Disclosure of wrongdoing under the Public Servants Disclosure Protection Act (PSDPA) 2009-2010
Description of Wrongdoing:
A disclosure of wrongdoing under the PSDPA was received by the RCMP Senior Officer in 2008. Upon examination there were seven allegations of potential wrongdoing identified. An extensive PSDPA investigation was conducted and it was determined that one allegation was founded. It was established that a senior manager of the RCMP had exceeded their financial authority with regard to an Information Management / Information Technology project. The employee is no longer with the organization.
Recommendations set out in any report made to the Chief Executive and corrective action taken in relation to the wrongdoing:
That the RCMP continue to implement and sustain the new project management regime which has been initiated. This new framework and capacity in the RCMP have provided the Force, via Treasury Board approval, with significant project approval authorities to effectively and expeditiously deal with projects and initiatives that are often unique to the RCMP's operational requirements.
All major projects undertaken at a regional or national level, should include clearly stated deliverables and timelines, with a dedicated project management office responsible to ensure appropriate financial tracking, scheduling, risk management and reporting. This is in compliance with the new project management framework.
The RCMP has made much progress and undertaken a number of initiatives that have transformed, strengthened and modernized its governance framework. Central to this, is the RCMP's on-going development and implementation of a more robust Project Management / Project Delivery regime. This regime is intended to deliver a number of benefits, including heightened tracking, scheduling, risk management, reporting, clearer delineation of roles and responsibilities at the project manager/account manager level and better alignment of regional/ headquarters participation. In addition, it is expected that the framework will result in a reduction of administrative irregularities. RCMP has demonstrated that it is strongly committed to continuing this implementation.
In 2009, Treasury Board approved the RCMP Investment Plan. This Plan outlines governance and decision making processes in addition to the priorities for real property, moveable assets, Information Management / Information Technology (IM/IT) projects and major acquired services. The RCMP Chief Information Officer (CIO) sector is continuing to develop a strategic governance framework to support sound IM/IT investment planning as defined by new Treasury Board policies on Investment Planning and Project Management.
That discussions continue with Treasury Board, under the Reform Implementation initiatives, to enable financial approval processes and financial delegation levels to be more responsive to the demands placed on Commanding Officers in contract policing jurisdictions.
The RCMP has been successful in securing increased financial authorities through its active participation in the Treasury Board investment planning process. This has resulted in significantly increased authority from Treasury Board to purchase, lease, build, and sell RCMP assets, and to contract for construction.
- Construction contracting authority increased from $2M to $10M
- Purchase of Real Property authority increased from $350K to $12M
- Leases from the private sector authority increased from an annual limit of $150K to $2M
The RCMP can now approve over 95% of our projects internally for IT, real property and fleet (vehicles). Only highly complex and risky projects will continue to require Treasury Board approval.
This success will afford the RCMP greater flexibility, responsiveness to priorities, and control over projects that provide the infrastructure and services supporting front line operations. This is a major achievement supported by the RCMP's demonstrated strengths in real property, procurement, and project management.
The RCMP is also finalizing negotiations with Public Works and Government Services Canada for increased delegated authority for procurement of all goods and commodities. This increased delegation will provide the RCMP with much needed flexibility to respond to operational requirements in a timely manner while continuing to demonstrate due diligence and accountability in all our procurements.
Over the next year, RCMP will continue to press for increased authorities that will provide the greatest benefit to core business activities.
That a communication strategy be implemented by Contract and Aboriginal Policing to ensure that contracting partners at the provincial or municipal level are aware that RCMP managers and executives are required to comply with Treasury Board guidelines when carrying out their responsibilities under the various Police Service Agreements.
The RCMP is satisfied that contracting partners at all levels have a clear understanding of the RCMP's requirement to comply with federal guidelines and Treasury Board directives when carrying out their responsibilities under the various police services agreements.
The RCMP demonstrates accountability and transparency to all contracting jurisdictions by addressing the responsibilities of financial planning, costs and expenditures in the articles contained in the various police service agreements such as Provincial Police Service Agreements (PPSA) and Municipal Police Service Agreements. Police Service Agreements, established through extensive consultation between RCMP representatives and federal, provincial, territorial and municipal officials, assist the RCMP and contracting partners in ensuring that resources and services are managed competently to achieve maximum cost-effectiveness. Once signed, a copy of the police service agreement is provided to each signatory and is accessible on the Public Safety Canada external website.
Article 11.1 b PPSA states: "Canada, in procuring such equipment, shall do so in accordance with its own procurement practices and procedures, directives of the Treasury Board of Canada and the Government Contract Regulations."
Where a number of policy centers are involved in providing support for a regional or national initiative, a committee approach to establishing priorities and action plans should be implemented. It is essential that a clarity of roles and responsibilities be reached between regional and national headquarters.
Specific to information management, in 2008, the Chief Information Officer Strategic Review Council was created to provide IM/IT program governance and initiative priority setting based on the overall organizational priorities of the RCMP. The council is comprised of Assistant Commissioner level participants from all RCMP program areas and the regions to ensure strategic decisions and investment decisions are based on a committee approach.
CIO Sector Review Council decisions will be reflected in the RCMP Investment Plan and resources will be allocated according to the RCMP's needs, supported by an overall funding strategy including investment options to identify sources of funding available in the five-year planning period. Unfunded IT initiatives will be included in the investment plan only when an appropriate funding strategy has been identified.
The Senior Executive Committee (SEC) has approved the design and implementation of a structured, tiered policy committee process for the RCMP. The new process will establish three linked policy committees: the Policy Working Group (PWG), the Senior Policy Committee (SPC); and the SEC which will have every second meeting dedicated to policy items.
The policy committee process is intended to: provide the RCMP with a more clearly defined organizational structure and process to support policy development and decision-making, and enable consideration of a broader array of relevant interests and concerns across the RCMP. This should result in more consistent and better articulated policy that is more closely aligned with the priorities of the RCMP and those of the Government of Canada.
Achievement of these objectives should produce the following benefits for the RCMP:
- policies that adequately address the considerations of all affected program areas, Divisions and Regions;
- reduced risk of the RCMP taking on new service delivery commitments without adequate resources;
- increased opportunities to obtain new and/or additional resources for the RCMP;
- more consistent implementation and communication of policy decisions; and,
- senior management that is better prepared to promote the RCMP's interests and priorities with Central Agencies.
In designing both the proposal and the terms of reference (TORs) for the committees, the Strategic Policy Unit pursued extensive internal and external consultations. Particular care was taken to align the new process with: the RCMP's policy needs and concerns; views of business and service lines; the RCMP's organizational structures and processes; and the mandates of existing committees. The Strategic Policy unit will conduct a review of the TORs after the policy committees have been functioning for approximately six months to determine if they are functioning optimally and will recommend any necessary changes for consideration of the policy committees.
The proposal to create the policy committee process was constructed by reviewing the policy development processes of other agencies of the federal government, and adapting best practices to the needs and realities of the RCMP. The key findings from the review of other federal agencies is that policy development processes can be strengthened through the adoption of linked policy committees that engage working level and mid-level and senior-level management for all significant policy items. Such committees enable the application of the integration and challenge functions, which results in the production of higher-quality policy items and the reduced likelihood of significant errors and omissions.
Each project manager and accountability manager should receive training in relation to the level and limits of their financial authorities, as well as the related Treasury Board reporting and contract / procurement guidelines.
Since the events occurred, the Federal Government has instituted a new program requiring all managers with financial signing authority to attend a Canada School of the Public Service delegation of authorities training course and complete an examination. The training includes authorities and policies on financial, human resources, information technology and other management functions including project authorities. The program has been implemented across the RCMP, and managers are only delegated financial signing authorities upon completion of the mandatory training.
The RCMP should consider adopting a further program to provide periodic refresher authorities training to managers with course material and examples reflecting situations that managers would be more likely to face in their role as an RCMP manager.
The RCMP has made significant efforts and progress in internal authorities training. At the national level, corporate responsibility training is delivered twice yearly to newly commissioned officers and officer equivalents at the Officer Orientation and Development Course. This example, discussion, and scenario-based course covers all corporate aspects, including authorities, and is focused on supporting participants in fulfilling the role of an officer in the RCMP. National Policy Centres also develop self-learning tools and provide training on demand or on identified need; for example, a monthly course called Delegation of Financial Authorities which is open to all. Training and tools are also developed for targeted groups; for example, to regional procurement officers or employees exercising sec. 33 of the Financial Administration Act, when authorities are granted or upon program or policy changes.
Additionally, RCMP Regional Corporate Management Offices provide bi-annual to annual training sessions to detachment and unit commanders, and detachment and unit administrators. This training is typically offered over two or three days, covers all aspects of corporate authorities, and is focused on the real worldof managing or administering a unit or detachment. For example, Northwest Region's Corporate Responsibilities Workshop gives an overview on exercising delegated authorities, then covers each aspect including financial, procurement, and hospitality, and provides detailed instructions on documentation, approvals, contact, and forms. Each region has also produced a Reference Guide to corporate responsibilities, including authorities, to guide managers in exercising their authorities.
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