroller General will follow up on the management action plan until all findings are resolved.

Brian M. Aiken, CIA, CFE
Assistant Comptroller General
Internal Audit Sector, Office of the Comptroller General

Appendix 1: Policies and Directives Tested

Financial Management

  • Directive on Delegation of Financial Authorities for Disbursements
  • Directive on Expenditure Initiation and Commitment Control
  • Directive on Account Verification
  • Directive on Acquisition Cards

Contracting

  • Contracting Policy

Travel and Hospitality

  • National Joint Council Travel Directive
  • Directive on Travel Cards and Travellers Cheques
  • Hospitality Policy

Human Resources

  • Membership Fees Policy
  • Policy on Learning, Training and Development
  • Directive on Leave and Special Working Arrangements
  • Directive on Financial Management of Pay Administration
  • Performance Pay AdministrationFootnote 2
  • Casual Employees

Management Action Plan

Commission for Public Complaints Against the RCMP's Opinion of the Audit Report:

CPC has reviewed the findings and recommendations and, as far as the scope of this audit is concerned, these accurately reflect the state of control over financial management, contracting, travel & hospitality and human resources.

Audit Entity Sign Off on the Management Action Plan

Ian McPhail, Q.C.
Interim Chair

Recommendations Priority Response Planned Actions Responsibilities
(position title responsible for the action) 		Timelines
1. The CPC should ensure that expenditure initiation is approved by an individual with the delegated authority to do so. HIGH Management agrees with the recommendation. Revision of CPC's hospitality form to include a signature line for certification of expenditure authority of the Deputy Head by the Chief Financial Officer (CFO) / Deputy Chief Financial Officer (DCFO). DCFO Revised hospitality form by May 20, 2011
Refresher training sessions for managers and their administrative assistants on financial delegation, including expenditure initiation. DCFO Training sessions to encompass all training needs from Management Action Plan (MAP). Sessions to be determined by end of the first quarter of 2011-12.
Subsequent training sessions will be given to new managers and/or their administrative assistants. DCFO On-going
2. The CPC should ensure that expenditure initiation is approved before expenses are incurred. HIGH Management agrees with the recommendation. Revise CPC's procedures on acquisition cards and on travel to ensure compliance with expenditure initiation. DCFO May 20, 2011
Create a "membership form" to capture the expenditure initiation. DCFO Completed January 2011
3. The CPC should ensure the approval of the CFO is obtained for the distribution and credit limit of acquisition cards. HIGH Management agrees with the recommendation. As per planned action for recommendation no. 2, revise CPC's procedures on acquisition cards to reflect CFO approval, including credit limits of acquisition cards. DCFO May 20, 2011
4. The CPC should adopt a formal process for ensuring non-competitive contracting files contain all the appropriate documentation, including:
  • reason for non-competition;
  • consideration of standing offers and supply arrangements;
  • justification for awarding non-competitive contracts and amending contracts;
  • why the contract is directed to the chosen supplier; and
  • why the price is considered fair and reasonable in absence of competition.
 HIGH Management agrees with the recommendation. Establishment of a checklist for contracting to ensure appropriate supporting documentation is on file for contracts. DCFO Checklist established by May 20, 2011
The training sessions identified in planned action no.1 would include documentation for contracting. These sessions will be provided to managers and their administrative assistants to ensure that the proper supporting documents are on file by using the tools to assist in the tracking of each contract. DCFO Training sessions to encompass all training needs from MAP. Sessions to be determined by end of the first quarter of 2011-12.
5. The CPC should ensure that contract amendments are issued prior to the contract expiry date. HIGH Management agrees with the recommendation. Create a form, highlighting to the manager when approving contract invoices, the remaining commitment and end date of the contract to ensure that an amendment is processed, if applicable. DCFO Form and procedures in place by May 20, 2011.
As per planned actions in recommendation no. 4, training sessions will be provided to managers and their administrative assistants with the emphasis in the contract training to be on the importance of amending contracts as soon as a shortfall of time or money is known. DCFO Training sessions to encompass all training needs from MAP. Sessions to be determined by end of the first quarter of 2011-12.
6. The CPC should ensure that all travel files contain documentation for travel authorization and justification for any exceptions to the Travel Directive including accommodations and rental cars. MEDIUM Management agrees with the recommendation. The Administrative Officer within Corporate Services is the Travel Coordinator. The officer has significant experience in travel and is responsible to review all travel claims before they are sent to the Finance Office for payment. Any anomalies will be addressed and corrected by the manager before the claim is forwarded to the Finance Officer for processing. In addition, the Administrative Officer is available to assist all employees on questions regarding their travel plans or claims. DCFO CPC's Travel Policy to include Travel Coordinator's roles and responsibilities and the revised procedures by May 20, 2011.
Training to be developed for managers and administrative assistants on travel documentation with a particular emphasis on the importance of supplementary documentation and justification on file for any exceptions. DCFO Training sessions to encompass all training needs from MAP. Sessions to be determined by end of the first quarter of 2011-12.
7. The CPC should ensure that it obtains and keeps on file written acknowledgment of responsibilities and obligations from all travel card holders. MEDIUM Management agrees with the recommendation. A review of all current card holders written acknowledgement forms has been completed and updated where necessary. Procedures are now in place to ensure that written consent forms are on file for all future card holders. DCFO Completed March 2011
8. The CPC should ensure that documentation exists to provide support that hospitality events are planned and conducted in an economical and appropriate way to facilitate government business, which is consistent with the events' circumstances. MEDIUM Management agrees with the recommendation. The training sessions identified in planned action for recommendation no. 1 would emphasize the decision making process of hospitality events and ensure that requests include the supporting rationale. DCFO Training sessions to encompass all training needs from MAP. Sessions to be determined by end of the first quarter of 2011-12.
9. The CPC should ensure that all annual leave requests are pre-authorized by an individual with the delegated authority to do so. MEDIUM Management agrees with the recommendation. Letters of Authority to be given to those supervisors who have not received delegated authority to approve leave. DCFO Delegation approved for current supervisors completed in March 2011.
Revise CPC's policy on Administration of Leave to ensure that it is in keeping with the delegation of authority matrix. DCFO May 20, 2011
Revise the CPC's delegation of authority on human resources to reflect the delegation assigned to supervisors. DCFO May 20, 2011