3.1 Management Control Framework
A management control framework is made up of key management controls that are reasonably expected to be in place in any department or agency to enable the achievement of objectives. Management controls are practices and procedures established to create business value and minimize risk. They include policies, procedures, business processes, roles and responsibilities, objectives and/or performance measures, monitoring and reporting.
An effective system of internal control is integral to an organization’s ability to manage risks and to achieve objectives related to operational effectiveness, reliable reporting and compliance. Controls contribute to the proactive and intelligent management of risk, which, if left unmanaged, can prevent key performance objectives in these areas from being achieved. When the organization’s system of internal control is effective, losses are minimized and performance is optimized.
It is important to note that the organization’s control framework does not guarantee that risks will be prevented, detected and managed, nor that the organization will achieve its goals. It does, however, greatly increase the likelihood that organizational objectives will be achievedFootnote 7. Management controls also support compliance with applicable legislation, policies, and guidelines.
3.1.1 Roles and Responsibilities
Why it’s important
At the outset of the audit, the audit team expected to find that roles and responsibilities, key deliverables, resources, and timelines were clearly defined in an integrated framework supporting overall planning and delivery. Defined roles and responsibilities provides clarity, alignment, and expectations to those executing the work and delivering services and benefits. When roles and responsibilities are clearly defined, team members look beyond their own individual positions and learn to understand, respect, and value the unique contributions of one another, and they recognize that the overall success of the team is a function of shared responsibility and ownership.
What we found
Veteran Benefit Team:
- The VBT consists of Disability Services Assistants, Benefits Program Officers, and Disability Adjudicators. Roles and responsibilities for all members of the VBT were clearly defined and communicated.
Benefits Adjudication and Processing Unit:
- This team consists of Benefits Program Officers and Payment Officers. While employees indicated that roles and responsibilities were understood, there was no official documentation that identified clear individual roles and responsibilities.
Area offices:
- This team consists of Case Managers and Veterans Service Agents. Roles and responsibilities related to the condolence letter and benefit information letter were clearly defined and communicated in the related business process.
What is the effect/impact?
When roles and responsibilities are not clearly defined and communicated, there may be a risk of duplication of effort; confusion, disappointment, and frustration; which may negatively impact productivity.
3.1.2 Monitoring and Reporting
Why it’s important
Effective planning and risk management are supported by sound monitoring and reporting tools and processes. Monitoring is the process of systematically tracking key indicators to assess progress made in achieving goals and objectives. Ongoing monitoring also assists with decision-making and risk management.
Quality assurance comprises administrative and procedural activities implemented in a quality system so that requirements and goals for a service or activity will be fulfilled. It focuses on improving work processes so that services and benefits are delivered more efficiently by tracking key indicators to assess progress made in achieving goals and objectives. Workload management allows for efficient distribution and management of work across teams. When successfully done, team members will feel confident about their work volume and maximize performance.
Disability benefit for survivors workload is primarily generated by applications for disability benefits for survivors. Work is directed by work items generated in Client Service Delivery Network (CSDN) or emails created by staff. Tracking work items measure the time elapsed between steps. Since April 2019, VAC has a new system of record called GCCase, however this system does not yet include disability benefits for survivors.
What we found
Veteran Benefit Team:
- There was a lack of performance monitoring and quality assurance/review of
workload related to disability benefit for Survivors. Reporting data was limited to CSDN. GCCase was launched in April, 2019 and to date, the functionality to generate reports which would provide for high level fulsome reviews of performance has not been implemented. Since staff used both systems to complete work, detailed workload reporting was inaccurate and monitoring was ineffective.
Benefits Adjudication and Processing Unit:
- Workload performance was monitored and feedback was provided during the periodic performance review process. Staff’s performance appraisals included workload goals and expectations and discussions were held verbally on their results.
Area offices:
- Interviews indicated that there was no monitoring or quality assurance/review of workload related to the condolence letter and benefit information letter.
What is the effect/impact?
Inadequate or nonexistent quality assurance may create risks in quality, noncompliance and delays in service delivery, that may otherwise not be detected. Without workload management in place to distribute work and promote balance, the feeling of overwork among staff increases and contributes to low morale and/or stress/burnout.
3.2 Compliance with Applicable Policies and Processes
Why it’s important
Documented business processes serve as a means for the direction of actions and/or activities into a defined and consistent process which creates structure, supports timely decision-making and promotes compliance with policies. Without documented and formalized procedures, there is increased risk of error in processing disability benefits for Survivors, particularly for new staff.
Having a trained workforce creates an overall knowledgeable staff who can perform their duties independently. Without adequate, complete and current business processes and training, there is an increased likelihood of non-compliance and confusion related to roles and responsibilities.
What we found
Veteran Benefit Team:
- Staff relied on outdated reference material, that did not reflect the current organizational structure and lacked an overarching framework or business process to provide direction. Additionally, existing business processes provided high level instructions however, did not provide the level of detail that would ensure staff properly/consistently performed required duties.
- There was no formal training related to disability benefits for survivors. Staff relied on co-workers to obtain guidance.
Benefits Adjudication and Processing Unit:
- There was no official business processes or guidance on how to process disability benefits for survivors.
- There was no formal training related to disability benefits for survivors. Staff relied on co-workers to obtain guidance.
- A review of a random sample of 235 Survivor files indicated that decisions were appropriate, fully documented and supported in 99.6% of the cases (234/235).
Area offices:
- The existing business process for preparing and sending the BIL did not provide sufficient level of detail to properly perform/conduct their responsibilities.
- While standardized letter templates for CL and BIL ensured consistency by limiting the information it contained to a selection of optional paragraphs, the lack of flexibility may have created risks of misinformation in certain scenarios.
- Training provided on the process for creating and sending the BIL did not provide sufficient guidance to support staff in determining potential eligibility to the various VAC benefits and services.
- A review of a random sample of 181 Survivor files indicate that CLs were sent in 96% of the cases (173 of 181). Of the CLs that were sent, only 55% (95 of 173) were sent within 2 working days.
- Of the 181 Survivor files reviewed, only 60% (104 of 181) of BILs were sent. Of the 104 BILs that were sent, only 43% (45 of 104) were sent within 5 working days of notification of death.
What is the potential effect/impact?
Due to the lack of clear business processes for the VBT and BAPU, the audit team was unable to assess compliance with applicable business processes. Identified gaps in business processes, letter templates and training as outlined above may have contributed to lack of compliance in regards to the condolence and benefit information letter process. Delay or failure in sending a CL and BIL to a vulnerable population may result in reputational loss for the Department. Failure to send a benefit information letter may also increase the risk of delays in Survivors applying for and/or being informed of VAC’s disability benefits and support services.
3.3 Audit Recommendations
Recommendation 1
It is recommended that the Assistant Deputy Minister, Service Delivery improve the management control framework related to the processing of disability benefits for Survivors by:
- clearly defining roles and responsibilities; and
- developing and implementing comprehensive business processes and guidance.
Management Response
The Service Delivery Branch of Veterans Affairs Canada will review and update the roles and responsibilities for employees involved with processing disability benefits for survivors. There will also be development and implementation of a comprehensive business process for the same. The Centralized Operations Division’s Training and Development team will create online curriculum that provides end-to-end guidance on the survivor process for Veteran Benefits Teams and Benefits Adjudication and Processing. To further support guidance, we will also update the disability benefits survivor chapter in the Adjudication Manual and post it on the VS Toolbox.
Target Date: September 30, 2022.
Recommendation 2
It is recommended that the Assistant Deputy Minister, Service Delivery implement a performance monitoring and a quality assurance program related to the processing of disability benefits for Survivors.
Management Response
The Service Delivery Branch of Veterans Affairs Canada will implement a performance monitoring and quality assurance program related to the processing of disability benefits for survivors.
Target Date: July 31, 2022.
3.4 Audit Opinion
Based on the findings above, the audit team determined that the processing of disability benefits for survivors requires improvement. Although staff generally understood their roles and responsibilities, several opportunities for improvements were noted with respect to business processes, performance monitoring and quality assurance.