Review of the Status of the IERU Plan
The Centre for Public Management Inc. Audit Report
September 6, 2011
Ms. Suzanne Legault
Information Commissioner of Canada
Office of the Information Commissioner of Canada
112 Kent Street, 22nd floor
Ottawa, Ontario K1A 1H3
Re: Review of the Status of Management's Actions in Response to the Recommendations in the May 2009 Audit of the Intake and Early Resolution Unit (IERU)
Dear Ms. Legault:
The Centre for Public Management Inc. conducted the audit of the Complaints Resolution and Compliance Branch (CRC) on behalf of the Office of the Information Commissioner (OIC). At the request of management, during the audit, we also reviewed the status of management's actions in response to the recommendations in the May 2009 audit of the Intake and Early Resolution Unit (IERU).
We based this review on management's description of their actions, interviews with management and a review of selected documents. The purpose of this letter is to provide additional, value-added considerations that exist outside the scope of the CRC audit.
Overall, the OIC has addressed the recommendations in the IERU audit. Furthermore, several of the IERU audit recommendations relate to continuous improvement, and our review finds that management remains committed to the spirit of the recommendations by continuously making improvements in these areas. Attached are the details of our review.
On behalf of the Centre for Public Management, we extend our thanks to OIC management for their cooperation during this engagement.
Richard Palmer, Associate Partner
John Burns, Partner
Dan Kenney, Manager
Review of the status of management's actions in response to the recommendations in the May 2009 audit of the Intake and Early Resolution Unit (IERU)
IERU was introduced as a pilot project to "strengthen and streamline its complaints-handling process in order to eliminate its historical backlog of cases and to improve service to Canadians and federal institutions (IERU audit 2009)." The processes within the audit's scope included:
- Receipt of complaint, validation and registration in the Investigations System (IIA). Also included is acknowledgement of the complaint to the complainant, establishing the priority of the complaint, and assigning it to an investigation team (straightforward complaints to Early Resolution (ER) and other complaints to Complaints Resolution and Compliance (CRC);
- Summarization of the complaint in a letter which is sent to the institution requesting relevant documents;
- Preparation of complaint files (including documents received from the department) for investigators;
- Investigation of straightforward complaints by ER; and
- Approval of investigation findings, communication of results and file closing.
The Audit contained 16 recommendations based on a set of 6 "expected conditions." Recommendations are indicated by "R", e.g. recommendation 1.1 is R1.1. Management organized their action plans around these six expected conditions. The results of our review are presented below.
Detailed Results of our Review
1. Timely process to allow early resolution to be attempted at the earliest opportunity
The IERU audit attached the largest number of recommendations (5) to the first expected condition. IERU has become more successful at closing administrative cases. For example, IERU and OIC management have established average processing time targets and weekly monitoring of open files (R1.2). Process improvements such as modified intake checklists and simplified Practice Directions for complaint triaging have improved claims processing. The CRC audit found CRC staff to have a clear understanding of their roles and responsibilities. Further, monitoring of timeframes to receive documents from federal institutions occurs daily and has been in place since October 2009 (R1.3). In addition to the change in Practice Direction, the CRC audit found that a "dual risk assessment" at intake remains in place, satisfying R1.4.
Management has developed strict targets to avoid creating a new backlog. Monthly case status updates are delivered to management; weekly monitoring of targets and departmental goals also takes place across CRC (R1.1). Regular communication with staff on performance remains an ongoing priority. As well, results monitoring for continuous improvement continues to be a key priority within IERU (R1.5) and across CRC.
2. Complaints prioritized, assigned and investigated on a priority basis
As mentioned above IERU developed and implemented new business rules and practice considerations for triage nearly two years ago. OIC has simplified intake triage, set a 90 day target to complete administrative complaints, and has adopted a dual risk approach to support early complaint resolution (R2.1). New priority criteria were finalized in December 2009 (R2.2). OIC implemented a Three-Year Plan for report cards and systemic investigations. The Commissioner and members of senior management have visited federal institutions to discuss complaints handling and departmental or agency statistics vis-à-vis information requests for complaint investigations. Finally, IERU and OIC in general have more swiftly escalated priority complaints, relying at times on the formal prerogatives of the Office such as subpoenas to hasten information exchange (R2.3).
3. Adequate volume of complaints being resolved
IERU has established a "comprehensive set of business rules" for generating statistical reports for complaint processing. Monthly reports contain variance measures, backlog reduction statistics, and processing times for a variety of investigation stages. The unit of analysis was shifted in 2009 from the individual investigator to the unit as a whole. IERU staff has decreased administrative case processing time (R3.2).
Clear targets for file closures remain a priority (see discussion of R1.1 above).
4. Reporting capacity and capability that informs management about the risk of a new backlog developing and provides reliable information for decision-making including establishing service / performance standards
Reporting responsibilities have been implemented without negatively affecting claims processing, and the reporting of complaint cancellations has been addressed (R4.1 and R4.2). Data integrity remains an ongoing concern for IERU as it does for all organizations. The recent adoption of InTrac should help improve data accuracy and performance measurement (R4.3).
5. Improved ability to handle corporate information needs related to complaints
Identifying risk-based complaint information remains a priority for management. The IERU Director and Assistant Commissioner review all incoming complaints daily for relevant corporate information; lists of new complaints are compiled and sent to OIC's management group on a monthly basis. The dual risk assessment at intake helps enforce handling prioritization and due attention for priority complaints (R5.1).
Management's commitment to reducing claims processing times have come in conflict with increasingly complex cases. IERU have reduced the numbers of hand-offs, simplified triage, created a consistent framework for prioritizing complaints, adopted a dual risk assessment at intake. Yet reducing processing times for both administrative and increasingly complex refusal cases remains an on-going priority at IERU and the OIC.
6. Information that would support OIC in informing both complainants and institutions to increase efficiency in handling complaints and prevent future backlog
IERU adopted a new Practice Direction on obtaining documents in 2009. The IERU Director and the Commissioner have adopted a policy of proactive disclosure that has targeted non-compliant federal institutions, developed negotiated workarounds, and used the Office's formal powers to escalate priority cases.