Archived - Audit of the Implementation of the Child and Family Services Enhanced Prevention Focused Approach

5.1.1 Governance and Oversight Arrangements

Governance and oversight arrangements for Program activities are the foundation for all other components of internal control, providing discipline and structure. Governance bodies should receive sufficient, complete, timely and accurate information in order to maintain an effective oversight role and ensure that there is adequate challenge and discussion on all matters related to the EPFA. Without adequate governance and oversight arrangements in place for the Program, there is the increased risk of a lack of accountability, challenge, discussion and ability to change direction with respect to responding to significant issues. Ultimately, effective governance is necessary to ensure the achievement of expected results and the monitoring of progress against stated objectives. The audit expected to observe that the governance arrangements in place are sufficient to evidence clearly documented approval of the key aspects of EPFA implementation, including the accountability frameworks, costing models and business plans. In the majority of jurisdictions, evidence of the approval of these documents could not be provided to the audit team due to a lack of an appropriate audit trail.

Within the jurisdictions that have implemented the EPFA, the key oversight bodies are Tripartite Working Groups (or equivalent), comprising representatives from the Program, the Provinces and the First Nations. The Working Groups are established to provide oversight of all aspects of the implementation and generally meet on a quarterly basis. It is noted that not all of the Working Groups have established a formal Terms of Reference and do not always maintain formal records of their meetings.

Without adequate and effective oversight mechanisms there is an increased risk that there would be a lack of evidence to support challenge and decision making, leading to a lack of audit trail and an inability to fully demonstrate transparency and effective governance.

With the Program at HQ, there is no specific oversight body/committee that reviews the implementation of the EPFA or the finances and activities of the Regions/Agencies. We did note, however, that the Regions are tasked with the overall implementation of the EPFA and meet with stakeholders via tripartite oversight committees. In addition, the Program undertakes some oversight activities, including:

• Program staff at HQ meet informally on a weekly basis to discuss ongoing program matters and program implementation and regular discussions also occur daily on a case by case basis;
• The Program facilitates a formal monthly conference call with Regional staff, which discusses all aspects of the Program as well as the EPFA implementation. This includes a roundtable in order to inform HQ staff and other Regions of current and anticipated EPFA issues. This forum also presents Regions with the opportunity to ask each other questions about specific EPFA issues that others may have experience mitigating and allows for knowledge sharing and open discussion;
• The Program and Regions provide quarterly reports to the Associate DM, on the activities and issues relating to the FNCFS and within this the Program and Regions provides status updates on the progress being made on EPFA implementation; and,
• The Program also facilitates 1-2 annual meetings, spread over three days, that enables the Director to hold face to face meetings with Regional representatives to discuss EPFA implementation progress, issues and concerns as well as allowing for general Program discussions on future strategies and policy alternatives.

5.2.1 Planning

Business plans provide the opportunity to look ahead, allocate resources, focus on key activities and objectives, and identify financial and staffing resources, etc. To be effective, business plans should be measureable in order that results can be tracked and compared against expectations.

To help monitor and report on performance against Agency business plans, it is important to have a rigorous and formalized process for periodic review (e.g. at least annually). The purpose of this review is to assess the progress being made against stated objectives, plans and activities and enable the measurement of performance. Ultimately, this will enable the Director General of the Social Policy and Programs Branch to demonstrate the success of the EPFA implementation and the impact of the new enhanced prevention focused approach on child welfare.

The process for the development of business plans works well in that the Program and the Region both provide support, advice, templates/tools and guidance to the Agencies in the early stages of implementation. This provides for both consistencies of approach as well as supporting efficiencies in the approach and, as the Agencies become more experienced and knowledgeable in the development of their business plans over time, this will aid in identifying further efficiencies and help reduce the administrative burden.

All Agencies are required to provide a business plan in order to receive the additional funding for EPFA. It should be noted that the process of business planning is new to the Agencies that are implementing the EPFA and, recognizing this, the Program provided the Regions with a Business Plan Template to ensure a consistency of approach. In addition, Program staff from both HQ and the Regional Offices provided advice and support to the Agencies in the development of their business plans as they transitioned to the new enhanced prevention focused approach in order to help reduce the administrative burden. While audit testing noted that business plans differ in size and complexity between Regions, this is not unexpected due to differing needs, pressures, and caseloads. It was also noted that all of the Agency business plans sampled during audit testing complied with the Business Plan Template and all plans document the activities that are aimed at achieving the stated EPFA objectives.

5.2.2 Budgeting

Effective stewardship includes following a rigorous and timely process for developing budgets and forecasts, including a challenge of resource allocation decisions. It is also important that approved budgets and forecasts are monitored by Regional management regularly.

For EPFA (and child and family services generally) the Program provides the overall funding but does not set the budgets for service delivery. The Agencies that implement the EPFA use their existing child and family services resource allocations with additional incremental funding to support enhanced prevention. It is the combination of the resources that is then applied to the implementation of the new EPFA approach on a flexible funding basis. This flexible funding approach means that the budgets are developed and managed by the individual Agencies and they may manage their budgets as they wish while remaining within the overall budget envelope of total resources. There is an expectation that, in time, the cost of historical child maintenance activities will reduce as the enhanced prevention focused approach becomes fully embedded into the delivery of child and family services.

The allocation of EPFA funds to the Regions and thereafter to the Agencies is based on cost models, each of which is adjusted for each jurisdiction, based on tripartite discussions and reflective of circumstances and need. The cost models consider a range of variables, examples include:

• Number of children served in the jurisdiction;
• Average number of children per family;
• Number of children in care;
• Staffing ratios;
• Administrative overheads; and,
• Agency administration salaries.

The development of the cost models are led by the Program at HQ in order to ensure consistency. The early stages of the development of the cost models includes a process of consultation with the Region and the Province to confirm a common understanding and clear expectations in terms of moving forward. Provinces deliver child welfare through Ministries or Departments that have mandates that are often much broader than simply child welfare. The cost model must therefore reflect the approach to service delivery (e.g. direct delivery by provincial staff, third party service providers, voluntary organizations), and how these services are funded (caseload and staffing ratios, salary scales, etc.).

Subsequent to the initial meetings with provincial officials, numerous tripartite discussions take place with representatives from First Nations, First Nation Child and Family Service Agencies and organizations, the Province and AANDC (HQ and Regional). Tripartite Working Groups are established in all jurisdictions and are tasked with developing the costing model. The Working Groups consider the relevant elements and variables used to determine the funding that will flow to each Agency to deliver the services that are outlined in their business plans, enabling them to achieve their goals and improve outcomes for children and families within their communities.

The funding models are developed collaboratively with First Nations and provincial representatives, and reflect federal funding commitments that meet or exceed provincial funding for comparable funding elements.

Although letters of support are provided through the tri-partite collaborations, we found that, due to a lack of formal meeting records for the Tripartite Working Groups, formal approval of the costing models by these groups could not be evidenced. In addition, there is a lack of documentary evidence that the process and underlying assumptions to develop the cost models and prepare the EPFA budgets are challenged and that decisions resulting from the challenge process are recorded.

Cost models are not revised after they are initially set and there is the risk that they become outdated, particularly with respect to salary increases, Provincial changes to their service delivery models, and Provincial cost pressures. There is a need to analyze and, where relevant, revise the cost models on an annual basis to reflect any changes to the cost-base assumptions during EPFA implementation.

Program Officers in the Regions undertake budget analysis and forecasting against Agency expenditure through the receipt of quarterly reports from the Agencies. While it is acceptable for the Agencies to use the additional funding for the delivery of all their child and family services, it is noted that the expenditure information received is in relation to maintenance costs and not specifically the EPFA prevention expenditures. Consequently, there is no specific oversight of the EPFA expenditures and the EPFA funding investment cannot be tracked and fully accounted for (i.e. the reconciliation between actual expenditures and the activities detailed with Agency business plans).

5.3.1 Performance Measurement and Reporting

Performance measurement is necessary in order to aid in the setting of goals and objectives, the planning of activities to accomplish these goals and to facilitate the monitoring and evaluation of the progress made towards the achievement of the established goals and objectives.

Effective results reporting allows for a clear demonstration of the achievement of objectives and/or support for the progress being made to achieve those objectives. This is necessary in order to demonstrate that the Program is effective, and there is an adequate and acceptable return on the investment, and to ensure accountability. A rigorous results reporting process also facilitates and challenges decision making, allowing the Program to adjust its course if needed and allowing the Director General to demonstrate the impact and success of the EPFA implementation.

As stated previously at (5.2.1), all Agencies are required to provide a business plan in order to receive funding for the enhanced prevention focused approach. The business plans all state the expected objectives, goals and activities for the EPFA that are aligned with Program objectives. It was noted, however, that the business plans are inconsistent in the documentation of their performance measurement targets. While some Agency business plans do state specific performance measures that are supported by specific targets, the majority document their performance measures but state that their performance targets are "equal or greater than baseline" although the baseline targets have not been identified. Consequently, there are weaknesses with respect to the ability to fully demonstrate results and measure the success (or failure) of the EPFA.

The accountability frameworks for the implementation of the EPFA indicate that each Agency is required to provide annual results-based reports on the progress being made against the objectives, goals and activities identified within their business plans. For practical reasons, a general practice is that the Regions that have Agencies that are transitioning onto the new enhanced prevention approach do not expect annual reports in the first two years of implementation as there is a focus on business planning and in implementing the changes in service delivery resulting from the new approach. Audit testing identified inconsistencies in the extent of Agency annual reporting. While it is noted that some jurisdictions remain in transition to the new approach and have therefore not yet provided annual reports, a number of those that are well established with respect to EPFA implementation are producing annual reports that do not reconcile to business plans and do not clearly state the progress being made against objectives.

EPFA-specific performance measurement is currently not undertaken by the Program at HQ as there are currently difficulties in capturing relevant data (e.g. identifying common data sets and addressing data privacy concerns) and producing meaningful reports. A new Information Management system is being developed for which a pilot project is planned for 2014/15. This project remains in its very early stages as the Program continues to define system requirements ahead of the development stage. The progress of the implementation of the EPFA is monitored by the Program and the status of implementation is reported to the Assistant Deputy Minister within the Education and Social Development Programs and Partnerships (ESDPP) Sector and to the Associate Deputy Minister in quarterly reports.

5.4.1 Staffing to Support EPFA Implementation

To ensure the implementation and ongoing administration and management of the EPFA is successful, it is important that human resource planning be aligned with strategic and business planning and an optimal level of resources distributed between HQ and Regions. Without a good understanding of the human and financial resources required to administer and manage the implementation of the EPFA, it is difficult for management to properly determine human resource needs in HQ and in the Regions and ensure that adequate support is provided to the Regional teams.

The EPFA does not include new human resource funds to administer and manage the program. All of the Regions that were included in the scope of this audit, as well as program management at HQ, expressed significant concern that the allocation of resources needs to be assessed to ensure the effective and efficient administration of the EPFA, particularly as the Regions transition further into the new enhanced prevention focused approach. At the time of the audit, the Regions had not yet developed EPFA-specific Human Resource plans and had therefore not identified their future EPFA staffing needs. The re-alignment of resources undertaken within the context of current reorganization efforts being made with respect to the Government's Deficit Reduction Action Plan (DRAP) represent an opportunity to collaborate with other relevant Sectors and Regions to assess and determine optimal and/or practical distribution of staffing levels between HQ and the Regions under the current economic environment.

The risk is high that a shortage of staffing at the Regional Offices will have an impact on the capacity of the Regions to effectively and efficiently undertake all necessary administration duties (i.e. development of business plans, analysis of Agency annual reports against planned objectives and activities, analysis of budgets and preparation of forecasts, provision of advice and guidance, oversight responsibilities, etc.) and to efficiently manage the EPFA.

The implementation of the new enhanced focused approach is a long-term commitment by the Program and it is essential that the future human resource needs for the administration and management of the EPFA are understood and are reflected in Sector and Region staffing plans.