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Management Response and Action Plan (MRAP) - First Nations and Inuit Health Branch - Audit of the Recipient Audit Function

September 2009

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Recommendations Management Response:
(1) Accept
(2) Accept with conditions
(3) Reject
Planned Management Actions Deliverables Expected Completion Date Accountability
1. It is recommended that the Assistant Deputy Minister of the First Nations and Inuit Health Branch (FNIHB) ensure that guidelines are developed and implemented to ensure that decisions to postpone recipient audits are adequately supported, approved by the Branch Executive Subcommittee on Audit, Evaluation and Review and followed. Accept FNIHB has implemented new guidelines and a change request form for the 2009-2010 FNIHB Risk-Based Audit Plan in order to ensure that any requests for changes or postponements of recipient audits are adequately supported, approved by the Branch Executive Subcommittee on Audit, Evaluation and Review, and followed. Guidelines for changes to the approved Audit Plan as well as a Change Request Form Completed Business Planning and Management Directorate (BPMD)
2. It is recommended that the Assistant Deputy Minister of the First Nations and Inuit Health Branch ensure that the Branch Ministerial Audit Guide is updated to provide guidance for completion of recipient audits, including clarity and appropriateness of objectives and related criteria. Accept The FNIHB Ministerial Audit Guide is currently being updated to provide additional guidance for completion of recipient audits, including clarity of objectives and related criteria. Updated FNIHB Ministerial Audit Guide March 2010 BPMD
3. It is recommended that the Assistant Deputy Minister of the First Nations and Inuit Health Branch ensure that the Branch Ministerial Audit Guide is updated to require the issuance of an opinion statement related to financial information in all recipient audit reports and that these statements be included in all reports tabled at FNIHB's Audit, Evaluation and Review Committee. Accept FNIHB will update the Ministerial Audit Guide to require the issuance of an opinion statement related to financial information in all recipient audit reports, and these statements will be included in all reports tabled at the FNIHB Audit, Evaluation and Review Committee. Updated FNIHB Ministerial Audit Guide March 2010 BPMD
4. It is recommended that the Assistant Deputy Minister of the First Nations and Inuit Health Branch ensure that audit programs are obtained from auditors, in order to review them as part of the Branch's quality assurance process for the purpose of confirming compliance with its Ministerial Audit Guide. Accept FNIHB will include the requirement in the Ministerial Audit Guide for auditors to include audit programs in order to review them as part of the FNIHB quality control for the review of audit reports. Updated FNIHB Ministerial Audit Guide and Updated FNIHB Ministerial Contribution Audit Procedures March 2010 BPMD
5. It is recommended that the Assistant Deputy Minister of the First Nations and Inuit Health Branch ensure that BPMD improves its oversight process over audit responses. This would include improvements to the processes and criteria for determining appropriate changes to Audit Action Plans, including the review and approval of responses to recommendations for sufficiency of documentation, and, reasonability of regional and program decisions related to reducing recoverable amounts. Accept FNIHB will enhance the existing process to improve audit responses by working with the regions/programs to better understand the issues they face in negotiating with the recipients.  FNIHB and the region/programs will develop guidelines to improve documentation of management responses to recommendations and improved justification for the acceptance of expenditures that were adjusted by the auditor. Guidelines for Determining Responses to Audit Recommendations and Recoverables March 2010 BPMD
6. It is recommended that the Assistant Deputy Minister of the First Nations and Inuit Health Branch ensure the enforcement of timelines for the development of Audit Action Plans and Summaries of Actions. Accept FNIHB will undertake a study with regions/programs in order to determine more reasonable timelines and establish procedures to justify extensions for complex files. Following the study, FNIHB will recommend new timelines and enforcement procedures to BEC-AER for approval.

The existing timelines of 45 days for the completion of the audit action plans following release of the draft audit report to the region/program, frequently does not provide adequate time to discuss the report with the recipient, to develop a mutually acceptable audit action plan and recovery plan (if warranted), and to get the approval of regional/program management.

For files that exceed the revised timelines, regions/programs will be required to provide justification for the extension of timelines, which will be presented to BEC AER on a quarterly basis.
Study to determine realistic and enforceable timelines March 2010 BPMD
Guidelines for audit response timelines and enforcement procedures June 2010 BPMD