2014 Fall Report of the Auditor General of Canada Chapter 4—Providing Relocation Services

2014 Fall Report of the Auditor General of Canada
Chapter 4—Providing Relocation Services

Introduction

4.1 To meet their operational needs, the Canadian Armed Forces, the Royal Canadian Mounted Police (RCMP), and the federal public service can require their members or employees to relocate elsewhere in Canada or abroad. Members of the Canadian Armed Forces and the RCMP may be required to serve anywhere in Canada. It is the policy of the Government of Canada that employees be relocated in the most efficient fashion, at the most reasonable cost to the public, while having a minimum detrimental effect on the members or employees, their families, and departmental operations.

4.2 To meet the needs of members or employees whose jobs require  moving to a new location, and to manage the relocation process, the government approved the Integrated Relocation Program (IRP) in 2002. The government contracts out relocation services under the IRP.

4.3 In August 2009, the government announced the awarding of the IRP contract to Brookfield Global Relocation Services (“the contractor”). Under the contract, the contractor provides relocation services to members of the Canadian Armed Forces and the RCMP, and employees of the Government of Canada in accordance with their respective relocation policies. These services include claim processing, and the provision of information, counselling, and professional assistance at every step of the relocation process. Also included are relocation planning, marketing assistance, and destination services. The contractor also provides access to third-party service providers such as realtors, lawyers and notaries, home inspectors, appraisers, and rental search agencies.

4.4 On average, about 15,500 members of the Canadian Armed Forces and 2,200 members of the RCMP, along with their families, have been authorized each year to receive relocation services under the 2009 contract.

4.5 Expenditures for the 2012–13 fiscal year included $228.9 million for the Canadian Armed Forces, $49.8 million for the RCMP, and $24.5 million in administration fees paid to the contractor.

4.6 The contract sets out two separate service models, one designed to provide relocation services to members of the Canadian Armed Forces, and the other for RCMP and Government of Canada personnel. These separate models were intended to take into account the different operating locations and environments of the organizations. For example, Canadian Armed Forces members are for the most part located at large bases; accordingly, the contract provides for Canadian Armed Forces members to have face-to-face services from the contractor’s advisors, who are co-located on Canadian Armed Forces bases across the country. On the other hand, RCMP members may be transferred to rural areas or isolated posts, where they often work shifts and therefore might not be available during regular business hours; accordingly, RCMP members receive services from the contractor via telephone and email through the contractor’s operational offices located in Winnipeg and Halifax.

Roles and responsibilities

4.7 Under the IRP contract, the Canadian Armed Forces and the RCMP are responsible for all matters concerning the monitoring of the work under the contract for their responsible entity only.

4.8 In addition, under the IRP contract, the Canadian Armed Forces, as technical authority, is the representative of the departments and agencies for whom the work is being carried out under the contract, and is responsible for all matters related to the technical content of the work under the contract. This includes verifying that the contractor has complied with all technical requirements, and reviewing and approving all final deliverables.

Past audit work

4.9 In 2006, we examined the financial controls implemented by National Defence and the Canadian Armed Forces and by the RCMP in relation to the administration of the contracts. We concluded that National Defence had yet to establish basic internal controls for the expenditure of public funds for the program, and that the RCMP needed to ensure that it comply more rigorously with the government’s policies and procedures for validating expenditures under the IRP. We also examined the extent to which the government had established appropriate performance measures for the relocation contracts. We concluded that the organizations had not developed the tools or indicators needed to assess the performance of the contractor.

4.10 Our Spring 2014 audit focused on the awarding of the 2009 IRP contract, specifically on whether decisions and actions taken by the involved organizations facilitated access and encouraged competition. We concluded that while the responsible organizations had followed most of the established processes for a competitive process, some barriers remained that did not facilitate access and encourage competition.

Focus of the audit

4.11 We examined whether the Canadian Armed Forces and the RCMP had fulfilled their responsibilities in managing selected requirements of the 2009 Integrated Relocation Program contract in accordance with the relevant government authorities and terms and conditions of the contract. We assessed the extent to which the Canadian Armed Forces and the RCMP had monitored the services provided under the contract and taken corrective action, when necessary, in the areas of financial management and performance measurement.

4.12 Relocation services for federal public service employees were not included in the scope of the audit. We did not audit Public Works and Government Services Canada’s role as contract authority; nor did we audit the Treasury Board of Canada Secretariat, which is responsible for leading policy development and interpretation for client departments. Moving services for household goods and effects are provided at an additional cost under separate contracts, and are not within the scope of this audit.

4.13 Our conclusions about management practices and actions refer only to those of the Canadian Armed Forces and the RCMP. The rules and regulations we refer to are those that apply to public servants; they do not apply to the contractor. We did not audit the contractor. Consequently, our conclusions do not pertain to any practices the contractor followed. We also did not assess individual claims made by relocated employees or members, or activities related to the moving of household goods.

4.14 The audit covered the management of selected requirements of the 2009 Integrated Relocation Program contract between December 2009 and December 2013. More details about the audit objective, scope, approach, and criteria are in About the Audit at the end of this chapter.

Observations and Recommendations

Financial and administrative controls

4.15 The Financial Administration Act (FAA) sets out a series of fundamental principles on the manner in which government expenditures can be made. Compliance with the terms of the FAA is critical to maintaining the government’s control of its finances.

4.16 Section 34 of the FAA requires that before a payment can be made for goods or services received, the responsible department official must certify that the work was performed, the goods were supplied, or the services were rendered in accordance with the terms, conditions, and prices set out in the relevant contract.

4.17 We examined whether the Royal Canadian Mounted Police (RCMP) and the Canadian Armed Forces each have in place financial and administrative controls to verify that payments to the contractor are being made in accordance with section 34 of the FAA and their own internal policies. Effective financial and administrative controls support government organizations in their duty to safeguard public assets, use their resources economically and efficiently, and produce accurate and reliable financial information for reporting and decision making.

4.18 Adequate financial controls are important to ensuring that the work was performed, the goods were supplied, or the services were rendered in accordance with the terms, conditions, and prices set out in the relevant contract. Overall, we found that the RCMP has improved financial and administrative controls for relocation transactions. The process that the Canadian Armed Forces has implemented does not provide enough assurance that the payments are in accordance with the contract and the related policies.

The RCMP has improved controls for relocation transactions

4.19 In our 2006 report, we recommended that the RCMP ensure that it complies more rigorously with account verification policies and procedures for validating expenditures for the Integrated Relocation Program (IRP).

4.20 Advance payments. According to the Treasury Board’s Directive on Payment Requisitioning and Cheque Control, advance payments for goods and services can be issued before services are rendered, under certain circumstances—essentially, when the payments are considered essential to achieving program objectives and when no reasonable alternative exists. In the case of the RCMP, the IRP contract states that the contractor will be provided with funds in advance to pay for estimated expenditures.

4.21 To pay for relocation expenses incurred by its members, the RCMP uses an estimate of the final cost of each relocation as the basis for making a series of advance payments to the contractor. Individual files are monitored by 30 relocation reviewers at regional offices across the country. These reviewers are also responsible for approving and scheduling the removal of household goods and effects, as well as for arranging travel for relocating members and their families.

4.22 Until April 2014, each RCMP regional office was responsible for ensuring that advance payments to the contractor were supported by appropriate receipts. We found that while all regional offices had account verification practices in place before April 2014, only two regions had formal procedures to help ensure that all reviewers were monitoring relocation files in the same way.

4.23 RCMP officials told us that because of the number of overpayments and underpayments made by the contractor to members, and delays in identifying them, the organization took steps to increase its oversight efforts. The RCMP set up a working group in March 2013, with the objective of standardizing procedures across regional offices. This led to the RCMP’s adoption of national standard procedures in April 2014.

4.24 The national standard procedures are a monitoring tool intended to provide the relocation reviewers in regional offices with account verification practices and controls to apply when certifying payments to the contractor. They are intended to ensure that RCMP members receive payments in accordance with the Relocation Policy for the Royal Canadian Mounted Police, that the requirements of section 34 of the FAA are met, and that the reviewing of relocation files is consistent across the country.

4.25 The RCMP requires that the relocation reviewers review 100 percent of all relocation files. This review includes verifying that all the required approvals are complete, that payee information is accurate and complete, that transactions have been accurately calculated and properly supported, and that payments have been made in compliance with the relevant authorities.

4.26 Before adopting standard procedures across the country, the RCMP piloted them in its Pacific region. We conducted a file review to assess whether files were managed in accordance with the draft national standard procedures. We randomly selected 37 of the 112 relocation files that had been opened and closed in the Pacific region between June 2013 and March 2014. Our test consisted of verifying whether key financial and administrative controls had been applied as prescribed in the RCMP’s draft national standard procedures.

4.27 We found that payments made by the RCMP as part of the pilot project in the Pacific region were in compliance with the FAA, and that the files were in compliance with the draft national standard procedures. Any deficiencies we found were minor. We also found that the RCMP followed up on the individual observations and errors it found and informed the contractor that corrective action was required.

4.28 The RCMP has told us that it is too early to know whether the implementation of the national standard procedures has reduced the number of overpayments and underpayments, but that it plans to track this in the future.

4.29 The RCMP acknowledges that a 100 percent review of relocation files is not an optimal use of its resources. RCMP officials told us that relocations have led to complaints and grievances, and have come to the attention of senior RCMP management. Officials also told us that the contractor has made overpayments and underpayments to members. For these reasons, the organization has opted to review 100 percent of files.

4.30 Real estate incentive. During our data analysis, we noted that a real estate incentive of up to $12,000 is available to any RCMP member who elects not to sell his or her primary residence. If a member elects to receive the incentive, then on a subsequent transfer the member is not eligible for reimbursement of costs associated with the sale of his or her home. The incentive benefits both the member, who retains his or her home, and the government, which does not have to cover expenses related to the selling of real estate, such as commissions to real estate agents.

4.31 Of the 170 RCMP members who received a real estate incentive since 2009, we found that in six cases, the member was paid a real estate incentive or other benefits when not entitled to them under the RCMP IRP. These cases represent about $78,000 in overpayments to members.

4.32 We noted that all of these cases occurred before the national implementation of the standard procedures. The RCMP has told us that the risk of such errors occurring in the future has been reduced because it implemented the procedures for RCMP relocation reviewers in April 2014.

4.33 Recommendation. The Royal Canadian Mounted Police (RCMP) should periodically review the design and implementation of its national standard procedures to validate them and to ensure that they are applied consistently across the country. The RCMP should adopt a risk-based approach to selecting files for compliance review, to ensure that it is optimally using its resources.

The Royal Canadian Mounted Police’s (RCMP’s) response. Agreed. The RCMP fully implemented its national standard procedures in April 2014 following a successful pilot of the procedures in the Pacific regional office. The RCMP will continue to review and refine its standard procedures to focus the verification on areas of greatest risk to ensure optimal use of resources.

The Canadian Armed Forces’ process does not provide enough assurance that the payments are in accordance with the contract and the related policies

4.34 In our 2006 report, we recommended that the Canadian Armed Forces take steps to comply with the FAA and to develop a plan to ensure that expenditures made under the IRP are valid and accurate.

4.35 In 2006, the Canadian Armed Forces established a separate unit with 14 employees to manage its IRP. The Canadian Armed Forces is responsible for ensuring the necessary financial controls are established to verify that all payments made under the Canadian Forces Integrated Relocation Program are compliant with section 34 of the FAA.

4.36 Relocation claims are considered high-risk transactions under National Defence’s internal account verification policy and according to the policy are to be fully reviewed by the Department before it certifies compliance with section 34 of the FAA.

4.37 The Canadian Armed Forces has a daily process to ensure that the cheques that the contractor has written have been cleared through the contractor’s bank account. The Canadian Armed Forces then certifies that all the payments for that day comply with section 34 of the FAA.

4.38 After the certification, the verification unit then selects approximately 15 individual transactions for review daily. The Canadian Armed Forces told us that it considers that the examination of 15 transactions provides it with an overall assurance about all of the transactions for that day. It makes a request to the contractor for supporting documentation, to be used to determine whether the amount paid was justified. We were told that during the 2012–13 fiscal year, the unit verified 3,960 transactions, which represents about 0.5 percent of the total of 838,191 transactions processed.

4.39 These processes do not meet the departmental policy because all relocation claims have not been reviewed before certifying compliance with section 34 of the FAA. In addition, while 100 percent review of all relocation claims may not be practical, we found that the review of 15 transactions per day is not usually large enough to give the Canadian Armed Forces statistical assurance on the population of transactions for the purpose of certifying compliance with section 34 on that day. Consequently, the Canadian Armed Forces cannot demonstrate that it fully meets the requirements of section 34 of the FAA.

4.40 Recommendation. The Canadian Armed Forces should improve its process to ensure that payments made under the Canadian Forces Integrated Relocation Program are appropriate and meet all the requirements of section 34 of the Financial Administration Act (FAA).

The Canadian Armed Forces’ response. Agreed. By 27 February 2015, Chief Military Personnel staff will complete an examination of the management control framework governing the current process in place for the Canadian Forces Integrated Relocation Program to determine where improvements could be made to address all of the requirements of section 34 of the FAA. In particular, the suitability of the sampling plan in place will be examined. The requirements of National Defence’s financial policy will also be reviewed to ensure that it provides appropriate guidance with respect to relocation transactions.

The Canadian Armed Forces’ monitoring of the status of files helps avoid payment of cancellation fees

4.41 When the Canadian Armed Forces informs the contractor of its intent to relocate a member, this triggers the creation of a file. However, relocations can subsequently be cancelled for a variety of reasons—for example, if a member is released from the Canadian Armed Forces before the relocation can take place, or on compassionate grounds. In the case of a cancelled relocation, if the file has been open for less than 60 days, there is no cancellation fee paid to the contractor. If the file is older than 60 days, the Canadian Armed Forces is subject to a cancellation fee.

4.42 The Canadian Armed Forces monitors the status of relocation files for the first 59 days after they are opened, to keep track of cancellations so that they can advise the contractor and avoid cancellation fees. Over the life of the contract, this monitoring has helped to identify relocations cancelled within the 60-day period. We found that from December 2009 to June 2013, the Canadian Armed Forces identified and cancelled 3,946 relocation files within the 60-day period. Through this monitoring, the Canadian Armed Forces avoided the payment of $1.9 million in cancellation fees.

4.43 However, we found that 153 files were not identified within the 60-day period, resulting in the payment of approximately $72,420 in cancellation fees. We were told that this happened because of a Canadian Armed Forces technical problem that has since been resolved.

Performance measurement

4.44 Effective performance measurement is important to managing and administering contracts successfully. It requires clear targets and indicators and the collection and analysis of data. In our 2006 audit, we reported that the government had not developed the tools or indicators needed to assess the performance of the Integrated Relocation Program (IRP) or that of the contractor. In that audit, we recommended that formal mechanisms be established to measure and report on the contractor’s performance. We also recommended an ongoing analysis of previous years’ files to validate policy and program application.

4.45 In our current audit, we examined whether the Canadian Armed Forces’ monitoring provided reasonable assurance to the Canadian Armed Forces that the contractor was complying with the contract’s terms and conditions. We reviewed the contract requirements and deliverables for performance measurement, and conducted interviews and data analyses, to determine whether selected performance information allowed the Canadian Armed Forces to confirm that the contractor was meeting the terms and conditions of the contract.

4.46 Overall, we found that the key elements of performance measurement, which should allow the Canadian Armed Forces to monitor the contractor’s performance, were developed and reported on as required. However, we also found that the Canadian Armed Forces does not leverage the information at its disposal to help ensure that every member receives benefits in accordance with the policy. We also found that low response rates to surveys of members limit their usefulness in assessing member satisfaction and in validating the contractor’s results.

Tools were developed to measure the Integrated Relocation Program’s performance

4.47 Under the terms of the contract, the contractor was required to develop and deliver a performance measurement plan and produce quarterly performance measurement reports to demonstrate that it was meeting the targets set out in the plan.

4.48 The contractor developed a performance measurement plan that included 69 performance indicators and related targets.

4.49 The indicators included in the plan covered the major elements of the contractual requirements, including accuracy of financial information (such as overpayments and underpayments), compliance with policy, and member satisfaction. For example, each relocation file should contain sufficient documentation to demonstrate that the services were provided and that the member was compensated in accordance with his or her organization’s relocation policy. The performance target accepted by the government is that no more than 5 percent of all files have incomplete data.

4.50 Another key indicator set out in the performance measurement plan is that audits conducted by the organizations of relocation files find an error rate of no more than 2 percent in the total dollar value of overpayments and underpayments in the reviewed files.

4.51 We also found that the contractor is providing the required quarterly reports and that these contain information on all 69 performance targets.

The Canadian Armed Forces does not leverage the information at its disposal to help ensure that every member receives benefits in accordance with the policy

4.52 As part of its own monitoring of the contractor’s performance, the Canadian Armed Forces reviews approximately 1,000 relocation files from the previous year to ensure that the amounts paid to members were in accordance with the Canadian Forces Integrated Relocation Program Directive. During its review, the Canadian Armed Forces examines files to determine whether they contain sufficient documentation to support the payments for relocation expenses and to ensure that members are compensated for the relocation expenses they are entitled to. Files selected for review are from Canadian Armed Forces bases across the country and from all military ranks. In the 2013–14 fiscal year, the Canadian Armed Forces reviewed 996 relocation files from the previous fiscal year.

4.53 Due to the Canadian Armed Forces’ sampling approach, only about 75 percent of relocation files in the previous year are included in the population for selection—meaning that a significant number of relocation files in a given year are excluded from being selected for file review. We found that this is a limitation in the Canadian Armed Forces’ sampling approach.

4.54 As a result of its 2013–14 review of files closed during the previous year, the Canadian Armed Forces informed the contractor of observations it had identified in its review. Some of the observations pointed to potential overpayments and underpayments to Canadian Armed Forces members. The total of the potential overpayments and underpayments was $344,446, based on the 996 files reviewed that year. This represented approximately 2 percent of the total dollar value of payments. This Canadian Armed Forces review indicated that the contractor met the performance measure that the Canadian Armed Forces review of relocation files find no more than 2 percent in the total dollar value of overpayments and underpayments made to members.

4.55 We conducted a review of 30 randomly selected files from the 996 files reviewed by the Canadian Armed Forces to determine if it followed its process for reviewing files to ensure that the files contained sufficient information to support payments made to members.

4.56 We found that the Canadian Armed Forces had applied its process for reviewing files. Any deficiencies we found in their review were minor and related to documentation. We also found that the Canadian Armed Forces informed the contractor that, as a result of the Canadian Armed Forces observations, further action was required for 17 of the 30 files we examined.

4.57 Some of the observations made by the Canadian Armed Forces in the 17 files included the identification of errors in the calculation of benefits or the application of policies. The Canadian Armed Forces review found that not all errors were due to mistakes made by the contractor. However, the Canadian Armed Forces’ process identified that in 15 files, the errors were the result of the contractor miscalculating or misapplying benefits for individual members. The Canadian Armed Forces review found that for these files, the contractor may not be meeting the performance measure that no more than 5 percent of all files have incomplete data.

4.58 In our opinion, the Canadian Armed Forces could use the results of its reviews to address the reasons for and extent of the errors in an effort to help ensure that members consistently receive relocation benefits in accordance with the policy.

4.59 Recommendation. The Canadian Armed Forces should make better use of the results of its reviews so that there is a consistent provision of benefits to all members in accordance with the policy.

The Canadian Armed Forces’ response. Agreed. The results of the data collection and analysis will be further leveraged to ensure the consistent application of the Treasury Board–approved Canadian Forces Integrated Relocation policy.

Low response rates limit surveys’ usefulness in assessing member satisfaction

4.60 Another indicator we looked at was member satisfaction. Quantifying the satisfaction of relocated members helps decision makers understand how well the contractor is performing and helps decision makers prioritize actions on the basis of data. We looked at the processes established to assess members’ satisfaction with the relocation experience.

4.61 In 2006, we recommended that the Canadian Armed Forces and the Royal Canadian Mounted Police (RCMP) systematically collect information from members who have been relocated, to measure their satisfaction with the benefits and incentives of the IRP and the performance of the contractor.

4.62 As part of the performance measurement plan, the contractor is to measure member satisfaction with the services at the end of each relocation. The performance measurement target for this indicator is that 90 percent of member respondents report being satisfied or very satisfied with the contractor’s services. The target includes an expectation that 50 percent of members would respond to the contractor’s satisfaction survey.

4.63 For 2013, the contractor reported that satisfaction was generally high (over 94 percent). However, quarterly response rates to the surveys did not meet the performance target, fluctuating between 41 and 47 percent.

4.64 The Canadian Armed Forces also conducts annual surveys of its members. The 2013 Canadian Armed Forces survey reported that 82 percent of respondents were overall satisfied with the relocation services provided, with a response rate of 26 percent.

4.65 Low response rates limit both surveys’ usefulness in assessing member satisfaction and in validating the contractor’s satisfaction results.

4.66 Members who do respond can add comments to the surveys to describe their satisfaction or dissatisfaction. We found that the Canadian Armed Forces has taken some steps to address issues raised by the members. For example, when members identified difficulties in contacting or meeting with contractor relocation advisors, the contract was amended to allow for Canadian Armed Forces members to opt for a single point of contact during their relocations.

4.67 We found that the RCMP does not currently carry out a survey to determine whether its members are satisfied with the relocation services they have received.

4.68 While the organizations have taken action on issues that they are made aware of through surveys, the low response rates mean that neither the Canadian Armed Forces nor the RCMP can rely on the results to know the extent to which its members are satisfied with the services provided.

4.69 Recommendation. The Canadian Armed Forces and the Royal Canadian Mounted Police should consider other approaches to tracking and determining members’ satisfaction.

Conclusion

4.70 While the Canadian Armed Forces has taken steps to improve the management of the Integrated Relocation Program (IRP) contract, we concluded that it has not completely fulfilled its responsibilities in managing selected requirements of the 2009 IRP contract in accordance with the relevant authorities and terms and conditions of the contract. We concluded that the Royal Canadian Mounted Police (RCMP) has fulfilled its responsibilities in managing selected requirements of the 2009 IRP contract in accordance with the relevant authorities and terms and conditions of the contract.

4.71 The process that the Canadian Armed Forces has implemented does not provide enough assurance that the payments are in accordance with the contract and the related policies. The Canadian Armed Forces should improve its process to ensure that payments made under the Canadian Forces IRP are appropriate and meet all the requirements of section 34 of the Financial Administration Act.

4.72 The RCMP has improved controls for relocation transactions. The RCMP should adopt a risk-based approach to its review, to ensure that it is making optimal use of its resources.

4.73 A performance measurement plan was developed by the contractor and accepted by government. The Canadian Armed Forces should make better use of the results of its reviews so that benefits are consistently provided to all members in accordance with the policy.

4.74 Because of low response rates, the member satisfaction surveys provide limited information. As a result, neither the Canadian Armed Forces nor the RCMP knows the extent to which members are satisfied with the services provided.

About the Audit

The Office of the Auditor General’s responsibility was to conduct an independent examination of the management of the 2009 Integrated Relocation Program contract in order to provide objective information, advice, and assurance to assist Parliament in its scrutiny of the government’s management of resources and programs.

All of the audit work in this chapter was conducted in accordance with the standards for assurance engagements set out by the Chartered Professional Accountants of Canada (CPA) in the CPA Canada Handbook—Assurance. While the Office adopts these standards as the minimum requirement for our audits, we also draw upon the standards and practices of other disciplines.

As part of our regular audit process, we obtained management’s confirmation that the findings reported in this chapter are factually based.

Objective

The audit objective was to determine whether National Defence and the Royal Canadian Mounted Police have fulfilled their responsibilities in the management of selected requirements of the 2009 Integrated Relocation Program contract in accordance with the relevant authorities and the terms and conditions of the contract.

Scope and approach

The audit included National Defence and the Royal Canadian Mounted Police (RCMP).

During the conduct of the audit, the team interviewed National Defence and RCMP officials responsible for the management of the 2009 relocation services contract. We reviewed pertinent data and documents produced by the organizations during the management of the contract and performed analysis with this information. Where sampling was used, samples were large enough to conclude on the sampled population with a confidence level of 90 percent and a margin of error of 10 percent.

For the audit scope, we examined whether the organizations completed required steps and documents in compliance with relevant authorities.

We did not audit the management practices and decisions of the contractor, nor did we audit the contractor. The audit scope did not include contracts for moving household goods.

Criteria

To determine whether National Defence and the Royal Canadian Mounted Police have fulfilled their responsibilities in the management of selected requirements of the 2009 Integrated Relocation Program contract in accordance with the relevant authorities and the terms and conditions of the contract, we used the following criteria:

Management reviewed and accepted the suitability of the criteria used in the audit.

Period covered by the audit

The audit covered the period between December 2009 and December 2013. Audit work for this chapter was completed on 15 September 2014.

Audit team

Assistant Auditor General: Jerome Berthelette
Lead Director: Casey Thomas
Director: Lori-Lee Flanagan

John McGrath
Jamie Singh

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Appendix—List of recommendations

The following is a list of recommendations found in Chapter 4. The number in front of the recommendation indicates the paragraph where it appears in the chapter. The numbers in parentheses indicate the paragraphs where the topic is discussed.

Financial and administrative controls

Performance measurement