Audit of Foreign Service Directives – Education

Final report

Global Affairs Canada
Office of the Chief Audit Executive

Tabling Date
December 2019

Acronyms and Symbols

CBS

Canada-based staff

CSDP

Common Services Delivery Point

DMCO

Deputy Mission Consular Officer

FSD

Foreign Service Directive

HOM

Head of Mission

LES

Locally Engaged Staff

MCO

Mission Consular Officer

NJC

National Joint Council

Executive summary

In accordance with Global Affairs Canada’s approved 2019-20 Risk-based Audit Plan, the Office of the Chief Audit Executive conducted an audit of Foreign Service Directives (FSDs) – Education.

Why it is important

The Government of Canada comprises employees that work in Canada as well as locally engaged staff (LES) and Canada-based staff (CBS) that work abroad. These CBS are federal public servants who rotate into positions at missions around the world. In addition to their salaries, CBS are eligible to receive allowances and benefits during their assignment abroad, under the legal authority of Foreign Service Directives (FSDs). The directives reflect three principles: comparability with life in Canada, incentive-inducement to serve abroad, and program-related needs. FSDs are co-developed by bargaining agents and public service employers at the National Joint Council (NJC) of the Public Service of Canada. The FSDs form part of the employees’ collective agreements and undergo cyclical review. Further to the cyclical review, new FSDs came into effect on April 1, 2019.

In 2018-19, Global Affairs Canada disbursed FSD payments of approximately $157 million. This included approximately $35 million for education-related FSDs. Education-related FSD expenditures have steadily increased over the past three fiscal years.

What was examined

The objective of the audit was to determine whether key controls over the management of education-related FSDs are in place and operating effectively. The audit specifically focused on education-related FSD transactions, namely FSD 30.7, 32, 33, 34, and 35. A sample of transactions ranging from April 1, 2018, to March 31, 2019 were tested. The audit also reviewed management actions and processes to integrate and communicate changes made to education-related FSDs since April 1, 2019. More details about the audit objective, scope and criteria are presented in Appendix C.

What was found

Key controls over the payment of education-related FSDs are in place and generally operating effectively. There are, however, opportunities to improve the administration of transactions, and monitoring practices.

Recommendations

1. The Assistant Deputy Minister of Human Resources should ensure that FSDs administered by Missions and CSDPs are in compliance with NJC directives, financial delegations, and departmental procedures.
2. The Assistant Deputy Minister of Human Resources should clarify roles and responsibilities for monitoring of FSDs processed at missions, and ensure sufficient training and support is provided to those conducting the monitoring. 

Statement of Conformance

This audit was conducted in conformance with the Institute of Internal Auditors' International Standards for the Professional Practice of Internal Auditing and with the Treasury Board Policy and Directive on Internal Audit, as supported by the results of the quality assurance and improvement program. Sufficient and appropriate audit procedures were conducted, and evidence was gathered, to support the accuracy of the findings and conclusion in this report, and to provide an audit level of assurance. The findings and conclusion are based on a comparison of the conditions, as they existed at the time, against pre-established audit criteria that were agreed upon with management and are only applicable to the entity examined and for the scope and time period covered by the audit.

1. Background

In accordance with Global Affairs Canada’s approved 2019-20 Risk-based Audit Plan, the Office of the Chief Audit Executive conducted an audit of Foreign Service Directives (FSDs) – Education. The objective of this audit was to determine whether key controls over the payment of education-related FSDs are in place and operating effectively.

The Government of Canada comprises employees that work in Canada as well as locally engaged staff (LES) and Canada-based staff (CBS) that work abroad. These CBS are federal public servants who rotate into positions at 178 missions located in 110 countries^{Footnote 1}. In addition to their salaries, these employees are eligible for allowances and benefits during their assignment abroad under the legal authority of FSDs. The directives reflect three principles: comparability with life in Canada, incentive-inducement to serve abroad, and program-related needs. The provisions of the directives recognize differences among regions, countries and cities in terms of living conditions, including cost of living, health care, security, adequate housing, and education.

FSDs are co-developed by bargaining agents and public service employers at the National Joint Council (NJC) of the Public Service of Canada. The FSDs form part of the employees’ collective agreements and undergo cyclical review. Following the most recent cyclical review, new FSDs came into effect on April 1, 2019. The NJC is responsible for the development of FSDs while Treasury Board is responsible for oversight. Global Affairs Canada administers the FSDs to its employees and to those of 22 other governmental entities. The Department also provides input on content and any potential issues with the application of FSDs through its participation in NJC working groups. In 2018-19, Global Affairs Canada disbursed FSD payments of approximately $157 million.

The FSDs include several provisions related to education, including day-care assistance, education assistance at a Lycée in Canada, education allowances and education travel. In 2018-19, the Department disbursed approximately $35 million for education-related FSDs. Education-related FSD expenditures have steadily increased over the past three fiscal years (see Appendix A). Some of these FSDs are administered at Headquarters, others at missions abroad. Some FSDs are a shared responsibility between missions and Headquarters.

Departmental Context

Foreign Service Directives Bureau

At Global Affairs Canada, the Human Resources Branch is responsible for administering and interpreting the FSDs. Reporting to the Human Resources Branch, the Foreign Service Directives Bureau is responsible for providing services to employees who are assigned abroad and their dependants in support of the Department's main business lines and other programs of the Government of Canada. The bureau has two divisions:

• The FSD Client Services Centre provides client-oriented advice and administration of the FSDs to eligible employees who have been assigned abroad and their dependants. It consists of 21 FSD Client Advisors, each of whom are assigned to a portfolio of missions.
• The FSD Policy and Monitoring Division clarifies and provides interpretation for FSD policy and monitors the expenditures made under the authorities provided by the FSDs. Within the division, there is an FSD – Education Coordinator who is responsible for the policy coordination and administration of education-related FSDs.

Missions

Heads of Mission (HOMs) are involved in the strategic planning and decision-making process of all programs including FSDs. Although HOMs normally assign the responsibility of the administration of FSDs to Management and Consular Officers (MCOs), the HOMs remain accountable. Missions have delegated authority for FSD 32 Daycare Assistance and 34.2 Education at Missions, with some restrictions. However, all expenses for the HOM and his/her dependents must be approved by the FSD Bureau.

Common Services Delivery Point (CSDP)

The Department has seven Common Services Delivery Points (CSDPs), which provide standardized financial, contracting and procurement, and LES human resource services to missions around the world. With respect to FSDs, CSDPs are responsible for processing payments made by missions and ensuring that FSD transactions comply with financial policies and authorities.

Interdepartmental Coordinating Committee (Working Group B)

Working Group B, located at Headquarters, is chaired by the Director of the FSD Policy and Monitoring Division and is composed of representatives from seven other government departments. It meets on a monthly basis and provides a forum for discussion about the interpretation and application of certain FSDs. Its goals are to ensure consistent interpretation and application; to discuss and recommend possible solutions to specific concerns and issues on a case-by-case basis; and to provide departmental administrators with a venue to exchange information. With respect to education-related FSDs, Working Group B must approve expenses related to educational institutions that are not on the pre-approved list, as well as supplementary programs and special needs education.

2. Observations and Recommendations

This section sets out key findings and observations, divided into four general themes addressing administration of education-related FSD transactions; monitoring; human resource capacity; and training, guidance, and change management.

2.1 Administration of Education-Related FSD Transactions

It was expected that controls would be in place to ensure that education-related FSD payments are legitimate, accurate, in compliance with directives, and appropriately approved, supported, and recorded. In order to assess this, a total of 135 financial transactions were tested during the audit, representing approximately $4 million. Testing criteria was derived from the NJC directives, departmental policies and procedures, and the departmental Delegation of Financial and Contractual Signing Authorities Instrument for FSDs.

Transaction testing results determined that controls were generally operating effectively to ensure education-related FSDs were administered appropriately, legitimately, and that they were compliant. However, testing identified a number of errors, which are summarized below. A detailed breakdown of testing results by each FSD tested, along with their description, is in Appendix B.

Transactions processed by Mission:

• In four cases, the Section 34 approver (MCO/DMCO) of the FSD expenses did not have delegated financial authority over a transaction (FSD for HOM’s dependant);
• In two cases, allowances paid were not compliant with directives or internal policies and should not have been allowed;
• In three cases, the pre-approved expenditure limits were exceeded;
• In two cases, pre-approval for an allowance was done at mission when it should have occurred at the FSD Bureau;
• In two cases, allowances were paid without the required Working Group B approval; and
• In three cases, the required documentation was not on file and/or sufficient supporting evidence could not be produced to substantiate the payment.

Transactions processed by the FSD Bureau:

• In one case, allowances were paid prior to pre-approval; and
• In one case, the required documentation was not on file and/or sufficient supporting evidence could not be produced to substantiate the payment.

While the majority of transactions tested were appropriate, some of the gaps identified above were found with sufficient frequency to warrant specific actions by management to mitigate the risk of inappropriate or illegitimate FSD transactions being processed. To address instances of non-compliance with financial delegation and procedures, and instances of missing required and supporting documentation, the actions below are recommended.

Recommendation 1:

The Assistant Deputy Minister of Human Resources should ensure that FSDs administered by Missions and CSDPs are in compliance with NJC directives, financial delegations, and departmental procedures.

2.2 Monitoring

It was expected that monitoring mechanisms are in place and operating effectively to ensure that education-related FSDs are consistently and appropriately applied.

Overall, monitoring practices are limited, not formalized, and inconsistent. The FSD Bureau has some monitoring practices in place over education-related FSDs that they are responsible for processing. For example, the Bureau verifies the eligibility of dependants receiving FSD 33 (students registered in the Lycée in Canada).

There is, however, limited monitoring of transactions associated with FSD 34 Education at Mission, which represent 83% of total education-related FSD expenditures. These FSDs are administered at missions and submitted to CSDPs for payment. CSDP questionnaire respondents indicated that, prior to payment, they review transactions against financial delegations, policies and guidelines, but not against the FSDs. They do not consider monitoring compliance with FSDs to be part of their role, nor do they feel they have sufficient expertise. Testing noted that CSDPs are not consistently identifying instances where MCOs or DMCOs are approving Section 34 for FSD payments related to HOM dependants, which is beyond their delegated financial authority. In addition, CSDP questionnaire respondents indicated that they had not received any specific or formal training regarding FSDs, and that they were not always clear about where to find available information and guidance. As noted in section 2.4.2, the FSD Bureau is in the process of conducting training sessions at each CSDP. 

Currently, there is a lack of formal monitoring processes over FSD 34 transactions, consisting of clearly defined roles, responsibilities, and expectations, consistent execution, and training support. Without this process there is a risk that these FSDs are not consistently and appropriately applied, and some non-compliant transactions may be approved and paid.

Recommendation 2:

The Assistant Deputy Minister of Human Resources should clarify roles, and responsibilities for monitoring of FSDs processed at missions, and ensure sufficient training and support is provided to those conducting the monitoring.

2.3 Human Resource Capacity

The audit team expected that strategies would be in place to maintain sufficient human resource capacity within the Foreign Service Directives Bureau to process and support education-related FSD transactions. This strategy would be beyond the routine cyclical human resource planning processes, and specifically designed to mitigate the high levels of turnover noted below, and improve staff retention.

The FSD Bureau administers FSDs to more than 4,200 clients and dependants across 22 departments at Headquarters and missions abroad. Over the past five years, the Bureau’s clientele has increased by 16% with no corresponding increase to bureau personnel. In June 2019, each Client Advisor was responsible for as many as 201 clients. Interviews with FSD Bureau management and Client Advisors indicated that the high workload has had a considerable impact on operations, particularly the bureau’s ability to process FSD transactions and provide client advice in a timely manner. Indeed, several MCO questionnaire respondents indicated that while they receive useful advice from Client Advisors, the response time can be long. Some MCOs indicated that they felt that the FSD Bureau was ‘short-staffed’ and ‘overwhelmed’. Management indicated during interviews that the high workload, coupled with the lack of internal opportunities for career progression, has resulted in high turnover within the Bureau, further compounding workload issues. They noted that turnover in the FSD Client Services Centre had been as high as 200% over the past two years.

To address these issues, FSD Bureau management sought and received approval for the creation of 10 new positions to reduce the general workload, and to increase the capacity to manage crisis and complex cases and the increased verification obligations resulting from the new FSDs.

2.4 Guidance, Training, and Change Management

2.4.1 Departmental Guidance (Procedures, Tools and HQ Support)

The audit team expected that departmental guidance on policy and procedures, tools and support would be clear and communicated to stakeholders in order to help ensure that FSD payments are eligible, sufficiently supported, and appropriately approved.

The FSD Policy and Monitoring Division maintains an Intranet site with numerous tools and guidance documents, including a Foreign Service Handbook, MODUS pages and Frequently Asked Questions. The Foreign Service Handbook is intended for employees and their dependants who are preparing for a posting abroad, and it provides a description of each FSD, the eligibility requirements, and the departmental procedures. The Handbook is updated on an annual basis and is accessible to all employees through the Intranet.

In some cases, there is a lack of clarity in documented procedures and tools, which resulted in inconsistent application of certain FSDs. In particular, departmental guidelines do not include a clear procedure for calculating and claiming mid-day meals (FSD 34.2), and the Handbook does not indicate that expenses for special education (FSD 34.9) must be authorized by Working Group B. At the time of the audit, the FSD Policy and Monitoring Division was in the process of clarifying roles, responsibilities, and procedures through the development a series of Intranet pages for each FSD.

Based on questionnaire responses, MCOs processing FSDs at mission are generally familiar with the available guidelines and tools and found the information to be sufficient to help them administer FSDs. Several MCOs, however, indicated that they would like more detailed guidance related to their roles and responsibilities, such as checklists or a desk book. Additionally, most MCO respondents indicated that they receive useful and sufficient advice from their FSD Client Advisors.

2.4.2 Training

The audit team expected that employees responsible for administering and processing education-related FSDs would receive adequate training to fulfill their responsibilities and accountabilities.

The Department offers a one-day pre-posting course for MCOs and Deputy MCOs. The objective of the course is to familiarize employees with FSDs and provide them with an overview of their functionality. It also describes the roles and responsibilities of Headquarters and missions in the administration of each FSD.

According to questionnaire responses, about a third of MCO respondents indicated it had been over 10 years since their last refresher training, and another third of respondents indicating that they have received little or no training. The audit team noted that the FSD Policy and Monitoring Division is currently providing FSD training to MCOs abroad, and to CSDP staff. This training covers three key themes: relocation; FSD delegated authorities; and the 2019 changes to FSDs. FSD Bureau management also indicated that they plan to modernize departmental training by creating short videos to clarify and provide instructions for the most commonly used FSDs.

For FSD Client Advisor training, interviews indicated that advisors receive refresher training prior to the annual relocation season and portfolio meetings held by team leaders. New advisors receive formal and on-the-job training, and their workload slowly increases as they gain experience and knowledge. During posting season, there are daily issues meetings led by management, which allow for effective and timely decision-making. The Client Advisors interviewed indicated that they felt the level of training they received was sufficient.

2.4.3 Change Management

The audit team expected that changes and updates (including changes from cyclical reviews of directives) are effectively communicated to all stakeholders to ensure FSDs are administered in accordance with the current policy and directives.

Changes made to education-related FSD directives in April 2019 were communicated through various means to those who administer and benefit from these FSDs. Means of communication included departmental broadcast messages, emails sent specifically to FSD administrators, pre-posting workshops, updates to online resources and guidance, in person training at CSDPs and teleconference calls. The MCO and CSDP questionnaire respondents indicated that individuals in the field are aware of April 2019 changes to the education-related FSDs.

Overall, FSD Bureau management is taking appropriate steps to ensure employees responsible for administering and processing education-related FSDs receive adequate training, proper guidance and are aware of the updates to FSDs.

3. Conclusion

Key controls over the payment of education-related FSDs are in place and generally operating effectively. There are however, opportunities to improve the administration of transactions, and monitoring practices.

Appendix A: Summary of Education-related FSD Transactions

Appendix B: Transaction Testing Results

It was expected that controls would be in place to ensure that education-related FSD payments are legitimate, accurate, in compliance with directives, and appropriately approved, supported, and recorded. The NJC directives, as well as departmental procedures, were used to identify requirements for education-related FSDs and determine compliance. In addition, compliance with the departmental Delegation of Financial and Contractual Signing Authorities Instrument for FSDs was also assessed. Missions have delegated authority for FSD 32 Daycare Assistance and 34.2 Education at Missions (with some restrictions). All expenses related to FSD 33 Lycée in Canada and FSD 35 Education Travel must be approved by the FSD Bureau, along with any FSD expenses for the Head of Mission and his/her dependants.

A total of 135 financial transactions were tested during the audit, representing approximately $4 million. These transactions were selected based on a judgmental sampling methodology. Since the sample selected was judgmental and not random, results cannot be extrapolated to the population.

Please see breakdown below:

Transaction testing determined that controls were generally operating effectively to ensure education-related FSDs were administered appropriately, were legitimate, and compliant. Testing did, however, identify a number of exceptions/errors. A summary of testing results by each FSD tested, along with their description, is provided below.

FSD 32 Daycare Assistance

Employees who are single or working parents are entitled to receive an allowance for daycare costs incurred at the mission, which are in excess of similar facilities in Ottawa. HQ , in consultation with missions and with approval from WGB, establishes a representative daycare ceiling, which represents the maximum amount payable for the daycare allowance at the mission. In order to request daycare allowance, employees must complete a Daycare Allowance FSD 32 Form and attach the enrolment contract, fee schedule, and the Declaration of Daycare Expenses for self-employed spouses only.
The following errors were noted:

• In one case, the daycare ceiling was exceeded;
• In two cases, the FSD 32 Form was not on file and one where it was completed after the fact; and
• In one instance, there was no evidence of the required employee’s declaration of being a single parent or having a working partner at post.

FSD 33 Education Assistance at a Lycée in Canada

The availability of French language education while serving outside Canada is often limited to the French National curriculum and this curriculum requires continuity throughout a child’s schooling. As such, career foreign service employees serving in Canada are entitled to receive financial assistance in enrolling their dependant children in a Lycée in Canada.

Based on the 2013 NJC directive, the eligibility of FSD 33 is normally limited to the two-year period immediately following assignment abroad and/or commencing rotational employment. Exceptions to the limitations may be considered by the Deputy Head, who may approve extensions of up to one year at a time, as a result of operational requirements. However, FSD Bureau management indicated that this two-year limit has never been enforced by the Department, although the Bureau implemented and has been enforcing a seven-year limit since 2016. In 2019, this FSD was updated to a limit of a maximum of six years immediately following assignment abroad and/or commencing rotational employment. The Deputy Head may consider on an individual basis one exception to the limitation. Furthermore, Working Group B may consider additional requests in exceptional circumstances. To request assistance under FSD 33, employees must complete an FSD 33 Eligibility Form. The department pays the Lycée directly for tuition fees.

Based on a review of 2018-19 enrollment, comprising 168 dependants for 103 CBS, there were no significant issues.

FSD 34 Education Allowances

Education at Mission (34.2)

Employees serving abroad are also entitled to receive financial assistance to ensure that their dependant children’s elementary and secondary education meets Canadian standards and allows them to easily re-enter the Canadian school system. The Interdeparmental WGB committee has established a list of schools, recognized as offering education that is compatible with education in Canada. From this list of compatible schools, Working Group B identifies representative schools for English and French education. The representative school’s fees are established as the maximum allowable education allowance for the mission. If an employee wishes to send their child to a school that does not appear on this list, the request must be reviewed and approved by Working Group B.

The NJC directive includes a list of admissible education expenses, such as registration and tuition fees, and other expenses that are a compulsory condition of enrolment. Subject to Working Group B approval and adherence to FSD 34.1.4 field trips may be considered an admissible expense if the trip is compulsory, a non-fee paying option is not available and the costs are included in the school fee schedule or if failure to participate would significantly impact the child’s grade or result in failure of the grade. In order to request an education allowance, employees must complete a Proposal FSD 34 Education Allowance form and submit it for approval to their mission.

The following errors were noted:

• In three cases, the person approving the FSD expenses did not have delegated authority (MCO/DMCO approving S.34 for a HOM’s FSD request);
• In one case, the child attended a school that was not on the approved list, and Working Group B approval was not sought;
• In one case, the deductible for mid-day meals was incorrectly claimed; and
• In one case, a field trip was reimbursed, without evidence of mandatory nature.

Tutoring (34.2.3)

Employees can request private tutoring for a dependant child in the second official language, up to a maximum of 50 hours per school year. To request this allowance, employees must complete a Proposal FSD 34 Education Allowance and attach a letter from the tutor detailing the proposed dates, hours and costs of tutoring. As per the 2019 Foreign Service Handbook, second language tutoring is to be approved by the FSD Bureau. In addition, students may be eligible for extra tutoring in subjects where the educational level of the child/student is below that of the class, when the academic deficiency is attributable to foreign service. Extra tutoring must be authorized by Working Group B.

The following errors were noted :

• In two cases, the MCO approved second language tutoring, rather than the FSD Bureau;
• In two cases, the actual expense exceeded the approved amount, by more than CAD $1,000; and
• In one case, the extra tutoring was approved by the Mission, without Working Group B approval.

Education in Canada (FSD 34.3 and 34.4)

Employees can request an education allowance for elementary education in Canada, where compatible education at the post is not available for a particular child, or living conditions at the post are unhealthy for that child, and neither parent/guardian is in Canada to provide childcare. For secondary education, despite the fact that educational facilities at the mission are compatible, employees may choose to send their child to a Canadian educational institution. The allowable limit covers admissible education expenses as well as board, lodging, laundering and mending services, up to a ceiling established by the NJC. To request an allowance for education in Canada, employees must complete a Proposal FSD 34 Education Allowance form. This allowance must be approved and processed by the FSD Bureau.

The following errors were noted :

• In one case, sufficient supporting documentation was not available to substantiate the payment. The required FSD pre-approval (form 2020) and payment approval (Section 34) could not be found.
• In one case, the FSD pre-approval (form 2020) was submitted and approved after tuition payments were made.

Post-secondary Shelter Assistance (34.6)

While posted at mission, employees can also request shelter assistance for students who are registered full-time at a post-secondary educational institution in Canada. To request this assistance, employees must complete a Shelter Assistance Certification Form and attach a registration confirmation from the educational institution to confirm registration and a copy of the student’s lease or Residence Agreement, signed by the student. Shelter assistance must be approved by the FSD Bureau. Based on transaction testing, there were no significant issues.

Special Education (34.9)

Employees can request a special education allowance, for a dependant child/student with proven special education needs, on an individual basis. This allowance must be based on programs normally provided without charge by the Ontario Ministry of Education and/or the Ontario Ministry of Community and Social Services. Special education allowance must be approved by Working Group B. Based on transaction testing, there were no significant issues.

FSD 35 Education Travel

Employees may request an allowance for travelling expenses to assist a dependant student to get to their place of schooling, when they are being educated away from the mission. Employees must request the FSD Bureau’s approval prior to travel, by submitting an estimate of the costs based on the lowest airfare available. The FSD Client Advisor will determine eligibility and entitlement and then email authorization to the employee and the mission. Employees must complete and submit Certification and Verification Form for Travel, within 30 days of travel. Based on transaction testing, there were no significant issues.

FSD 30.7 – Education Transportation

Employees may request allowance to assist with the cost of transporting a child to and from school in instances where school transportation is not provided by the school or incorporated in the school fees.

Based on a sample of four transactions testing found one case in which the person approving the FSD expenses did not have delegated authority (MCO/DMCO approving S.34 for a HOM’s FSD request).

Appendix C: About the Audit

Objective

The objective of the audit was to assess whether key controls over the payment of education-related FSDs are in place and operating effectively.

Scope

The audit examined education-related FSD transactions, and controls impacting the management of those FSDs. The audit tested a sample of transactions ranging from April 1, 2018, to March 31, 2019. The audit also reviewed management actions and processes to integrate and communicate changes made to education-related FSDs since April 1, 2019.

FSDs include several provisions related to education, including daycare assistance, education assistance at a Lycée in Canada, education allowances and education travel. This audit focused on the application of the following FSDs related to education:

• FSD 30.7 – Education Transportation: Allowance to assist parents with the cost of transporting a child to and from school in instances where school transportation is not provided by the school or incorporated in the school fees.
• FSD 32 Daycare Assistance: Allowance to assist parents with the cost of enrolling children in daycare that exceeds the cost of similar facilities in Ottawa.
• FSD 33 Education Assistance at a Lycée in Canada: Financial assistance to career foreign service employees while serving in Canada in enrolling their dependent children in a lycée in Canada.
• FSD 34 Education Allowances: Financial assistance to employees serving abroad to ensure that their dependent children’s elementary and secondary education meets Canadian standards and allows them to easily re-enter the Canadian school system.
• FSD 35 Education Travel: Allowance for travelling expenses for a dependent student to assist in paying for travel expenses (incurred at the beginning and end of an employee’s assignment to a post) to send a dependent to an approved educational institution.

Criteria

The criteria were developed following the completion of the detailed risk assessment and considered the audit criteria related to the Management Accountability Framework developed by the Office of Comptroller General of the Treasury Board Secretariat. The audit criteria were discussed and agreed upon with the auditees. The detailed criteria are presented as follows.

Approach and Methodology

In order to conclude on the above criteria, and based on identified and assessed key risks and internal controls associated with the related business processes, the audit methodology included, but was not limited to the following:

• Review of relevant policies and directives on FSDs – Education;
• Process review and mapping;
• Interviews with Departmental staff and management;
• Questionnaires sent to MCOs (31 responses) and CSDPs (6 responses);
• A walkthrough of the FSD – Education portal (under development);
• Data analysis and tested through file review and a judgemental sample; and
• Other relevant methods as deemed necessary by the audit team.

Appendix D: Management Action Plan