Archived — Audit of the Infrastructure Program—Canada Strategic Infrastructure Fund (CSIF)

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Final Audit Report  
Industry Canada Audit and Evaluation Branch

August 31, 2007

Recommended for Approval to the Deputy Minister By the DAC on December 5, 2007 

Approved by the Deputy Minister on December 12, 2007

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Aussi offert en français sous le titre Vérification du Programme d'infrastructure—Fonds canadien sur l'infrastructure stratégique (FCIS)

Table of Contents

1.0 Executive Summary

1.1. Background

The Canada Strategic Infrastructure Fund ("CSIF") is a national infrastructure program emphasizing public-private partnerships and focusing on large-scale projects of major federal and regional significance. On behalf of Infrastructure Canada, Industry Canada's CSIF Program ("the Program") is responsible for the delivery of CSIF projects within Ontario. As a federal delivery partner, Industry Canada is responsible for administering the Program within Ontario in accordance with the terms of a Memorandum of Understanding with Infrastructure Canada. Industry Canada's responsibilities relate primarily to the monitoring of recipient compliance with terms and conditions of contribution agreements and reviewing and approving claims for payment.

A total of $220 million in funding for Ontario projects under the CSIF Program has been approved or announced as of March 1, 2007. The CSIF Program is administered jointly by Infrastructure Canada and by Industry Canada through the Sector Strategies and Infrastructure Programs (SSIP) Branch, Regional Operations Sector.

The Audit and Evaluation Branch's (AEB) 2005-2008 Multi Year Risk-Based Audit Plan, approved by the Departmental Audit and Evaluation Committee (DAEC) includes an audit of the Infrastructure Program.

1.2. Audit Objective

The objective of the audit was to provide an independent and objective assessment of the design and operating effectiveness of the Program's management control framework (MCF) and the extent to which the transfer payments under the Program are managed in accordance with the Policy on Transfer Payments.

1.3. Audit Scope

The scope of the audit covered the Program's operations from its inception in 2002 through to July 2007 and included all Ontario CSIF projects administered by Industry Canada's Regional Operations Sector. This does not include projects in Ontario relating to First Nations communities, transportation or broadband. These projects fall under the responsibility of Indian and Northern Affairs Canada, Transport Canada and Industry Canada's Broadband Program.

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1.4 Key Findings

The audit noted management controls and operational practices in place within the Program to help ensure sound governance, internal controls, and risk management.

The management of the program is consistent with the expectations of the Treasury Board Secretariat Policy on Transfer Payments. A summary of the key audit findings is provided below.

Internal Controls

Contribution agreements, the Risk-Based Audit Framework (RBAF), the Results-Based Management and Accountability Framework (RMAF), and the Draft Agreement Steering Committee Handbook developed by Infrastructure Canada define the expected roles and responsibilities of Industry Canada at a project level. Industry Canada actively monitors the status of projects through the receipt and review of regular project progress reports, annual audits, and the conduct of site visits. A key strength of the Program is the implementation of Agreement Steering Committees for each project. These Committees consist of Infrastructure Canada and Industry Canada (federal) representatives and recipient representatives and meet on a bi-monthly basis to discuss and monitor project status and identify action items required. This practice enables both Industry Canada and Infrastructure Canada to keep apprised of the issues affecting each project.

Two issues were identified within this category: 1) the Manager of the CSIF Program is the only dedicated resource for the Program; and 2) there are no formally documented internal operating procedures for the Program. These factors impact succession planning and continuity for long term program management and delivery. Management is currently working to address succession planning under the Program through a job-shadowing arrangement.

Risk Management

Infrastructure Canada conducted an initial program risk assessment through the development of the Program's RBAF. Changes in identified risks at the project level are monitored through the Agreement Steering Committee meetings and remedial action is taken as necessary. At a global level, Annual Business Plans are prepared by Industry Canada that include a section describing new and significant challenges or risks facing the Program that may impact the achievement of Program objectives.

Governance

The Program operates in compliance with the Memorandum of Understanding between Industry Canada and Infrastructure Canada which defines the general roles and responsibilities of Industry Canada in implementing CSIF projects in Ontario. Individual project performance results are monitored by Industry Canada.

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1.5. Recommendations

To support the future delivery of the CSIF Program, it is recommended that:

  • The Director General, SSIP, in consultation with the Manager of the CSIF Program should ensure that an appropriate succession plan is developed, approved and implemented for the CSIF Program; and
  • The Director General, SSIP should ensure that the Manager of the CSIF Program develops appropriate operating policies and procedures to be followed for Industry Canada's delivery of the CSIF Program.

1.6. Audit Conclusion

Overall, we found that the CSIF Program's management control framework and related practices and internal controls are in place. They are operating as intended and are in compliance with Treasury Board's Policy on Transfer Payments. The audit noted two issues related to the need to develop a formal succession plan and to formally document internal policies and procedures. This is reported in detail in Section 3 of this report.

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2.0 Statement of Assurance

We have completed the internal audit of the CSIF Program. The objectives of this internal audit were to provide an independent and objective assessment of: the design and operating effectiveness of the management control framework (MCF) in place within the CSIF Program; and, the extent to which the transfer payments under the CSIF Program are managed in accordance with the Policy on Transfer Payments. The design and operating effectiveness of management controls within the CSIF program are the responsibility of CSIF Program management.

The audit examined the management controls in place within the CSIF Program, including management and operational practices, integrated risk management practices, and information management and reporting for decision making in support of the achievement of overall objectives of the program. The audit also examined the program's compliance with the Policy on Transfer Payments including the processes in place to track and monitor recipient compliance with the terms and conditions of their CAs and the practices in place to ensure funds are used for intended purposes.

The scope of the audit included the entire Program operations for the delivery of Ontario CSIF projects from the Program's inception in 2002 through July 2007. CSIF projects related to transportation, First Nations communities, and broadband were excluded from the audit as these projects do not fall within the responsibility of the Department's Ontario Infrastructure Programs portfolio.

Our internal audit conclusions were based on the assessment of findings against pre-established audit criteria and agreed to by management and reflect the audit work conducted between March and July of 2007.

In my professional judgement as Chief Audit Executive, sufficient and appropriate audit procedures have been conducted and evidence gathered to support the accuracy of the conclusions reached and contained in this report. The conclusions are based on a comparison of the conditions, as they existed at the time, against pre-established audit criteria that were agreed with management. The conclusions are applicable only to the Program examined.

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Chief Audit Executive

 
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3.0 Background

3.1 Program

CSIF began in 2002 through the Canadian Strategic Infrastructure Fund Act. Designed as a national infrastructure program, CSIF emphasizes public-private partnerships and focuses on supporting large-scale projects of major federal and regional significance in areas vital to sustaining economic growth and enhancing the quality of life of Canadians. Overall responsibility for the CSIF program lies with Infrastructure Canada. Infrastructure Canada has been allocated a total of $4.75 billion nationally for the implementation of funding through the 2001, 2003 and 2006 federal budgets. Infrastructure Canada is ultimately accountable to Parliament for infrastructure program funding and performance results through the Minister of Transport, Infrastructure and Communities.

On behalf of Infrastructure Canada, Industry Canada's CSIF Program is responsible for the delivery of all CSIF projects within Ontario, excluding projects related to First Nations communities, transportation or broadband. A Memorandum of Understanding between Industry Canada and Infrastructure Canada defines Industry Canada's responsibilities for administering the CSIF program within Ontario.

Of the $4.75 billion available for national CSIF funding, approximately $1.4 billion is notionally available for Ontario projects. As of March 1, 2007, projects totalling approximately $220 million have been approved or announced under the responsibility of IC's Ontario Infrastructure Programs.

Through its implementation, the CSIF Program emphasizes partnerships with any combination of municipal, provincial, and territorial governments, as well as the private sector. Partnerships are governed by specifically tailored arrangements through which costs are generally shared between Provincial and Federal governments through independent negotiations and contribution agreements.

All applications for funding under the CSIF Program are reviewed and approved by Infrastructure Canada. Infrastructure Canada has responsibility for project selection, business case analysis, initial funding announcements, environmental assessments, preparation of Treasury Board submissions and the negotiation of terms and conditions of contribution agreements with recipients.

Industry Canada's responsibilities include the monitoring of recipient compliance with the terms and conditions of their agreement and reviewing and approving payments for claims submitted.

The CSIF Program is administered by Industry Canada's Sector Strategies and Infrastructure Programs (SSIP) Branch, Regional Operations Sector. Program delivery is largely conducted from the Ontario Regional Office in Toronto, with overall direction and support for program management, policy, and communications being provided through the Department's SSIP Branch in the National Capital Region.

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3.2 Audit Objectives

The objectives of the audit were to provide assurance that:

  1. a management control framework ("MCF") and related management, operational, and risk management practices were in place and operating as intended; and
  2. the transfer payments under the Program were managed in accordance with the Policy on Transfer Payments.

In support of the requirements under Treasury Board's Policy on Internal Audit, the audit criteria were linked to each audit objective and were categorized by internal controls, governance and risk management (please see Appendix A for the specific criteria).

3.3 Audit Scope

The scope of the audit covered the CSIF Program's operations from its inception in 2002 to July, 2007. The scope included all Ontario CSIF Projects delivered out of the Regional Operations Sector. The audit excluded any projects relating to First Nations communities, transportation, or broadband, as these projects fall under the responsibility of Indian and Northern Affairs Canada, Transport Canada and Industry Canada's Broadband Program.

3.4 Audit Methodology

The audit was conducted in accordance with Treasury Board Secretariat's Guide to the Planning, Conducting, and Reporting on Internal Audit Assurance Engagements in the Federal Government of Canada.

The approach to the audit was detailed in the Audit of the Infrastructure Program Preliminary Survey Report dated March 29, 2007 and consisted of the following:

  • Relevant documentation was examined to obtain an understanding of the Program's current risks, risk management processes, governance structures, management control frameworks, information used for decision making, and internal controls;
  • Eight projects are currently approved under CSIF, with individual project values ranging from $20 million to $35 million. A sample of two projects was randomly selected and examined for compliance with Program policies and procedures. These two projects represent 24.5 percent of total federal funding committed to date under the CSIF program;
  • Eight interviews were conducted with representatives from the CSIF Program, the Regional Operations Sector, Infrastructure Canada, and selected funding recipients; and
  • The information gathered through the above procedures was analyzed against each of the audit criteria listed in Appendix A.
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4.0 Detailed Findings and Recommendations

In accordance with the Audit of the Infrastructure Program Preliminary Survey Report dated March 29, 2007, management practices and procedures within the Program were examined against each of criteria listed in Appendix A. We found that the CSIF Program's management control framework and related practices and internal controls are in place. They are operating as intended and are in compliance with Treasury Board's Policy on Transfer Payments.

Two findings and areas for improvement were identified, relating to the capacity of existing human resources and documented policies and procedures. These findings are presented in Section 4.3 below.

4.1 Effectiveness of the management control framework

A number of strong management practices were identified through the audit, providing evidence that the Program's management control framework is in place and operating effectively. Of particular note is the active participation of both Industry Canada and Infrastructure Canada representatives on Agreement Steering Committees (ASCs). An ASC is required for each project as a key means of monitoring and tracking project performance. This practice enables both Industry Canada and Infrastructure Canada to keep apprised of the issues affecting each project. The ASCs facilitate open and timely communication among key project stakeholders and foster a supportive relationship with recipients.

Observations under the categories of internal control, risk management, and governance are provided below.

Internal Control

The Manager of the CSIF Program is the only Departmental representative dedicated to the delivery of the Ontario CSIF Program. The Manager does not have any directly reporting or supporting staff. However, the Manager does utilize staff from the Canada Ontario Infrastructure Program (COIP) and the Canada Ontario Municipal Rural Infrastructure Fund (COMRIF) program on an as needed basis. COIP and COMRIF personnel provide assistance in entering project data into the Shared Information Management System for Infrastructure (SIMSI) and have provided claims verification assistance during periods of high volume. The existing Manager of the CSIF Progam has a long history and extensive experience with both the Department and the Infrastructure Programs. Given the low number of staff dedicated to the Program and this individual's extensive experience with infrastructure programming, neither a succession plan nor a formal training plan have been developed for the Program.

Management practices and procedures for the Program are defined at a high level in the October 2005 Draft Agreement Steering Committee (ASC) Handbook. This Handbook was developed by Infrastructure Canada and outlines the expected actions to be taken by federal delivery partners in a number of areas. The Handbook includes guidelines on expected involvement of Departmental representatives as Co-Chairs of the ASC; responsibility for the ASC to determine the administrative arrangements for claims submissions and payments; financial and management oversight expectations; risk management practices; dispute resolution mechanisms; contract amendment procedures; communications protocols; and, suggested templates for progress reports, claims, and final project reports. While the ASC Handbook provides general guidelines to be followed by management, no specific CSIF policies or procedures within Industry Canada have been documented or defined.

Risk Management

Infrastructure Canada has developed an RBAF and RMAF for the CSIF Program on a national basis. These frameworks identify sixteen risk areas for the Program as a whole.

Both Infrastructure Canada and Industry Canada representatives are kept up to date on risks affecting the program through their attendance at regular ASC meetings. While Infrastructure Canada is responsible for the conduct of an initial risk assessment at the project level, the ASC have responsibility for monitoring changes in project risks through the life of the project. ASC meetings are typically held on a bi-monthly basis and allow for a thorough discussion of project specific risks, as well as result in specific action plans to mitigate risks identified. The ASC Handbook requires the ASC to conduct a number of monitoring activities, including site visits and reviewing annual audits, project progress reports, and detailed claims submissions. These sources of information are expected to be used to identify risks and risk mitigation strategies on a timely basis. Based on our examination of a sample of Program files, Industry Canada has complied with these requirements. Agreement Steering Committees are in place for each funded project and are operating as intended.

Business Plans for the Ontario Infrastructure Programs are developed annually by the Director of the Canada Ontario Infrastructure Program and Director General SSIP, with the input from all respective managers. Annual Business Plans include a section that describes new and significant challenges or risks facing the Program, including external and political factors as well as internal constraints that may impact the achievement of Program objectives.

Governance

Annual Business Plans for the Ontario Infrastructure Programs define key objectives and priorities for the Program as well as action plans and deliverables required to meet the Program's stated objectives. Annual Business Plans also include a documented human resource plan and financial plan.

The Program operates in compliance with the Memorandum of Understanding between Industry Canada and Infrastructure Canada. This document defines the general roles and responsibilities of Industry Canada in implementing CSIF projects in Ontario. It defines expectations under the categories of reporting and due diligence, environmental issues, information management, communications, and resources and financial management.

The Program also operates in compliance with the Program's RBAF and RMAF developed by Infrastructure Canada. The RMAF describes performance measurement and evaluation strategies. As described previously, it is Infrastructure Canada's responsibility to report to Parliament on the overall performance results of the CSIF Program. Individual project performance results are monitored by Industry Canada and the project's ASC.

Financial and non-financial program and project performance information is tracked within SIMSI. SIMSI was resourced and developed by Infrastructure Canada for its national infrastructure programs. The Memorandum of Understanding with Infrastructure Canada governs the management and use of SIMSI.

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4.2 Compliance with the Policy on Transfer Payments

The audit found that the Program's management practices are in compliance with the Policy on Transfer Payments. Key practices in place to help ensure compliance with the Policy include:

  • ASCs must be implemented for every project, with Infrastructure Canada, and Industry Canada (federal) and recipient representatives, through which project progress and issues are tracked and monitored on a timely basis;
  • claims are supported by detailed breakdown of costs by category, supporting invoices, and certifications by the client attesting to the work performed in the period;
  • clearly defined delegations of financial authority are documented and adhered to; and,
  • contribution agreements, drafted by Infrastructure Canada, clearly define the project's objectives, roles and responsibilities, project monitoring and reporting requirements, and the conditions that are required to be met prior to payment.

Observations under the categories of internal control, risk management, and governance are provided below.

Internal Controls

Our examination of a sample of project files indicated that strong financial controls are in place and operating as intended. In general, all required documentation in support of claims was on file. All approvals were obtained in accordance with delegated signing authorities for the Program. Regular communication was received as required on the project status including annual audits of the projects, project progress reports, site visit reports, and ASC meeting minutes.

As stated previously, each ASC includes a federal and recipient co-chair and two other representatives (one from the federal government and the other from the recipient organization). In all projects examined, timely meetings were held with the ASC to monitor the project and members of the committee included two federal members and two representatives from the recipient.

Where issues with claims were identified, there was evidence on file of communication between the Manager of the CSIF Program and the recipient to address and resolve the issue in a timely manner.

Infrastructure Canada is responsible for defining specific project evaluation and monitoring requirements in the individual project contribution agreements. Our interviews with representatives from the CSIF Program, Infrastructure Canada, and selected recipients indicate a consistent agreement that the contribution agreements clearly define the roles and responsibilities and performance expectations of both Industry Canada and the recipients.

Risk Management

The Program's RBAF indicates that Infrastructure Canada is responsible for defining specific monitoring procedures to be performed within each contribution agreement. Based on our file examination process, evidence exists that Industry Canada followed the monitoring activities specified in the contribution agreements.

The Program's RBAF further requires recipient audits to be conducted for all CSIF projects. Recipient audits were conducted as planned for all projects examined in our sample of two projects. In all cases where overpayments of claims were identified through the recipient audits examined in our sample, Industry Canada recovered the amount overpaid on the next claim submitted by the recipient.

Due to the complexity of the projects funded under the CSIF program, recipient audits are a key control in confirming recipient compliance with the terms and conditions of their agreements and in ensuring only eligible costs are reimbursed through claims.

Governance

As described previously, the Program is subject to the management controls as defined within the Draft ASC Handbook, the RBAF and RMAF defined by Infrastructure Canada, and the Memorandum of Understanding between Industry Canada and Infrastructure Canada. As required under these documents, the Program has complied with all policies and procedures required to ensure compliance with the Policy on Transfer Payments through all phases of the contribution life cycle. This includes the active monitoring of project progress through the ASC, recipient audits, and reviews of project progress reports.

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4.3 Findings and Recommendations

Finding #1:

There are limited human resources dedicated to the CSIF program impacting continuity and succession planning.

The Manager of the CSIF program is eligible for retirement in the near future. Because this individual is the only resource dedicated to the Program, there is limited capacity for succession planning to allow for corporate memory retention and ensuring the required skills, knowledge and capacity are in place to deliver and manage the Program into the future.

Program management has recognized this risk in its 2007/08 Annual Business Plan. In response, in the spring of 2007 the Program implemented a job shadowing arrangement with the Communications Manager of the COIP Program, who may be assigned to take over the responsibilities of the Manager of the CSIF Program. Under this arrangement, the Communications Manager is intended to attend ASC meetings, and assess claims and recipient progress reporting as an observer to increase her familiarity and understanding of the Program. This Manager has previous experience with the CSIF Program through her participation in Communications Sub-Committees of ASCs.

There is a concern over the timeliness of knowledge transfer under this arrangement, given the Communications Manager's formal daily responsibilities in her current role. As a result, there is a need to have a formally documented succession plan, including contingency plans, to address the satisfactory transition of both management and administrative staff within the Program. This may limit disruption in the ongoing administration and management of the Program during times of unanticipated turnover.

Drafting and adopting a more formal succession plan for the Program will help Industry Canada retain corporate memory and maintain service levels during management turnover. It may also allow for a more proactive monitoring of human resource capacity and related issues. A formally documented plan should address both the management position as well as requirements for support staff under the Program.

It is noted that controls over segregation of duties for claims verification, approval and project monitoring activities exist and are operating effectively. In all cases, representatives of the ASC are responsible for project monitoring and verifying the eligibility of claims. In addition, claims are required to be approved by the Director, SSIP, and are forwarded to Infrastructure Canada for additional approval. As such, this finding concerns only the Program's resource capacity to allow for continuity in the future. No issues regarding segregation of duties within the Program were identified.

Recommendation #1

  • The Director General, SSIP, in consultation with the Manager of the CSIF Program should ensure that an appropriate succession plan is developed, approved and implemented for the CSIF Program.

Finding #2:

There are no formally documented internal operating policies and procedures for the CSIF Program.

Industry Canada currently relies on the guidance and manuals drafted by Infrastructure Canada for the day to day operations of the Program. While these guidelines provide a high level summary of roles, responsibilities, and expectations, they are not reflective of any internal policies or procedures that would be specific to Industry Canada's management of this program.

The formal documentation of internal policies and procedures would support the Program's operations in times of transition by helping new individuals gain familiarity with the operations and expected processes and procedures under the Program. Once internal guidance has been developed, it should be formally communicated to all relevant parties to ensure a common understanding of Industry Canada's expectations and delivery of services.

Recommendation #2:

  • The Director General, SSIP should ensure that the Manager of the CSIF Program develops appropriate operating policies and procedures to be followed for Industry Canada's delivery of the CSIF Program.
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Appendix A—Audit Criteria

The following table outlines the audit criteria that were used to assess Industry Canada's management of the CSIF Program for each audit objective.

Audit Objective #1: A Program management control framework and related management, operational, and risk management practices were in place and operating as intended.

Criteria

a) Internal Control

Staff and management who are responsible for program delivery have the required skills, knowledge and capacity

Business planning is performed annually to identify financial and human resource requirements to meet program objectives over the planning cycle

Proper financial controls have been designed and implemented to help ensure that payments are subject to control, account verification and payment requirements under the terms and conditions of the contribution agreements, and Sections 32, 33 and 34 of the Financial Administration Act (FAA)

b) Risk Management

A mechanism exists to systematically identify, assess, monitor and report on risks facing the program.

A risk-based approach to the monitoring of contribution agreements exists and is followed.

c) Governance

Results expected from the program are clear, measurable, and directly related to program objectives

A mechanism exists to identify and share lessons learned, knowledge and expertise between Industry Canada and other Infrastructure Program partners.

Third party delivery agreements/memorandums of understanding clearly define terms, service levels, and performance targets

Expected results are monitored, communicated and reported on a regular and timely basis and support effective and timely management decision-making at both the project and program levels.

Roles and responsibilities for managing and delivering the program are clearly defined between partners, executive committees, and other stakeholders

Communication on program and progress status, issues and results occurs on a timely basis between relevant stakeholders, such as through various Committee structures.

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Audit Objective #2: The transfer payments under the Program were managed in accordance with the Policy on Transfer Payments

Criteria

a) Internal Control

Officers have complied with financial controls including:

  • Section 34—there is proof that performance conditions of the agreement were met before each payment was made
  • Section 33—proof that finance officer signing was assured that Section 34 was met prior to payment authorization

Claims are reviewed for reasonableness and accuracy and are examined for compliance with terms of contribution agreements.

Advance payments are properly authorized and are in accordance with TBS guidelines.

Progress reports prepared by the recipient, either on a monthly basis or in conjunction with the submission of claims, are reviewed to ensure the project is progressing consistently with contribution agreement statement of work.

A mechanism exists to verify that the terms of contribution agreements have been met. Consequences for non-compliance have been defined and are adhered to in practice.

b) Risk Management

Monitoring and audit requirements of the program's Risk-Based Audit Framework are met and issues identified are resolved on a timely basis.

c) Governance

There is a process in place to determine whether the project was successful in contributing to expected program results.

Program guidelines are fully consistent with the Policy on Transfer Payments.

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Appendix B—Management Response and Action Plan

The following table summarizes recommendations addressing findings from our audit of the CSIF Program.

Summary recommendations of the CSIF Program
Recommendation Management Response and Proposed Action Responsible Official Action Completion Date
1) The Director General, SSIP in consultation with the Manager of the CSIF should ensure that an appropriate succession plan is developed, approved and implemented for the CSIF Program. Management concurs. A succession plan will be developed to address the transition of both management and support staff for successful ongoing delivery of the CSIF Program in Ontario. Director General, SIPP December 31, 2007
2) The Director General, SSIP should ensure that the Manager of the CSIF Program develops appropriate operating policies and procedures to be followed for Industry Canada's delivery of the CSIF Program. Management concurs. Building on the existing Infrastructure Canada guidelines and ASC Handbook, as well as the terms and conditions of the Industry Canada's MOU for program delivery, a comprehensive procedures manual will be developed which will serve as a valuable management and reference tool for employees, particularly during periods of transition. Director General, SIPP March 31, 2008
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