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Management Action Plan – Core Control Audit of the National Energy Board

Management Action Plan
Core Control Audit of the National Energy Board

National Energy Board (NEB) Opinion of the Audit Report:

NEB has reviewed the findings and recommendations of the core control audit, and as far as the scope of the audit is concerned, they accurately reflect the state of control practices over key requirements related to the selected financial management policies, directives, and legislation.

NEB management is committed to take actions to address all findings. The implementation of action plans is the priority and the responsibility of all senior managers. As such, they will ensure that these action plans are properly implemented within the appropriate timeframe.

Audit Entity Sign Off on the Management Action Plan

Deputy Head / Chief Executive Officer
National Energy Board

The original version was signed by

_______________________________
C. Peter Watson, P.Eng., FCAE
Chair and CEO
National Energy Board

14 February 2018
_______________________________
Date

Actions to address findings

Recommendations

Priority

Response and Planned Actions

Responsibilities

Timelines

1. The NEB should ensure that:

  • Authority to approve travel is not delegated to managers below the Senior Departmental Manager level, as defined and required by the Directive on Travel, Hospitality, Conference and Event Expenditures; and,
  • All employees with delegated financial authorities receive mandatory training before they exercise their delegated authority, and that they revalidate their knowledge to maintain their delegated authorities before they continue to exercise their delegated authority.

Medium

Response:
The NEB agrees with the recommendation.

Planned Actions:

See below

See below

  • The latest update to the NEB Delegation of Spending and Financial Authorities Chart (signed by Minister on 28 November 2017) addressed this recommendation.

Director, Financial Management & Reporting

Completed

  • In 2016-17 the NEB clarified the training requirements for Director and Executive level positions. A list of these individuals are retained in Corporate Accounting. Revalidation of knowledge is required every five years. A monitoring process is in place to ensure that training has taken place prior to exercising delegation.

Director, Accounting & Procurement

Completed

2. The NEB should ensure that the organizational budget is signed by both the CFO and the Deputy Head at the start of the fiscal year.

Medium

Response:
The NEB agrees with the recommendation. The NEB has a process in place to ensure that the annual budget is approved by the appropriate authorities. The lack of documented approval in 2015-16 fiscal year was a unique occurrence.

Planned Actions:

  • The 2016-17 and 2017-18 NEB budget allocations have been signed by the CFO and CEO. Processes are in place to ensure that the 2018-19 budget allocations are signed by the CFO and CEO.

Director, Financial Management & Reporting

Completed

3. The NEB should ensure that documentation is retained on file for acquisition cards to substantiate their issuance, approval, modification, and conditions of use, as well as the acknowledgment of responsibilities by the acquisition cardholder.

Medium

Response:
The NEB agrees with the recommendation.

Planned Actions:

  • An RDIMS repository file will be set up to retain all required acquisition cardholder documentation.
  • For all current cardholders, new cardholders and any modifications to acquisition cards, we will ensure the following documentation is included in our acquisition card file (RDIMS repository file):
    • Acquisition card approval form signed by the Cost Centre Manager (CCM) with defined credit limits
    • Employee Acknowledgement of Responsibilities and Obligations form signed by employee and acquisition card coordinator
  • Process will be changed to have the CCM approve the employee cardholder restrictions such as credit limit, merchant category restrictions and daily transaction limits on a go forward basis. 
  • The acquisition card file will be reviewed quarterly to ensure required documentation is retained on file until 100% compliance is achieved and then annually thereafter.

Director Accounting & Procurement

30 June 2018

4. The NEB should ensure that a complete, documented audit trail exists for all payable expenses entered into the financial system.

Medium

Response:
The NEB agrees with the recommendation.

Planned Actions:

  • To establish additional documentation requirements to support set up of PAYE for FY2017-2018. Documentation will include certification by vendor that services have been provided or goods have been delivered to NEB.
  • To provide training on PAYE requirements through the Year-End Instruction manual and information sessions.

Director Accounting and Procurement

1 April 2018

5. The NEB should ensure that fleet log books are on file and systemically monitored, and that log data is periodically analyzed in order to track personal usage.

Medium

Response:
The NEB agrees with the recommendation.

Planned Actions:

  • A log book will be kept in the executive vehicle for the driver to track daily and personal usage.
  • Twice per year, Facilities will remove the data from the log books and record it in a spreadsheet where will monitor and analyze the data.

Director of Client Service

31 March 2019

6. The NEB should ensure that business processes are improved and consistently performed in compliance with the Treasury Board Contracting Policy and that documentation is retained on file to ensure that:

  • Non-competitive contract files contain justification for sole-source contracting in accordance with section 6 of the Government Contracts Regulations;
  • Security requirements are addressed prior to the start of work and are conducted in compliance with the provisions of the Policy on Government Security;
  • Proactive disclosures of contracts over $10,000 are posted, in the right amount, on the NEB’s website;
  • Best-value analysis is performed prior to contract award;
  • Appropriate procurement vehicles are chosen and used in compliance with their terms and conditions;
  • The bid selection method and evaluation criteria are clearly outlined in the bid solicitation document for competitive contracts before the request for proposal is issued;
  • Statements of work are developed and documented prior to the bid solicitation;
  • Bid-evaluation reports are developed, on file, and signed by all evaluators;
  • Contracts and amendments are issued before the goods and services are received;
  • Contract amendments are properly justified and substantiated; and
  • Contract amendments are issued before contract expiry dates.

High

Response:
The NEB agrees with the recommendation.

Planned Actions:

Director Accounting & Procurement

See below

  • Processes were improved in 2016-17. Contract approval forms now include a sole source justification appendix.

Completed

  • Processes were improved in 2016-17. Contract approval forms now include a link to the Security Requirements checklist.

Completed

  • As of April 2017, proactive disclosures are posted on Open Government and not the NEB website. Process includes a verification of data integrity by Procurement Services Group Leader.

Completed

  • Best Value analysis currently is being done on contracts over $25K. Guidelines, including criteria for Best Value determination will be clarified for contracts under $25K and put in place in 2018. The NEB will ensure that supporting documentation of compliance with the criteria will be kept on file.

30 September 2018

  • Additional training will be provided to Contract Officers in 2018 to address the remaining recommendations
  • A thorough update to current procurement guidelines and procedures will be performed to address the remaining recommendations.

30 September 2018

Overall Actions:

  • NEB Clients will receive Procurement Basics 101 Training.
  • Monitoring of Procurement activities will be put in place. A pre solicitation and post contract review process will be implemented in 2018 as per the Procurement Services Process Guide – Review of Solicitation and Contracting Files.

31 March 2019

7. The NEB should ensure that business processes are improved and are consistently performed in compliance with the National Joint Council Travel Directive, and that sufficient documentation is retained on file to ensure that:

  • Employees are reimbursed for meals and incidentals within the limits prescribed by the Travel Directive;
  • Accommodations are selected from the Government Accommodation Directory and within the city rate limit, and sufficient justification is kept on file when the hotel is not included in the Directory or when the identified limit is exceeded; and,
  • Rental vehicles are properly documented and respect the appropriate limits.

High

Response:
The NEB agrees with the recommendation.

Planned Actions:

  • NEB guide for compliance with Directive will be developed and published on the process dashboard in 2018 to clarify expenditure processes and required documentation.
  • Training will be provided to CCMs and administrative staff to reinforce compliance with processes and to ensure that appropriate documented justification is kept on file.

Director Accounting & Procurement

30 September 2018

8. The NEB should ensure that business processes are improved and are consistently performed in compliance with the Treasury Board Directive on Travel, Hospitality, Conference and Event Expenditures, and that sufficient documentation is retained on file to ensure that:

  • The most efficient and economical alternatives for hospitality expenditures have been considered; and,
  • Hospitality expenses for designated senior-level employees are proactively disclosed on the departmental website.

High

Response:
The NEB agrees with the recommendation.

Planned Actions:

  • NEB guide for compliance with Directive will be developed and published on the process dashboard in 2018 to clarify expenditure processes and required documentation.
  • Training will be provided to CCMs and administrative staff to reinforce compliance with processes and to ensure that appropriate documented justification is kept on file.
  • Disclosure of expenses will include a verification process of data integrity by Corporate Accounting Group Leader.

Director Accounting & Procurement

30 September 2018

9. The NEB should ensure that result-based measurement mechanisms are established and monitored regularly for accounts receivable.

Low

Response:
The NEB agrees with the recommendation.

Planned Actions:

A results based measurement mechanism (Accounts Receivable recovery rate) will be established and monitored quarterly by the Deputy Chief Financial Officer.

Director, Financial Management & Reporting

31 March 2018

10. The NEB should ensure that:

  • Funds commitment availability is certified, signed, and dated by an individual with the appropriate delegated authority prior to the expenditure initiation, and that documentation is retained on file to demonstrate that this had occurred;
  • Expenditure initiation is performed prior to the event; and,
  • Commitments are established and entered into the financial system in a timely manner, at the value expected to be incurred.

High

Response:
The NEB agrees with the recommendation.

Planned Actions:

See below

See below

  • For pre-approval of overtime a process will be developed, implemented and communicated that clarifies requirements.

Director, Financial Management & Reporting

30 June 2018

  • For pay administration actions the salary on appointment form will be used as the commitment authority and the Delegation of Spending and Financial Authorities chart will be amended accordingly.

Director, Financial Management & Reporting

30 June 2018

  • For all other expenditures a monitoring process will be implemented to identify exceptions with reporting to CFO. The first report will be prepared on 30 September 2018 and will be done on a quarterly basis thereafter.

Director Accounting & Procurement

30 September 2018

11. The NEB should ensure that:

  • Account verification (Section 34) is documented, duly signed, and dated in a timely manner by the appropriate delegated authority; and,
  • Account verification is supported by sufficient evidence to demonstrate that goods and services had in fact been received.

High

Response:
The NEB agrees with the recommendation.

Planned Actions:

See below

See below

  • For approval of overtime a process will be developed, implemented and communicated that clarifies requirements.

Director, Financial Management & Reporting

30 June 2018

  • For pay administration actions the Delegation of Spending and Financial Authorities chart will be amended so that the appropriate delegated authority is approving the pay administration action.

Director, Financial Management & Reporting

30 June 2018

  • For all other expenditures a monitoring process will be implemented to identify exceptions with reporting to CFO. The first report will be prepared on 30 September 2018 and will be done on a quarterly basis thereafter.

Director Accounting & Procurement

30 September 2018

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