Archived – Follow-up Audit of Employment Systems Review

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Project Number 6B089
Final Advisory Report
March 18, 2008

Table of Contents


1.0 EXECUTIVE SUMMARY

2.0 Background

3.0 Objectives and Scope

4.0 Statement of Assurance

5.0 Methodology

6.0 observations

6.1 EE MAP Was Difficult to Manage

6.2 Slow Progress is Observed

6.3 Monitoring is Weak

6.4 There is a Lack of Accountability and Engagement

7.0 Risk assessment

7.1 EE Representation

7.2 Self-Identification

7.3 Meeting the Expectations of CHRC

7.4 DFO’s Reputation

7.5 Fulfilling DFO’s Mission in the Long Term

8.0 conclusion

9.0 recommendations

10.0 Management action Plan


1.0 EXECUTIVE SUMMARY

Pursuant to a stipulation in the December 2003 EE Interim Audit Report of the Canadian Human Rights Commission (CHRC), DFO Audit and Evaluation led an Employment Systems Review (ESR). In 2004-05, Human Resources and Corporate Services (HRCS) prepared a related Management Action Plan (MAP) and a Supplemental Information Report to address additional issues which were not previously included in the ESR or EE MAP. The MAP was developed to address barriers and causal factors.

In keeping with Fisheries and Oceans Canada Internal Audit Policy, the Audit and Evaluation Directorate (AED) carried out a Follow-up Audit to determine the extent to which the activities to remove barriers and causal factors were implemented. A risk assessment was also conducted to identify where the Department should concentrate its efforts.

The Follow-up Audit found that HRCS made notable efforts in a few areas; however, the Employment Equity (EE) MAP is difficult to manage; progress is slow to achieve representation in certain areas (i.e., visible minorities and women); monitoring is weak; and there is a lack of accountability and engagement on the part of senior management.

The above implies the following significant risks for the Department: there is a high probability that representation for visible minorities and women may not be reached; CHRC (and other parties) expectations may not be met; and DFO’s reputation could be damaged.

The following recommendations are made to address these concerns:

1. HRCS develops a performance measurement strategy to include a logic model with a view to provide structure and direction to the EE Plan.

2. Integrate EE recruitment targets into the Departmental Management Committee (DMC) Accountability Accords and compare targets with results achieved.

3. Assess the need for additional resources for HRCS National to develop and disseminate tools and to:

a) Monitor recruitment targets;

b) Monitor implementation of EE Plan; and

c) Report on recruitment targets results (quarterly) and on the implementation of EE Plan achievements (bi-annually).

4. AED initiates another audit in 2010-11 for the Departmental Audit Committee (DAC).

2.0 Background

In 2004, HRCS prepared a MAP in response to the 50 recommendations made in the Audit Report on ESR, dated December 3, 2004. In July 2005, CHRC requested that DFO produce additional work to complete the departmental ESR. As such, a Report entitled "Supplemental Information Report" containing an additional 62 recommendations was produced by HRCS in October 2005. The MAP was later amended to take into account the new requirements.

The departmental efforts have been recognized in a letter to the Deputy Minister (DM) sent by the CHRC on June 7, 2006. The letter indicated that Fisheries and Oceans Canada (DFO) had been found compliant with all twelve of the statutory requirements of the Employment Equity Act. This recognition was conditional to making reasonable progress towards full representation of designated groups, and with the implementation of the departmental EE MAP.

3.0 Objectives and Scope

In keeping with Fisheries and Oceans Canada Internal Audit Policy, AED carried out a Follow-up Audit to determine the extent to which the activities to remove barriers and causal factors were implemented. A risk assessment was also conducted to identify where the Department should concentrate its efforts.

The scope of the Follow-up Audit covered the period December 15, 2004 to February 15, 2008 and consisted in analyzing supporting information provided to AED by HRCS staff responsible for the coordination of the EE MAP. It also included discussions with CHRC staff and research of various web sites (e.g., CHRC, Canada Public Service Agency (CPSA), and Standing Senate Committee on Human Rights).

4.0 Statement of Assurance

Generally speaking, the audit procedures have been applied to support the conclusions contained in this report. The conclusions are based on the comparison of the situation against the audit objectives as they existed at the time of the audit.

5.0 Methodology

To determine which activities were completed, partially completed and not actioned, AED reviewed documentation made available by HRCS (Human Resources Strategies and Programs/Recruitment and Staffing) and several discussions with HRCS staff were held. To prepare for these discussions, a progress report prepared by HRCS for the January 23, 2008 DMC meeting was reviewed. Advancement identified in this report was compared with a progress report resulting from a joint ADM Science and HRCS Call Letter of June 5, 2007 to DMC members on the implementation of the EE Plan, the three status reports presented to the Department Audit Committee (DAC) and the approved initial MAP included in the ESR Report dated December 3, 2004.

In addition to barriers and causal factors, activities contained in the MAP were also reviewed with HRCS staff to identify those of greatest importance to achieving results, i.e., close the representation gaps related to EE designated groups.

6.0 observations

The Department has made notable efforts in the following areas:

  • Communicating and encouraging the use of the Accommodation Policy and Guide.
  • Analyzing data on the workforce and providing managers with numerical EE recruitment goals, at the regional and national level.
  • Maintaining a database of self-identified employees and promoting self-identification to all new employees (with the completion of a form to be returned to their Regional Coordinator).

The following describes AED’s detailed findings and conclusions:

6.1 EE MAP Was Difficult to Manage

AED found the EE MAP difficult to manage for the following reasons:

  • There were too many activities (156);
  • An imbalance was created with the mix of high and low level type of activities;
  • There was a lack of structure, sequence and prioritization of activities;
  • One-time activities were mixed with recurring activities;
  • Many of the activities were unclear and modified regularly rendering completion almost impossible;
  • Duplication and overlap of activities were found; and
  • Status report updates indicated regular modifications to Offices of Primary Interest (OPIs) and sub-delegation of accountability.

The consultation process we engaged prior to the approval of the 2008-2011 Plan has provided HRCS with an opportunity to clarify activities, identify realistic timelines and determine/confirm stakeholders. The 2008-2011 Plan also differentiates outstanding activities from completed and on-going activities. It is our understanding that all outstanding activities should be completed by March 31, 2011.

6.2 Slow Progress is Observed

In most cases, responses to the June 5, 2007 Call Letter to DMC members generated insufficient supporting information to ensure that the activities were implemented or partially implemented. As such, HRCS staff could not provide supporting evidence to demonstrate progress.

Following the review of DAC status reports, progress reports to DMC and discussions with HRCS staff, AED concluded that of the 156 action items included in the 2004-2007 EE Plan, 42 were completed or on-going; 58 were partially completed; and finally 56 were not actioned or showed very limited progress.

Significant and recurring slippage was also observed during the review and analysis of the various status reports presented to the DAC. This means that little or no progress was achieved on many activities and that timelines were postponed from one status report to the next. This was found for 26 of the 156 activities.

Several of the activities were reported as completed by HRCS. For some of these activities, HRCS had received insufficient information from stakeholders or had a different understanding of what constituted ‘complete’ for the action. For these reasons they could not substantiate progress/completion therefore, we suggested that the 2008-2011 EE Plan be updated to reflect the AED assessment; HRCS agreed with the change for most items and this was reflected in the 2008-2011 Plan presented to DMC in late February 2008.

It should be noted that incomplete and partially completed activities of the 2004-2007 EE MAP were carried over in the 2008-2011 EE MAP.

The situation could be somewhat different if HRCS would have sufficient resources to perform monitoring of the implementation of the EE Plan and of recruiting targets, and to implement activities under its responsibility (e.g., tools).

6.3 Monitoring is Weak

Currently, reporting activities are performed by HRCS semi-annually at DMC; however, we believe that reporting should be done quarterly to inform senior management on a timely basis and to allow them to take action, as necessary. Also when monitoring is performed on the implementation of EE Plan, insufficient/irrelevant input is obtained from stakeholders. In fact, only 4 out of 11 primary stakeholders properly responded to the June 2007 Call Letter. This may reflect a lack of accountability and involvement of stakeholders but could also be a lack of clarity on activities and OPIs.

Rigorous monitoring is required by HRCS staff on achieving recruitment target results and on implementing the EE Plan.

6.4 There is a Lack of Accountability and Engagement

Many essential activities of the EE MAP are reported as completed; however, results are not meeting expectations. According to our discussions with HRCS staff, recruitment targets and the EE Plan are monitored occasionally and the results are presented to DMC for review and action. However, despite these actions, expected results are not achieved.

AED believes that the most significant reason for not reaching recruitment targets and for the lack of timely implementation of the EE MAP is the lack of accountability and engagement of stakeholders. Senior managers need to be held accountable to ensure that the necessary steps/measures are taken to deliver on EE commitments.

7.0 Risk assessment

7.1 EE Representation

The CPSA Employment Equity Annual Report 2004-05[1] shows that, as at March 31, 2005, DFO has the lowest representation for two designated groups (visible minorities and women) among all Federal Departments and Agencies with more than 1000 employees.

Recent results presented to DMC on January 23, 2008 show encouraging improvements for women but also indicate that special attention is still required to close the gap for visible minorities.

In fact, according to the CPSA Employment Equity Annual Report stated above, the DFO representation for the visible minority group has remained stable at 3.8% since 2002-03 and has recently slightly declined to 3.6%[2]. It should be noted however that DFO Workforce Availability Rate is 5.4% compared to 10.4% for the total Federal Public Service. DFO has an availability rate for visible minorities lower than the Federal Public Service average because of its regionally dispersed offices amongst small communities. Despite a lower availability rate of 5.4%, DFO is nevertheless under-represented by 171 out of a workforce availability of 525 visible minorities (or 32.6%).

When the new data from the 2005 Census becomes available (approximately in 2009), there is a high probability that the gap for some designated groups, particularly the visible minorities, will have increased. This represents the highest risk for the Department.

For women, DFO through its EE MAP has improved its representation from 30.2 % to 32.0%. Despite the workforce availability of 3,392 women, DFO is still under-represented by 268 (or 7.9%). Since the representation gap for women has been significantly reduced, DFO needs to focus the most effort on recruiting members of visible minorities.

7.2 Self-Identification

Self-identification is an important activity as it has a direct impact on results. In fact, if a new employee belonging to a designated group chooses not to self-identify, his/her EE status will not be reflected in DFO EE statistics. Unfortunately, managers cannot by law estimate the percentage of people that have chosen not to self-identify. This is unfortunate, because this information is key to determine the effort that should be devoted to promoting self-identification.

Since self-identification is a matter of choice, it will always be an area of concern in departments. Therefore, special measures should be put in place to promote it.

7.3 Meeting the Expectations of CHRC

According to discussions with CHRC staff, unless DFO has made reasonable progress towards full representation of designated groups, CHRC could choose to initiate a new audit most likely about 3-5 years after their June 7, 2006 letter to DFO.

To evaluate DFO’s progress, CHRC will use data provided annually by the Department to the CPSA. If CHRC chooses to conduct another audit (progress assessment), their primary interest will be the implementation of the departmental EE MAP. In fact, CHRC’s progress assessment phase[3] is designed to ensure that the employer continues to meet the audit requirements assessed in the preliminary assessment phase. Particular attention is paid to the employer’s progress in implementing the EE Plan, leading to improved representation levels.

It should be noted that CHRC has recently developed a new process containing only two phases: preliminary assessment and progress assessment. Also, while CHRC formerly gave 12 months to organizations for the implementation of all undertakings identified during their audit (preliminary assessment), they currently allow 4 months only.[4]

7.4 DFO’s Reputation

DFO’s reputation could be damaged if it does not comply with the Employment Equity Act within a reasonable timeframe, if it does not meet its commitments as indicated in the EE MAP provided to CHRC and its representation for certain groups (visible minorities and women) is consistently below that of other Government Departments or Agencies. As a result, CPSA could elect to impose sanctions or conditions on the exercise of delegated authority by the DM which would further damage DFO’s reputation.

7.5 Fulfilling DFO’s Mission in the Long Term

The Department needs to be perceived as an employer of choice (e.g., among other factors, fairness to designated groups), otherwise it could in the long run experience significant difficulty in attracting and recruiting a sufficient qualified workforce to fulfill its mission.

This long term risk has been recognized by the Canadian Senate. In fact, the introduction of the Standing Committee on Human Right Report of February 2007, entitled "Employment Equity in the Federal Public Service – Not there yet", indicates that employment equity hiring practices in the Federal Public Service are an issue of pressing and serious concern. The Federal Public Service is the largest employer in the country, and as such, aspires to be representative of the country it serves as well as a model for businesses and other sectors.

8.0 conclusion

We have concluded that the best strategy to mitigate the DFO risks is to focus on actions/activities required to obtain specific results rather than completing as many activities as possible in the EE MAP.

DFO needs to concentrate its efforts on reaching representation for visible minorities and women by among other things, expanding outreach activities, especially in large urban centres where the concentration of visible minorities is greater (e.g., Vancouver, Toronto, Montreal, and the National Capital Region). It should also be noted that coupled with effective outreach, more focused collective recruitment processes might be required to get results, particularly if many organizations have only one or two recruitment opportunities.

Our analysis is corroborated by the preliminary findings of the Standing Senate Committee on Human Rights on the need to strengthen leadership and management accountability; and by the Clerk of the Privy Council who has requested in 2007 that deputy ministers increase emphasis on outreach initiatives.

If stakeholders are held accountable, this should also have a positive impact on the implementation of the EE MAP and the EE Program.

Specific recruitment targets should be incorporated into the DMC members’ Accountability Accords; ongoing monitoring and a reporting schedule should be established; and outreach promotion/activities should be expanded.

Overall leadership would be exercised by the DM whereas HRCS would concentrate its efforts on monitoring, analysis and reporting results to the DMC.

In summary, the Department is not meeting some of its EE recruitment targets more specifically, the visible minorities and women, and limited progress has been made in implementing the EE MAP. A performance measurement strategy is required for the EE Plan; senior management accountability, improved monitoring and reporting are also required to achieve representation of specific designated groups, namely visible minorities and women.

9.0 recommendations

The following recommendations are made:

1. HRCS develops a performance measurement strategy to include a logic model with a view to provide structure and direction to the EE Plan. The logic model would identify outputs and outcomes (long term results), determine accountabilities and responsibilities, establish reporting requirements and schedules and determine performance measures. This would eliminate the need for further MAP updates and follow-up audits.

2. Integrate recruitment EE targets into DMC Accountability Accords and compare targets with results achieved.

3. Assess the need for additional resource for HRCS National to develop and disseminate tools and to:

a) Monitor recruitment targets;

b) Monitor the implementation of EE Plan; and

c) Report on recruitment targets results (quarterly) and on EE Plan achievements (bi-annually).

4. AED initiates another audit in 2010-11 for the DAC.

10.0 Management action Plan

Recommendation Management Action Plan First Responsibility Initial Target Date

1. HRCS develops a performance measurement strategy to include a logic model with a view to provide structure and direction to the EE Plan. The logic model would identify outputs and outcomes (long term results), determine accountabilities and responsibilities, establish reporting requirements and schedules and determine performance measures. This would eliminate the need for further MAP updates and follow-up audits.

Develop and implement a Results –based Management and Accountability Framework (RMAF):
  • Draft framework
  • Consult EE Map
  • Development team
  • Submit to DMC HR Sub-committee for discussion
  • DMC for approval
  • Report through Health of HR Framework
ADM, HRCS HRSP July 31, 2008

2. Integrate recruitment EE targets into DMC Accountability Accords and compare targets with results achieved.

-Ensure that Accountability Accord tools link to the new recruitment targets developed in 2007.

-Update existing reporting mechanism in order to report on achievement of recruitment targets and representation objectives for each Region/Sector/CCG.

ADM HRCS HRSP May 30, 2008

3. Assess the need for additional resource for HRCS National to develop and disseminate tools and to:

a) Monitor recruitment targets;

b) Monitor the implementation of EE Plan; and

c) Report on recruitment targets results (quarterly) and on EE Plan achievements (bi-annually).

As part of a comprehensive business case for additional resources seek additional resources to increase frequency in reporting from semi-annual to quarterly. ADM HRCS
HRSP
July 31, 2008

4. AED initiates another audit in 2010-11 for the DAC.

Not applicable.

Audit and Evaluation Directorate FY 2010-11

[1] The CPSA Employment Equity Annual Report 2004-05, “Distribution of the Federal Public Service Employees by Designated Group According to Department and Agency”, Table 5. (Note: DFO’s statistics include the Canadian Coast Guard (CCG))

[2] DFO National Representation and Availability of the Designated Groups, as of September 30, 2007

[3] CHRC – Framework for Compliance Audits under the Employment Equity Act, May 2007, p9.

[4] CHRC – DFO Employment Equity Compliance Review, Interim Report, January 6, 2004, p4.