9 – Audit of the Canada School of Public Service

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9.1 This audit covers the Canada School of Public Service (CSPS)’s appointment activities for the period between April 1, 2011, and September 30, 2012. The objectives of the audit were to determine whether the CSPS had an appropriate framework, practices and systems in place to manage its appointment activities and whether appointments and appointment processes complied with the Public Service Employment Act (PSEA), the Public Service Employment Regulations (PSER), the Public Service Commission (PSC) Appointment Framework and related organizational appointment policies.

9.2 The CSPS was created on April 1, 2004, when the legislative provisions of Part IV of the Public Service Modernization Act came into force. The CSPS has been part of the Treasury Board Portfolio since July 2004. It was created from an amalgamation of three organizations: the Canadian Centre for Management Development; Training and Development Canada; and Language Training Canada. The School’s mission, which is set out in the Canada School of Public Service Act, is to provide a broad range of learning opportunities and establish a culture of learning within the public service.

9.3 The CSPS is a medium-sized organization that had 898 employees as of March 31, 2012. The majority (82%) of employees were located in the National Capital Region.

9.4 From April 1, 2011, to September 30, 2012, the organization carried out 231 appointments. As part of our audit, we conducted interviews, analyzed relevant documentation and reviewed with CSPS officials, during the planning phase of the audit, a sample of appointments in order to understand the way the organization conducted and documented its staffing processes.

9.5 During the same period, due to structural reorganization, the CSPS relied on a senior management committee to approve each indeterminate appointment request. Therefore, the audit team did not include in the conduct of its audit the verification of the staffing strategies to determine whether these described planned organizational staffing priorities and how and when they were achieved.

9.6 The audit effort focused on the staffing framework, including an assessment of the sub-delegation process and policies, the definition of roles and responsibilities, the availability of adequate human resources (HR) support and the use of monitoring.

9.7 In addition to the review of the staffing framework, the PSC would normally select a sample of appointments for review during the examination phase of the audit to assess whether appointments and appointments processes comply with the PSEA, the PSER, the PSC Appointment Framework and related organizational policies. However, given that the audit observations indicated systemic issues with the application of the approved CSPS instrument of sub-delegation document (which defined the staffing authorities and related roles and responsibilities of sub-delegated managers), further review of appointments for compliance was not undertaken.

Observations on the Appointment Framework

The Public Service Employment Act and the Public Service Commission’s delegated authorities

A sub-delegation instrument was in place, but was not adequately applied.

9.8 The PSC has the exclusive authority to make appointments to and within the public service as per the PSEA. The PSC delegates many of its appointment and appointment-related authorities to deputy heads, who in turn may sub-delegate the exercise of these authorities. The PSC expects deputy heads to have a sub-delegation instrument in place that is well managed and communicated across the organization.

9.9 During the period covered by the audit, the President of the CSPS formally accepted the delegation of appointment authorities by the PSC and had full delegated authority through the signing of an Appointment Delegation and Accountability Instrument (ADAI).

9.10 The President of the CSPS approved an instrument to sub-delegate appointment authorities to managers and communicated it to all employees. In order to become sub-delegated, a manager had to occupy a sub-delegated position, as identified by title and level in the sub-delegation instrument; complete mandatory training on staffing; receive a staffing sub-delegation letter signed by the President; and accept the conditions of sub-delegation in writing.

9.11 We found that, during the period covered by the audit, the list of the 23 sub-delegated managers, used by HR advisors to verify whether an individual was sub-delegated, was not accurate. For example, we found that one sub-delegated manager was not included on the list. Furthermore, the CSPS was not able to provide evidence that 15 sub-delegated managers identified on the list had completed the required training. This demonstrates that the control of sub-delegation described above was not systematically applied as required. Refer to Recommendation 1 at the end of this report.

Appointment policies

Mandatory appointment policies and criteria were not always aligned with the CSPS sub-delegation instrument.

9.12 The PSC expects deputy heads to establish mandatory appointment policies for area of selection, corrective action and revocation, as well as criteria for the use of non-advertised appointment processes. The PSC also expects other appointment policies that organizations develop to be compliant with the PSEA, the PSER and the PSC Appointment Framework.

9.13 The CSPS established mandatory appointment policies that met the minimum provisions required by the PSC. We found that the mandatory appointment policies and criteria were not always aligned with the CSPS sub-delegation instrument. Although these policies were communicated and made accessible to all sub-delegated managers, employees and bargaining agents, we found that these stakeholders were not consulted in their development, as required under the conditions of delegation in the ADAI.

9.14 Furthermore, we found that the CSPS President formally approved the sub-delegation instrument but not the mandatory policies, which are PSC requirements and important components of the CSPS staffing framework. Giving this formal approval would have allowed the CSPS President to ensure consistency within the various components of the staffing framework and to identify and rectify any related issues in a timely manner.

9.15 We also found that HR advisors developed additional tools (HR procedures, templates) to support and guide sub-delegated managers in conducting staffing activities. However, these tools were not always aligned with the sub-delegation instrument approved by the President. For instance, we found inconsistencies in the level of authority associated with key staffing decision points, including the qualifications for the work to be performed, the area of selection and the selection of the chair of the assessment boards.

9.16 In addition, the CSPS established organizational criteria for the use of non-advertised appointment processes. However, we found that the template used for the required written rationale omitted the value of representativeness. Refer to Recommendation 1 at the end of this report.

Capacity to deliver

Roles, responsibilities and accountabilities were defined, but were not carried out as approved.

9.17 The PSC expects deputy heads to ensure that those who have been assigned a role in appointment processes have been informed of their responsibilities and have the support to carry out this role.

9.18 The sub-delegated managers had access to HR advisors who passed the Appointment Framework Knowledge Test. However, we found that these sub-delegated managers were not always adequately informed of their responsibilities, and the support received from HR was not always consistent with the terms and conditions established in the approved sub-delegation instrument and required by the PSC as a condition of delegation. This was due to inconsistencies within the various components of the CSPS staffing framework. As a result, some sub-delegated managers carried out key duties within the staffing process that the sub-delegation instrument did not authorize. This included an assessment board being chaired by a sub-delegated manager who did not occupy the appropriate level required by the approved sub-delegated instrument. Refer to Recommendation 1 at the end of this report.

Monitoring

Monitoring was not in place.

9.19 Monitoring is an ongoing process that allows deputy heads to assess staffing management and performance related to appointments and appointment processes. Monitoring makes it possible to identify issues that should be corrected, to manage and minimize risk and to improve staffing performance. The PSC expects deputy heads to undertake the mandatory monitoring outlined in the PSC Appointment Framework and adjust practices accordingly.

9.20 During the period covered by the audit, the CSPS could not demonstrate effective appointment monitoring at the transactional level in order to ensure that appointment and appointment-related decisions adhered to the PSEA, the PSER, the PSC Appointment Framework and related organizational appointment policies. We also found that the CSPS did not have effective control mechanisms and did not conduct all of the mandatory monitoring outlined in PSC policies. Although the CSPS had hired external consultants to review some of the appointments after they were made, this was done on an ad hoc basis.

9.21 We also found that the information available at the CSPS on its appointment system and its individual appointment staffing actions was not always complete and reliable. For example, the length of acting appointments recorded in the CSPS HR database was not always properly calculated, and some appointment process numbers were missing. As a result, the organization did not have sufficient and accurate information available to adequately monitor acting appointments for periods of more than four months. Thus, the organization could not determine whether these appointments should have been subject to merit, or whether they required a rationale to demonstrate how a non-advertised process meets the organizational criteria and the appointment values.

9.22 The absence of organizational monitoring on staffing based on accurate information can hamper the ability of the CSPS to identify issues and take appropriate timely action as needed. Refer to Recommendation 1 at the end of this report.

Observations on compliance

Staffing activities were not always compliant with the instrument of sub-delegation approved by the CSPS President.

9.23 The PSEA establishes that all appointments must be made on the basis of merit. Merit is met when the Commission is satisfied that the person to be appointed meets the essential qualifications for the work to be performed, as established by the deputy head, and, if applicable, any other asset qualifications, operational requirements and organizational needs established by the deputy head.

9.24 The CSPS President sub-delegated the establishment of the qualifications for the work to be performed to sub-delegated managers occupying a position at least at the level of director general or regional director. During the planning of this audit, we reviewed a sample of appointments to understand the CSPS staffing processes. We found that staffing activities were not always compliant with the instrument of sub-delegation approved by the CSPS President. For example, CSPS officials could not demonstrate that the establishment of qualifications was exercised at the required sub-delegated level, and they confirmed that no control was in place to this effect.

9.25 The lack of consistency within the CSPS framework, practices and systems to manage appointment activities meant that CSPS appointments were at risk of non-compliance with the CSPS President’s sub-delegation instrument. This also meant that there was a risk of non-compliance with the PSC Appointment Framework, as lack of compliance with the approved framework does not meet PSC Appointment Framework requirements. As a result, given that audit findings indicated systemic issues with the application of the approved CSPS instrument of sub-delegation, as well as with the terms and conditions of the PSC delegation, further review of appointments for compliance was not needed to conclude the audit. Refer to Recommendation 1 below.

Recommendation

  1. The President of the Canada School of Public Service should confirm and communicate the approved organizational staffing management framework to ensure the implementation of:
  • Effective control of the sub-delegation process;
  • Approved and compliant staffing policies;
  • Sound support by human resources staff;
  • Clear guidance and effective staffing tools; and
  • Effective monitoring for staffing.

Conclusion

9.26 The first objective of the audit was to determine whether the CSPS had an appropriate framework, practices and systems in place to manage its appointment activities. Although the President of the CSPS had approved an instrument of sub-delegation, it had not been adequately carried out, as the CSPS developed a suite of policies and staffing tools — including defined roles and responsibilities — that were not always consistent. For instance, appointment policies were not always aligned with the approved sub-delegation instrument; roles, responsibilities and accountabilities were not adequately carried out; and organizational monitoring was not conducted as required.

9.27 The second objective was to determine whether appointments and appointment processes complied with the PSEA, the PSER, the PSC Appointment Framework and related organizational appointment policies. We found that staffing activities were conducted based on a framework that could not result in appointments that would be compliant with the requirements established by the President and that, by itself, was not compliant with the PSC Appointment Framework. As a result, further review of appointments for compliance was not undertaken.

Action taken by the Public Service Commission

The PSC informed the CSPS of its initial observations early in the conduct of the audit. The CSPS took immediate action in response to the preliminary audit observations. It also asked the PSC to assist it in meeting its obligations under the Appointment Delegation and Accountability Instrument; ensure that appointments respect all legislative, regulatory, policy and other requirements; and improve its internal controls. During the early stage of the audit, the PSC dedicated resources to the CSPS to help it to respond immediately to the preliminary audit observations.

The PSC systematically reviews audit information as well as an organization’s management response and associated action that it has taken or will take in response to the audit results and recommendations to determine whether any action should be taken by the PSC. As a result of this review, the PSC is satisfied with the CSPS’ management response and the actions it has taken or has committed to take in response to the audit results and recommendations. The PSC will continue to provide ongoing advice and support to the CSPS in the implementation of its action plan and will monitor progress on the implementation of the action plan on a quarterly basis. Another audit of the CSPS appointment framework and compliance will be conducted when the Commission determines it is appropriate.

Overall response by the Canada School of Public Service

The CSPS accepts the findings and recommendations of the PSC, and as the deputy head, I am fully committed to addressing the issues raised in a timely, rigorous and effective manner. A detailed action plan is being developed and will strengthen the staffing regime to ensure compliance with staffing values and with legislative, regulatory and policy requirements. It should be noted that each of the findings leading to the recommendation will be subject to specific improvement measures. The CSPS has begun discussion with the PSC representatives to put in place a Letter of Understanding to collaborate on specific areas for improvement. An important component of our response will be training and development.

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