Audit of CFIA's Staffing Framework - Audit Report
3.0 Findings and Recommendations

3.1 Design of CFIA's Staffing Framework

CFIA's staffing framework consists of, but is not limited to, the following Agency documents: Staffing Framework Policy (2013), HRB Staffing Service Delivery Model (2013) and the Recruitment and Staffing Risk Assessment (2013). HRB designed the 2013 SFP in consultation with CFIA senior management to facilitate competency- and values-driven staffing. The framework was also designed to reduce resource costs and time to staff, while maximizing the Agency's flexibility to develop and acquire modern ways to staff that would better predict how qualified candidates would perform on the job. The SFP was accompanied by a new HR business model with the identification of HR-led staffing processes, joint HR/management-led processes and manager-led staffing processes. The model also identified the assignment of Branch Strategic HR Advisors and the creation of the OSO. The introduction of the SFP included a concerted effort to promote and implement HR-led collective staffing processes.

Together these actions demonstrate management's commitment to innovation in staffing processes and assessment methodology while further utilizing the Agency's staffing flexibility as a separate employer.

Findings related to CFIA's staffing framework are presented below.

Management Controls

An effective system of management controls is a means through which management ensures that the (staffing) system is effective and is managed with due regard for economy and efficiency within the applicable laws, policies or other constraints. It includes the structures used to provide direction and to ensure that planned results are achieved, for example a staffing policy suite, the clear assignment of accountabilities, roles and responsibilities, standardized tools, and active oversight and monitoring.

Staffing Policy Suite

One of the key components of management controls is a policy instrument that provides clear and formal direction on what is expected to be achieved.

The audit examined the Agency's key staffing policy instrument, the SFP, and found that it includes the CFIA staffing values, roles and responsibilities, statutory obligations, and the requirements for specific staffing actions.

The SFP includes a clear statement on the requirement to undertake staffing processes and decisions in accordance with the Policy, the staffing values, statutory obligations and in the best interest of CFIA and its mandate. The SFP defines the seven staffing values (competency, non-partisanship, fairness, openness, representativeness, access, and efficiency and effectiveness), and states that the application of the values may differ for each staffing action to meet varied Agency objectives and business requirements. Broad guidance in support of values-based staffing is available on the CFIA intranet, for example How to Undertake Values-Based Staffing and Values in Action. However, some fundamental elements relating to accountabilities, roles and responsibilities are not included in the SFP. These areas are discussed under separate header below.

The SFP has not been updated since its implementation in 2013. Changes to things such as the length of acting appointments without solicitation requiring HR consultation, OSO inquiry procedures, and approval requirements for exemption from collective staffing processes are not reflected in the SFP.

More robust guidance, training and oversight controls would address confusion on appropriate staffing measures. By way of example, the Talent Management (TM) tool is a competency-based means to identify, evaluate, groom, reward, retain, promote and move talent through the organization based on business demands and priorities. The Agency's Policy on the Talent Management of CFIA Executives includes the allowance for talent management-based appointments for employees in the EX group only and following a roll-out of a structured and consistent assessment of all Agency executives. Notwithstanding these expectations, the audit found instances where TM was used as the basis for staffing of non-EX employees for manager-led processes.

While accountability for staffing decisions rests with the delegated hiring manager, HRB has an important role as the functional authority to provide advice to its internal clients and to protect the integrity of a values-based staffing regime. It is not clear how HRB intends to fulfil this role for manager-led staffing processes. Currently, there is no standardized mechanism or control to facilitate HRB's oversight. Such a mechanism is especially important in an environment where delegated managers are being asked to take on more responsibilities for staffing processes.

HRB has recognized the need to improve the staffing policy suite. During the course of the audit, the Branch drafted three documents to add greater clarity: a 2015 Staffing and Recruitment Framework, a 2015 Staffing and Recruitment Policy, and a 2015 Specific Staffing Guidelines. HRB should continue to update and finalize these documents to support a robust, effective staffing policy suite.

Accountabilities, Roles and Responsibilities

Another key component of effective controls is the formal identification and assignment of accountabilities, roles, and responsibilities. The SFP acknowledges that the President of the CFIA has a statutory authority to appoint the employees to the Agency and to delegate this authority within the Agency. CFIA managers and HR practitioners are accountable to the President for demonstrating that staffing is carried out in accordance with statutory obligations, established values and policies and in the best interests of the CFIA and its mandate. Interviews with HRB staff stated their mandate is to provide advice and guidance to clients. It is not clear, however, who is accountable for collecting and reporting information to ensure that staffing is carried out in accordance with statutory obligations and established values and policies.

There is also confusion regarding the OSO's responsibility for monitoring the SFP. The OSO's Terms of Reference states that the Office is in place to receive staffing concerns or complaints; it does not include the role of monitoring general compliance with the SFP. However, during interviews, some HRB staff stated that one of the responsibilities of the OSO is to monitor staffing. The assignment of a monitoring role to the OSO could blur the lines of independent and neutral body to hear and respond to staffing complaints, and a management monitoring function.

The audit noted that an opportunity exists to further strengthen the OSO's reporting structure by giving the Office formal authority to have direct access to the President while reporting administratively to the Chief Redress Officer of the Integrity and Redress Secretariat.

The policy suite is also silent with respect to defining official records relating to staffing processes and assigning the responsibility to maintain these records.

Recommendation 1.0:

The Vice-President of HRB should ensure that core management controls are in place to support the Agency's staffing framework. The staffing policy suite should be updated, and agreement should be reached on roles and responsibilities for staffing throughout, including accountability, oversight/monitoring and record keeping for staffing in CFIA.

3.2 Implementation of the Staffing Framework

Governance and Risk Management

We expected an effective governance and risk management systems to support the design and implementation of the staffing framework. The Agency Human Resources Committee, chaired by the Vice President of HRB provides strategic advice and makes decisions in regards to horizontal or corporate issues including HR policies, programs and strategies. At the operational level, there is a lack of risk-based oversight to monitor, report and adjust on the various operational aspects of the staffing framework on a timely basis. As noted in the preceding section of this report, the responsibility for monitoring has yet to be assigned. Some Areas of the Operations Branch have created staffing committees to review proposed staffing actions; however, there is no consistent practice across the Agency.

We expected to find a risk assessment for the Agency's staffing framework, including the HR Service Delivery Model, staffing processes and types of appointments. This risk assessment would include the identification of key risks, risk assessment in terms of likelihood and impact, rationale for risk assessment, and processes as well as controls in place to mitigate risks. We found that a "Risk Assessment of Change Agenda for Recruitment and Staffing" document that displayed staffing processes, types of appointments and other staffing actions on a heat map but was not supported by risk assessment methodology. Responsibilities were assigned to HRB, managers or both for each staffing process based on "risk", but there was no explanation of what the risks were and the rationale for their ranking. No further risk mitigation strategies were identified. For example, a more comprehensive risk methodology would have included an assessment of the different types of manager-led Expression of Interest processes: appointments at level versus those resulting in a promotion.

Effective risk management practices would further assist HRB with strategic priority setting for staffing, resource allocation, establishing appropriate levels of monitoring according to staffing risks, and informed management decisions.

Recommendation 2.0:

The Vice-President of HRB should implement a risk-based monitoring system to provide oversight on compliance with the Agency's staffing framework.

Staffing Planning

A key goal of HR planning is to get the right people with the right skills, experience and competencies in the right jobs at the right time and at the right costs. HR planning involves forecasting an organization's future demand for and supply of employees based on its business needs; and subsequently developing and employing the strategies required to meet these needs. It requires performing a gap analysis between current HR supply and future demand. Strategies are then developed to address the gap and may involve recruitment and staffing, training, contracting, etc.

The audit did not find branch HR plans but identified staffing plans for each branch for fiscal year 2013-14 on the Agency's intranet site. A calendar of all CFIA collective staffing processes is also posted on the intranet and updated on an ongoing basis. This calendar includes the type of position to be staffed, proposed intake strategy, proposed posting and completion dates, the status of the process and who to contact for additional information.

HR planning is important for the Agency to ensure that adequate resources are available to meet the overall strategic business objectives and operational plans. It further allows the Agency to plan, develop and implement strategies for collective staffing as well as other staffing processes/activities. It also allows HRB to better forecast and plan their work, determine what their own human and financial resource requirements are, and assign resources accordingly.

HRB is addressing the above-mentioned gaps by undertaking strategic HR planning with all branches for 2016-17. In addition, HRB Strategic HR Advisors are being trained on HR planning in order to provide greater advice and guidance to managers.

Recommendation 3.0:

The Vice-President of HRB should continue efforts to promote branch strategic HR planning as well as consolidated HR planning at the Agency level to provide insight on CFIA's overall HR needs, important skills gaps, supply and demand of essential talent, and targeted resourcing strategies.

Guidelines, Tools and Training

We expected the Agency's staffing framework to be supported by efficient, standardized and technology-enabled tools to promote compliant, efficient and effective staffing processes and to assist managers in taking on new responsibilities. We also expected that both managers and HRB staff involved in staffing would be trained.

For HR-led or joint HR/management-led staffing processes, either the BLSD Strategic HR Advisor or the HRSD Staffing Division representative is involved in the process. In such cases, HRB support is directly available to assist and guide the process according to stated requirements. However, for manager-led staffing, HR is less involved, increasing the risk exposure of not applying the staffing principles and processes as intended. Therefore, it is important that guidelines, tools and training be readily available, accessible and complete particularly for manager-led staffing.

We found that staffing training for new managers or supervisors covers the SFP, including the staffing values. We also found there is material available on the Agency's intranet site that discusses the staffing values and how they should be applied. Most hiring managers interviewed stated that they rely on their HR Advisor for staffing information and guidance. The intranet site was reported as their second most important source of staffing information; they stated that existing staffing information is confusing and difficult to find. We reviewed staffing information on the intranet site and found that it is not consolidated in one place to facilitate easy navigation and access. There is also an opportunity to increase the amount of guidance, with an emphasis on manager-led processes, to enable a self-service approach through the provision of checklists, core requirements, mandatory steps/documents, etc.

Without easily accessible information and support, managers may be vulnerable to being non-compliant with policies. There is also a risk of inefficiency in staffing as managers may spend extra time searching for information or contacting their HR Advisor more frequently than would otherwise be necessary.

During the audit, HRB presented to management a CFIA HR Paperwork Reduction Initiative with the objective of reducing staffing process paperwork in order to create efficiencies. The presentation acknowledges the need to develop guidelines and communications as a next step. We encourage HRB to ensure appropriate alignment of this initiative within the control framework for staffing. Managers as well as HRB staff need to have clarity on staffing documents to be retained, the means through which they must be accessible (i.e. electronically), their retention period and the assignment of responsibility for their retention (HRB or manager).

Recommendation 4.0:

The Vice-President of HRB should ensure that information and mechanisms are easily accessible to provide comprehensive and straight-forward guidance, including record keeping requirements, for HR practitioners and managers in applying the Agency staffing framework.

3.3 Staffing Performance Measurement Framework

An effective performance measurement framework for the Agency's staffing framework should include the identification of performance indicators and service standards (qualitative and quantitative), measurable performance data, established targets and/or timelines, costs, benchmarks, measurement, and finally, monitoring and reporting.

As per Treasury Board of Canada Secretariat Guideline on Service Standards, "service standards are integral to good client service and to effectively managing performance. They help to clarify expectations for clients and employees, drive service improvement, and contribute to results-based performance." During the audit, we found that service standards exist for maximum response times for 1-888 HR Service Centre processing of staffing transactions. With the implementation of the SFP, the President committed to 90-day service standards for completing collective staffing processes.

However, HRB does not have in place comprehensive indicators to measure achievement of the overall staffing framework, for example, comparison of actual staffing activities against branch HR plans, targets for use of distinct processes vs. collective processes, client satisfaction with the new staffing framework, etc.

The Agency tracks staffing related data in a Staffing Log that captures tombstone staffing information (i.e. type of staffing process), and permits HRB to produce statistics such as the number and type of staffing processes, appointments, etc. While HRB does track response times manually on an ad hoc basis, there is no efficient automated system to do so. The lack of an automated system increases the risk that reported data is not accurate, complete and reliable.

We expected that there would be regular reporting of staffing performance for decision-making and monitoring staffing framework performance. We did find examples of ad hoc presentations to CFIA management that included staffing related data and costs. Although HRB is externally reporting (through the Treasury Board's Management Accountability Framework and the Evaluation Measurement of the Common HR Business Process Indicators) there are limited measures directly related to staffing. There is no periodic formal internal reporting to management of performance of staffing against established performance indicators.

Effective monitoring of the staffing framework would allow for the assessment of compliance, outcomes/effectiveness, service standards, costs/efficiency, use of modern/flexible approaches and opportunities for continuous improvement. We found no evidence of formal monitoring of the staffing framework. Most HRB staff interviewed stated that if issues were to arise, they would hear about it informally or from the OSO.

Through limited benchmarking with other departments, we identified a good practice where one department conducts risk-based staffing monitoring with the extent or degree of monitoring adjusted according to the level of risk of the staffing option.

The lack of an effective performance measurement framework, including a comprehensive set of performance indicators, reliable staffing information, regular reporting and monitoring impedes the ability of the Agency to evaluate the success of the staffing framework including efficiency and effectiveness.

Recommendation 5.0:

The Vice-President of HRB should develop and implement a formal performance measurement framework (PMF) to assess how well the staffing framework is meeting its objectives. The PMF should include indicators with targets and timelines, measurable performance data, and processes for monitoring and reporting.