What if Canada had a PEFA Assessment? [Part 2]
Part 2: PI-15 to PI-28
Doug Hadden, VP Products
I suggested in my previous post, What Canada can learn from Developing Countries on Public Financial Management sustainability, [Part 5], that we could learn more about holistic public financial management. In particular, the PEFA assessment methodology. This is Part 2. [Part 1 covers PI-1 to PI-14]
PI-15. Effectiveness in collection of tax payments
(i) Collection ratio for gross tax arrears, being the percentage of tax arrears at the beginning of a fiscal year, which was collected during that fiscal year (average of the last two fiscal years).
(ii) Effectiveness of transfer of tax collections to the Treasury by the revenue administration.
(iii) Frequency of complete accounts reconciliation between tax assessments, collections, arrears records and receipts by the Treasury.
A 2006 report from the Auditor General of Canada about the Canada Revenue Agency found that as of “31 March 2005, the total amount in undisputed tax debt stood at $18 billion, of which the Agency expects to collect only about $13.3 billion—it considers the rest to be doubtful accounts and not collectible. The Agency also writes off a certain amount in uncollectible unpaid taxes every year—in 2004–05 the amount was $2.7 billion.”
It is likely that the Canada Revenue Agency has improved the following deficiencies from 2006 that related to the factors:
- Unsophisticated risk approach
- Untimely collection
- Tax debt growing faster than the rate in which taxes are paid
PI-16. Predictability in the availability of funds for commitment of expenditures
(i) Extent to which cash flows are forecast and monitored.
(ii) Reliability and horizon of periodic in-year information to MDAs on ceilings for expenditure commitment
(iii) Frequency and transparency of adjustments to budget allocations, which are decided above the level of management of MDAs.
My sense is that the federal government should be rated relatively high on these requirements. Cash is centrally managed. I expect that cash flow is well managed and that treasury functions like investments and bonds are also well managed.
Allocations are predictable except when there is an unusual circumstance like the financial crisis. Commitment information is provided from all MDAs (Ministries, Departments, Agencies). There are six month reviews.
FreeBalance developed the initial generation of products to manage budget, allotment and commitment control. Manual and computerized accounting systems did not track whether MDAs were over or under spending. Or forecasting the year-end position. The Government of Canada term to calculate the amount left to spend is the “free balance.” [budget – commitments – obligations – actuals = free balance]
PI-17. Recording and management of cash balances, debt and guarantees
(i) Quality of debt data recording and reporting
(ii) Extent of consolidation of the government’s cash balances
(iii) Systems for contracting loans and issuance of guarantees
Debt information is found budget documents. The cash position is consolidated centrally. My sense is that this is handled quite well in Canada.
PI-18. Effectiveness of payroll controls
(i) Degree of integration and reconciliation between personnel records and payroll data.
(ii) Timeliness of changes to personnel records and the payroll
(iii) Internal controls of changes to personnel records and the payroll.
(iv) Existence of payroll audits to identify control weaknesses and/or ghost workers.
Payroll is effective in the Government of Canada. There are some difficulties with the timeliness of changes to personnel records and payroll whereby one department may be paying for an employee who has transferred to another department. This is likely to change because of a new payroll system that will be implemented.
It’s unlikely that there is a ghost worker problem in Canada. There have been payroll audit such as at CIDA, but it’s probably not a major activity thanks to the reporting of expenses by public servants.
Many MDAs in Canada have strong controls on payroll budgets. Standard payroll or human resource Commercial-off-the-Shelf (COTS) software have no budget controls and are not “budget aware”. So it is possible to over or under-spend the budget. FreeBalance developed salary management software, currently in use in many federal departments to solve this problem.
FreeBalance Performance Budgeting for Human Capital (PBHC) enables MDAs to build payroll spending scenarios based on union collective agreements, payroll rules, salary scales and assumptions around training, vacancies, seasonal employment, leave accrual etc. PBHC takes the actual payroll generated from a pay period to re-forecast potential surplus or deficit situations.
Expense reporting for senior public servants is transparent in the federal government to add a further level of control.
PI-19 Transparency, competition and complaints mechanisms in procurement
(i) Transparency, comprehensiveness and competition in the legal and regulatory framework.
(ii) Use of competitive procurement methods.
(iii) Public access to complete, reliable and timely procurement information.
(iv) Existence of an independent administrative procurement complaints system.
The federal government does well in most of these factors based on our experience as a supplier. There is an open procurement system for tenders. There are mechanisms like supplier agreements that enable spend management. Advance Contract Award Notices are used to public sole-source contracts to add competitor feedback to non-competitive procurement.
There are numerous independent complaints systems depending on the nature of the procurement.
There has been some recent criticism about the Royal Canadian Air Force sole-source acquisition of F35 aircraft. My sense is that the F35 acquisition is an exception that proves the rule about procurement transparency. There is reasonable justification for the sole sourcing, although some question the acquisition of a single-engine fighter/interceptor in Canada. They key issue is whether the estimates were accurate – it was fairly open that the acquisition was planned. The Parliamentary Budget Officer first identified the estimation problem. Later, the Auditor General found that “Defence Department officials twisted government rules, withheld information from ministers and Parliament, and whitewashed cost overruns and delays afflicting the F-35 program.”
PI-20. Effectiveness of internal controls for non-salary expenditure
(i) Effectiveness of expenditure commitment controls.
(ii) Comprehensiveness, relevance and understanding of other internal control rules/ procedures.
(iii) Degree of compliance with rules for processing and recording transactions.
FreeBalance provides Government Resource Planning (GRP) software to 28 Government of Canada MDAs. The control regime is advanced to include:
- Commitment and obligation control
- Segregation of duties
- Approvals based on context such as by purchasing vehicle or amounts
PI-21. Effectiveness of internal audit
(i) Coverage and quality of the internal audit function.
(ii) Frequency and distribution of reports.
(iii) Extent of management response to internal audit findings.
According to Charles-Antoine St. Jean, the former Comptroller General of Canada, reform of internal audit in the Government of Canada has been slower than expected. Mr. St. Jean spoke at the FMI conference last month in Fredericton. He suggested that weaknesses in internal audit were to be improved in the last five years but has not met. In a previous presentation from 2007, he pointed out that the federal government introduced an internal audit policy on 2005 to “reorganize and bolster the internal audit function” and “strengthen public-sector accountability.” The intent was that “Internal auditors will fill an enhanced role” and that “Internal auditors and departmental audit committees will have more independence.” Audit training remains behind schedule.
PI-22. Timeliness and regularity of accounts reconciliation
(i) Regularity of bank reconciliations
(ii) Regularity of reconciliation and clearance of suspense accounts and advances.
My sense is that the federal government does well in reconciliation.
PI-23. Availability of information on resources received by service delivery units
Collection and processing of information to demonstrate the resources that were actually received (in cash and kind) by the most common front-line service delivery units (focus on primary schools and primary health clinics) in relation to the overall resources made available to the sector(s), irrespective of which level of government is responsible for the operation and funding of those units.
Many service delivery units at the sub-national level even though funding originates with the federal government. It is somewhat difficult based on the federal nature of government in Canada, the complexities of a developed countries and the country size to provide this information. As mentioned in Part 1, Statistics Canada attempts to overcome these constraints.
PI-24. Quality and timeliness of in-year budget reports
(i) Scope of reports in terms of coverage and compatibility with budget estimates
(ii) Timeliness of the issue of reports
(iii) Quality of information
The federal government provides quarterly reports for all MDAs. These are produced in a timely manner.
PI-25. Quality and timeliness of annual financial statements
(i) Completeness of the financial statements
(ii) Timeliness of submission of the financial statements
(iii) Accounting standards used
As above, the annual reports produced are comprehensive. The Canadian federal government is unique among G8 countries for the quality of financial statements and financial processes. As indicated recently:
For the 13th consecutive year, the Government has received an unqualified audit opinion, now referred to as an unmodified audit opinion under the new Canadian auditing standards, from the Auditor General of Canada on the financial statements.
PI-26. Scope, nature and follow-up of external audit
(i) Scope/nature of audit performed (incl. adherence to auditing standards).
(ii) Timeliness of submission of audit reports to legislature.
(iii) Evidence of follow up on audit recommendations.
The Auditor General of Canada has an international reputation for audit quality, for performance audit and for motivating changes from the audit recommendations.
PI-27. Legislative scrutiny of the annual budget law
(i) Scope of the legislature’s scrutiny.
(ii) Extent to which the legislature‟s procedures are well-established and respected.
(iii) Adequacy of time for the legislature to provide a response to budget proposals both the detailed estimates and, where applicable, for proposals on macro-fiscal aggregates earlier in the budget preparation cycle (time allowed in practice for all stages combined).
(iv) Rules for in-year amendments to the budget without ex-ante approval by the legislature.
The Westminster system in use in Canada provides incentive for party voting. Members of the government party vote for the budget to prevent the government from falling. There had been very limited scrutiny of the budget law in Canada until after the Federal Accountability Act came into force.
The 2005 IMF study suggests that there is not sufficient time provided to Parliament to evaluate the budget and with limited oversight:
In Canada, the legislature has largely been focused on optimizing the budget process, as opposed to taking an active role in the formulation of the budget…
Parliament receives the budget relatively late, less than two months before the start of the new fiscal year. A quarter of the fiscal year has typically elapsed by the time the budget is approved. In contrast, legislatures of other countries receive the budget two to six months before the new fiscal year, and even earlier in the United States…
As in many parliamentary systems, the Canadian legislature has limited powers to change the submitted budget. Parliament can reduce, but not increase, funding for line items, but has otherwise only the choice of approving or rejecting the government’s spending proposals.
The Westminster system has a notion of ‘budget confidentiality’. Budget information leaked before tabled can provide organizations with unfair advantages. Yet, this notion of confidentiality often extends past the point at which the budget is tabled. There has been significant criticism that the methods by which departments will reach spending cut targets has remained confidential.
The Government of Canada created the post of Parliamentary Budget Officer (PBO) in 2006. The post was filled in 2008. The PBO is an independent agency of the Library of Parliament lead by Kevin Page. The drivers for the creation of the PBO were:
- Unprecedented public demand for transparency and accountability across the public and private sectors
- A series of large unplanned budgetary surpluses for the Canadian government
- A number of high profile cost over-runs on major government capital projects
- New and emerging global standards and best practices to promote financial and budgetary transparency
- Successive minority governments that are changing the relationship between the government and Parliament A fundamental change has taken place in the way citizens view the government’s stewardship of taxpayer resources
Although there is asymmetrical access to information: the government through the Ministry of Finance and Treasury Board Secretariat have more information and staff, the PBO has been very effective, in my opinion, in helping parliamentarians to consider budget ramifications. “Even in a Westminster model, Parliament has the fiduciary obligation to scrutinize the planned expenditures of the government.”
PI-28. Legislative scrutiny of external audit reports
(i) Timeliness of examination of audit reports by the legislature (for reports received within the last three years).
(ii) Extent of hearings on key findings undertaken by the legislature.
(iii) Issuance of recommended actions by the legislature and implementation by the executive.