Final Report

Corporate Audit and Evaluation Branch
January 2011

Table of Contents

Executive Summary

1. Introduction
2. Purpose of the Evaluation
3. Evaluation Context
4. Methodology
5. Findings
   • 5.1 Relevance
   • 5.2 Program Design and Delivery
   • 5.3 Achievement of Expected Results
6. Conclusion
7. Recommendations
8. Management Response

• Appendix A: Glossary of Terms
• Appendix B: Registered Charity versus Non-profit organization
• Appendix C: Contribution Recipients and Projects
• Appendix D: Map of Contribution Recipients

Executive Summary

Introduction

The subject of this evaluation is the Charities Partnership and Outreach Program (CPOP) which is administered and managed by the Client Interface and Services Division (CISD), Charities Directorate, Legislative Policy and Regulatory Affairs Branch (LPRAB). The overall objective of CPOP is to increase compliance and build a responsive charitable sector. The main objectives of the program are to: (1) raise awareness among the sector of regulatory obligations under the Income Tax Act (ITA); (2) increase the capacity of the charitable sector in meeting regulatory compliance requirements in a sustainable fashion; and (3) improve the capacity of the sector to develop and deliver sustainable compliance-based education programs.

CPOP provides funding, in the form of contribution payments, to eligible registered charities and non-profit organizations serving the charitable sector. In March 2005, Treasury Board Secretariat approved the terms and conditions for CPOP and released funding of $1 million in 2005‑2006, $1 million in 2006‑2007, $2 million in 2007-2008 and $3 million in subsequent years to the Canada Revenue Agency. The recipients of the contribution funding are responsible for developing and delivering training and education to registered charities on how to comply with the ITA. Currently, 2.5 full-time equivalents (FTEs), consisting of 2 program officers (SP-08) and .5 of a manager (MG‑05) are allocated to the program. Program costs for 2010-2011 are projected to be approximately $196,000 in salaries and $11,700 in operating and maintenance costs.

Purpose

The evaluation was conducted to assess the extent to which the CPOP has achieved its expected results. The following issues were examined:

1. Is the program still relevant?
2. Is the design and delivery model the most effective way to achieve the objectives of the program?
3. To what extent has the program achieved expected results?

Methodology

A range of data collection and analysis methodologies were used in the conduct of this evaluation. These included: internal and external interviews; document, literature and file reviews; data analysis; a survey of 500 registered charities; and a high-level review of foreign charity/tax administrations.

Conclusion

Ensuring the integrity of the charitable sector is important not only because of the tax benefits associated with being or contributing to a registered charity but because of the larger role the sector plays in the day to day lives of Canadians. The CPOP's objective of raising awareness of the charitable sector and of the regulatory obligations under the ITA is clearly aligned with the Charities Directorate's mission "to promote compliance with the income tax legislation and regulations relating to charities through education… thereby contributing to the integrity of the charitable sector and the social well-being of Canadians."

There is a variety of data which suggests that, although compliance by registered charities has improved over the past several years, there is still an ongoing need for assistance to registered charities in understanding the requirements of the ITA. The majority of representatives from the voluntary sector strongly felt that the CPOP was meeting a need by making a variety of resources available to assist registered charities. The feedback data collected by contribution recipients from participants and/or users of the training and education has been overwhelmingly positive.

The CPOP has made progress, particularly in terms of the number of contribution projects that have been developed and delivered on compliance-based training and education, since the formative evaluation report was approved by the Agency Management Committee in April 2008. Although there are gaps in operating procedures, these deficiencies can be overcome especially in light of what has been learned by the program over the past several years. However, there are still considerable gaps in performance measurement, which may, in part, be due to program objectives not being well-defined and, not easily measured.

Additionally, the terms and conditions for this program require clarification in order to ensure that they are implemented in a manner that is well understood by all stakeholders. The CPOP is also not aligned with an overall Charities Directorate outreach strategy. The need to renew the terms and conditions in March 2011 provides an excellent opportunity for the Charities Directorate to reassess the program and determine how it aligns with the strategic direction of the Charities Directorate.

Recommendations

Based on the findings of this evaluation, program management should:

• in light of the program experience over the last five years and the findings of this evaluation, review the terms and conditions including the current objectives to ensure that they are more realistic and measurable;
• Once the terms and conditions and objectives are clarified, focus on developing and implementing a performance measurement strategy;
• Ensure that the CPOP is aligned with an outreach strategy for the Charities Directorate; and
• Continue to make improvements to internal operating procedures and guidance for program participants.

1. Introduction

The subject of this evaluation is the Charities Partnership and Outreach Program (CPOP) which is administered and managed by the Client Interface and Services Division (CISD), Charities Directorate, Legislative Policy and Regulatory Affairs Branch (LPRAB). The overall objective of CPOP is to increase compliance and build a responsive charitable sector. The main objectives of the program are to:

• Raise awareness among the sector of regulatory obligations under the Income Tax Act (ITA);
• Increase the capacity of the charitable sector in meeting regulatory compliance requirements in a sustainable fashion; and
• Improve the capacity of the sector to develop and deliver sustainable compliance-based education programs.

CPOP provides funding, in the form of contribution payments, to eligible registered charities and non-profit organizations serving the charitable sector. Refer to Appendix B for an overview of the differences between a registered charity and a non-profit organization. In March 2005, Treasury Board Secretariat approved the terms and conditions for CPOP and released funding of $1 million in 2005‑2006, $1 million in 2006‑2007, $2 million in 2007-2008 and $3 million in subsequent years to the Canada Revenue Agency (CRA). The recipients of the contribution funding are responsible for developing and delivering training and education to registered charities on how to comply with the ITA. Priorities for funding are established on an annual basis. To be eligible for funding, projects must be linked to at least one of the CPOP's objectives and to one of the funding priorities. The CISD solicits funding submissions through a national call for applications. All applications are assessed and selected by the CISD with the assistance of an Application Review Committee (ARC).

Currently, 2.5 full-time equivalents (FTEs), consisting of 2 program officers (SP-08) and .5 of a manager (MG‑05) are allocated to the program. Program costs for 2010-2011 are projected to be approximately $196,000 in salaries and $11,700 in operating and maintenance costs.

2. Purpose of the Evaluation

The purpose of the evaluation was to provide an evidence-based assessment to senior management on the extent to which the CPOP has achieved its expected results. The following issues were examined as part of the evaluation:

• Is the program still relevant?
• Is the design and delivery model the most effective way to achieve the objectives of the program?
• To what extent has the program achieved expected results?

The evaluation framework was approved by the Management Audit and Evaluation Committee in January 2010. The timeframe covered by this evaluation was October 2007 to October 2010.

3. Evaluation Context

In February 2005, the Charities Directorate committed to the Treasury Board Secretariat to conduct a formative and summative evaluation of CPOP before its terms and conditions expired in March 2010. In December 2009, the Commissioner requested that the Minister of National Revenue extend the terms and conditions for one year to allow for more contribution agreements to be put in place and additional data to be gathered in support of the summative evaluation.

The Corporate Audit and Evaluation Branch initiated a formative evaluation of the CPOP in February 2007 to provide information and advice to senior management on whether the program was well positioned to meet its objectives. The formative evaluation focused on program relevance; program design, implementation and delivery; and possible program modifications. The timeframe covered by the formative evaluation was from March 31, 2004, to September 30, 2007. The formative evaluation report, approved by the Agency Management Committee in April 2008, made the following recommendations:

• Revisit the original program design to reassess the feasibility of implementing the program in terms of what was planned as detailed in the Treasury Board Submission that was used to obtain funding for this program;
• Focus on developing and implementing a performance measurement strategy that will identify the baseline data that is required to measure performance and report on the success of this program;
• Develop and implement a communication strategy that clearly identifies the steps that will be taken, both in terms of collaboration and promotion, to help achieve the program objectives; and
• Implement the policies, procedures and information system(s) necessary to ensure that quality information is available to support decision-making, the measurement of performance as well as accountability and transparency of the program.

4. Methodology

The following data collection and analysis methodologies were used in the conduct of this evaluation:

• Interviews (internal to the CRA) – 20 interviews were carried out with 21 representatives of the Charities Directorate, Public Affairs Branch, Finance and Administration Branch, and Training and Learning Directorate of the Human Resources Branch.
• Interviews (external to the CRA) – interviews were carried out with 48 representatives from the voluntary sector in Canada (the majority of which were applicants and contribution recipients), 7 representatives of other federal and provincial government organizations, and 3 representatives of foreign charity and/or tax administrations.
• Document and File Review – A review of files and documentation associated with the administration and management of the program was conducted.
• Literature Review – A review of literature related to registered charities, non-profit organizations, the voluntary sector in Canada and other countries, grant and contribution programs, and various types of training – including the use of social media – was also conducted.
• Data Analysis – Program data was analyzed to assess the extent to which registered charities are non-compliant with the ITA and information reported on the Registered Charity Information Return (T3010) is accurate and complete.
• Survey – A survey of 500 registered charities was conducted by an independent consulting firm in October 2010. The purpose of the survey was to determine the extent to which registered charities were aware of the regulator and the information and assistance that is available to them – including CPOP – and the extent to which the information and assistance has been utilized.
• Review of Foreign Charity/Tax Administrations – A high-level comparative analysis was conducted to determine the extent to which Australia, New Zealand, the United Kingdom and the United States regulate – and educate – the charitable sector.

Use of Methodologies

Each methodology is not necessarily designed to address all evaluation issues. A specific methodology may be used to address only one issue or a series of research questions applicable to one or more issues. A survey, for example, may be used to assess awareness of a program and its relevance but may not assess program effectiveness or the program delivery model.

Conflicting Information

In most cases findings are determined based on the results of multiple sources of information derived from multiple methodologies. However, in some cases information from one source may or may not be consistent with information from other sources. In these circumstances the evaluation team must examine the various sources of information to assess the discrepancy and to determine which source of information is most valid. In this evaluation, the survey of representatives from the charitable sector provided information that was inconsistent with the views expressed in external interviews and from the literature review. In this instance, the evaluation team had to consider biases and the veracity of other sources of information vis-à-vis the survey results. Since the survey sought information directly from a random sample of the sector and the results are accurate to within plus or minus 4.4 percentage points in 19 out of 20 samples we consider the survey to be more representative of officials in the broader charitable sector.

5. Findings

5.1 Relevance

The CPOP is clearly aligned with the mission of the Charities Directorate

The Charities Directorate is responsible for administering the provisions of the ITA related to registered charities. Its mission is to "promote compliance with the income tax legislation and regulations relating to charities through education, quality service, and responsible enforcement, thereby contributing to the integrity of the charitable sector and the social well-being of Canadians". The CPOP is clearly aligned with the mission and responsibilities of the Charities Directorate. It provides, through the contribution recipients, training and education on a variety of topics to assist charities in complying with the ITA. This is consistent with the Charities Directorate's education-first approach to ensuring registered charities are compliant with the ITA.

The CPOP is one of several activities implemented by the Charities Directorate as part of the Charities Regulatory Reform Initiative (CRRI). The Charities Directorate received $12 million annually for five years in the March 2004 Budget to implement the CRRI which was aimed at modernizing the regulator and working differently, and more closely, with the charitable sector. The CRRI was largely based on recommendations made by the Joint Regulatory Table (JRT) entitled "Strengthening Canada's Charitable Sector: Regulatory Reform" published in May 2003. The JRT was a key element of the Voluntary Sector Initiative, a joint initiative launched in June 2000, to strengthen the relationship between the federal government and voluntary sector.

The integrity of the charitable sector is important to Canadians

Substantial federal government support is provided to the over 85,000 (as of January 2010) registered charities in Canada. Registration allows a charity to issue official donation receipts for gifts it receives. These receipts can be used to reduce the income tax payable of an individual donor or the taxable income of a corporate donor. Once registered, a charity is exempt from paying income tax under Part I of the ITA. Many goods and services provided by registered charities are exempt from goods and services tax/harmonized sales tax (GST/HST). Also, in many situations, registered charities can claim a partial rebate for the GST/HST they pay.

In 2008, donors claimed approximately $8.2 billion in donation credits. This works out to approximately $3.9 billion in foregone revenue for the federal and provincial governments [Footnote 1]. According to one survey [Footnote 2], almost 23 million Canadians – 84% of the population aged 15 and over – made a financial donation to a charitable or other non‑profit organization in the 12‑month period covered by the survey. The same survey found that Canadians also donated a total of $10 billion in 2007 and almost half (46%) said that someone in their household would be claiming an income tax credit for donations made over the previous 12 months.

Maintaining the integrity of the charitable sector is not only important in terms of tax credits and exemptions. The charitable sector is a significant contributor to the Canadian economy and is a major employer in Canada. Non-profit organizations, including registered charities, make a significant contribution to the economic and social well‑being of Canadians [Footnote 3]. In 2007, the gross domestic product of the core non‑profit sector amounted to $35.6 billion, accounting for 2.5% of the total Canadian economy [Footnote 4]. This share increases to 7.0% when hospitals, universities and colleges are included, reaching $100.7 billion in 2007 [Footnote 5]. In addition, almost 12.5 million Canadians or 46% of the population aged 15 and over, volunteered during the one-year period preceding the survey. Canadians volunteered almost 2.1 billion hours in 2007 – the equivalent of close to 1.1 million full‑time jobs [Footnote 6].

Compliance by registered charities has improved but there is an ongoing need for assistance

The number of registered charities continues to grow. There was an average of 2,520 new registrations in each year from 2004-2005 to 2008‑2009. Registered charities must file a properly completed T3010 and financial statements within six months of their fiscal period end. The evaluation team conducted an independent analysis of the return and financial data to assess the extent to which registered charities are non-compliant with the requirements of the ITA. The filing non-compliance trend indicated that the percentage of charities that file late has been dropping fairly steadily from 48.3% in 2000 to 35.4% in 2008. Given that the Charities Directorate may revoke a charity's registration as a result of filing non‑compliance, there is still room for improvement.

The percentages of charities having their charitable status revoked for non-filing is relatively small and has also been on a decreasing trend since reaching a peak of 4.1% in 2000. By 2008 this percentage had dropped to 0.9%. Revocation of a charity's registration has serious consequences. The charity will have its name and the reason for its revocation posted in the Canada Gazette and online on the CRA website; it cannot issue official donation receipts for gifts it receives; no longer qualifies for tax exemptions, and must transfer all its remaining property to an eligible donee or be subject to a revocation tax equal to the property's full value.

Audit results also suggest the ongoing need for education and training. The CRA conducted an average of 801 audits per year from 2006-2007 to 2009-2010. This data indicates that approximately 50% of audited charities require an education letter explaining the rules and suggesting corrective actions. We do acknowledge that audits may be targeted, rather than purely random, thereby skewing results in favour of the identification of non-compliance.

Research by the Charities Directorate has also identified a number of unique challenges that small and rural charities face in meeting their administrative and legislative responsibilities [Footnote 7]. The report found that small and rural charities have few, if any, full-time or paid staff; rely almost solely on volunteers to deliver their programs, and many are located in isolated areas with limited access to the Internet and few community resources. Not surprisingly, the report noted that volunteers want to be involved in the delivery of their charity's core programs rather than its administration. In effect, small and rural charities have little time, resources, and expertise available to interpret information or keep up‑to‑date with the requirements of the ITA. The research resulted in an action plan, developed jointly by the Charities Directorate and a panel of individuals from small and rural charities, committed to providing educational tools for the charitable sector.

Research conducted by the voluntary sector raised concern with the quality of information reported by registered charities [Footnote 8]. It identified that there was a very high frequency of problems that include mistakes in simple arithmetic (i.e., the sums of individual items not adding to reported totals), errors of omission (e.g., the failure to itemize expenditures) and logical inconsistencies (e.g., active charities reporting that there have been no charitable expenditures). It found that over one-third of charities had at least one readily identifiable problem of these types in their returns. The report also found that only 27% of charities report fundraising costs despite the fact that 84% report receiving dollars from tax-receipted gifts or fundraising revenues. The independent analysis of the T3010 data conducted by the evaluation team also identified issues regarding the quality of information reported by registered charities.

Many interviewees believe that CPOP is meeting a need

The evaluation team conducted interviews with 48 representatives from the voluntary sector. These interviewees were either applicants, contribution recipients, or others working in or on behalf of the voluntary sector. The majority of these interviewees felt that the CPOP was meeting a need by making a variety of resources available to assist registered charities in complying with the ITA. Most interviewees felt it was important for charities to have the option of receiving training and education from someone else in the voluntary sector other than the regulator. It was strongly believed that there may be a hesitation amongst registered charities to draw attention to themselves and any compliance issues they may have by asking questions directly to the regulator. The majority of those interviewed within the Charities Directorate also felt that there was validity to the perception that some registered charities would be hesitant to approach the regulator.

Despite this hesitation, most interviewees strongly felt that training and education developed and delivered by contribution recipients should supplement and not replace what was provided by the regulator and that both were required to meet the needs of charities. In several instances, contribution recipients reminded the evaluation team that the information they provided was of a general nature. If questions were asked of contribution recipients that should be directed to the Charities Directorate - as the regulatory authority – the questions should have been redirected as such.

The majority of all interviewees, internal and external to the Charities Directorate, felt that the turnover of staff and volunteers was an issue for registered charities and contributed to the ongoing need for compliance-based training and education.

The Charities Directorate has initiated several outreach activities to address non‑compliance

The CISD is responsible for the management and administration of the CPOP. The program, through the contribution recipients, has developed and implemented a variety of outreach that provides compliance-based training and education to registered charities. This includes the development and delivery of information sessions and webinars on a variety of topics. CISD also develops information sessions and webinars that are delivered by employees of the Charities Directorate directly to registered charities. CISD is also responsible for maintaining the "Charities and Giving" web pages on the CRA website and provides assistance to registered charities in the form of telephone and written enquires. In 2009-2010, the Charities Directorate received 10,671 written requests for service from registered charities and 111,136 telephone enquiries [Footnote 9].

Although not the subject of the evaluation, the CISD provided the evaluation team with data on the information sessions and webinars that are delivered directly to registered charities. The information sessions are free of charge and delivered across the country. Even though some data was missing, the number of participants ranged from a high of 4,579 in 2002 to a low of 2,021 in 2009. The CISD has not consistently collected data over the years as to whether participants were satisfied with what was learned at information sessions or if they found the information useful. However, when this type of question was asked in feedback surveys, the response was positive with the majority of participants being satisfied or finding the information useful.

The CISD began piloting Internet-based webinars in February 2009 as another way to educate registered charities. In 2010, the CISD delivered 21 interactive webinars in English and French, with an average of 138 participants for each session. Webinars have been delivered on a variety of compliance-based topics (e.g., GST/HST, financial statements, books and records, fundraising, gifting and receipting, etc). The live webinars are recorded and made available for viewing on the CRA website. CISD has received limited feedback on the webinars but it has been primarily positive.

The majority of interviewees from the voluntary sector praised the Charities Directorate for the improvements made in relation to the availability and accessibility of information for registered charities. Positive comments were received with respect to the quality of the information sessions delivered directly by the CISD to registered charities and, in particular, with respect to changes to the CRA website.

Our survey found that the majority of registered charities are satisfied with outreach activities that are provided directly to them by the Charities Directorate

The survey of 500 registered charities that was conducted as part of this evaluation found that 71% of respondents indicated that if they or others in their charity looked for information or assistance in the past two years, they would go to the CRA for assistance. This is compared to the 7% of respondents that indicated they would go to another charity or non‑profit organization. In addition, of those that went to the Charities Directorate for assistance, 76% got the information they needed and 70% found it useful. Finally, when asked their preference, 85% of respondents said they would prefer to obtain information on how to comply with the ITA directly from the CRA essentially because it is the authority.

The survey data indicates that turnover may not be a significant issue within the charitable sector. When asked how long they have been involved with their charity, 54% of respondents stated eight years or more and 25% stated four to less than eight years.

5.2 Program Design and Delivery

Considerable progress has been made on funding projects

The original program design anticipated that a total of 4 FTEs would be dedicated to this program. Although the number of FTEs allocated to the CPOP has changed over the years, it has ranged from 2.2 to 2.5 FTEs. The amount allocated for operating and maintenance costs has also fluctuated over the years. In certain instances, the CPOP has had to limit program activities (e.g., monitoring visits) due to budget restrictions. The CPOP is still in its infancy in terms of program delivery (19 of the 21 completed contribution projects ended on March 31, 2010, and 7 are still ongoing).

At the end of the formative evaluation in September 2007, CISD had conducted two calls for applications that resulted in 3 multi-year contribution agreements and the delivery of education had just begun. As of October 4, 2010, a total of 28 contribution agreements had been entered into with a total of 16 contribution recipients - 15 registered charities and 1 non‑profit organization. The CPOP has also made significant improvements in the last two calls for applications in terms of allocating the contribution funding and avoiding the lapsing of funds at the program level.

There have been a total of five calls for applications. The fifth call for applications resulted in 7 contribution agreements that are currently underway but are planned for completion by March 31, 2011. Each call for application has focused on different funding – or compliance - priorities. Other than the first call for applications, each call has had more than one funding priority. As indicated in Figure 1, the second call had 2 funding priorities, the third and fifth calls had 3 funding priorities, and the fourth call had 4 funding priorities.

Compliance-based education and training has now been developed by contribution recipients on a variety of topics and delivered in a variety of formats – from in-person workshops to web-based information and tools – to registered charities and potential registered charities across the country. Contribution recipients are spread across the country and training and education has been delivered and, in the case of web-based information and tools, made available to charities across the country. Refer to Appendix C for a complete list of contribution recipients and their projects.

The feedback data collected by contribution recipients from participants and/or users of the training and education has been overwhelmingly positive. In some instances, contribution recipients hired consultants to conduct an independent evaluation of their contribution project. Depending on the project, contribution recipients used a variety of methods to obtain feedback and assess the extent to which participants were satisfied with the training and education and/or whether they found it useful.

For the most part contribution recipients have developed and delivered the training and education in accordance with their agreements. In certain instances, adjustments had to be made due to time constraints and the changes were managed accordingly. Time constraints were particularly evident in single year - as opposed to multi-year - contribution projects. For example, the evaluation team found that some contribution recipients did not have enough time to implement the evaluation plan and collect the required data within the timeframe of the project. Of the 28 contribution projects, 22 have been single-year – in some cases less than a year - as opposed to multi-year projects. In the case of single-year projects, the evaluation report was due a month after completion of the project. This does not, realistically, give the contribution recipient much time to collect and assess data.

It should be acknowledged that the CPOP is the only contribution program administered by the CRA. As a result, employees had a significant learning curve not only in terms of understanding the many aspects of non‑compliance – as identified in the funding priorities – but also in terms of learning how best to manage and administer a contribution program. This combined with the turnover in employees has resulted in the CPOP essentially being in a continuous learning environment with little opportunity to apply what has been learned based on previous experience.

Figure 1: Funding Priorities

Call 1 2005-2006

Registered Charity Information Return (T3010)

Call 2 2006-2008

(1) Conducting foreign activities in a manner that is compliant with a charity's regulatory obligations under the ITA.

(2) Raising funds, issuing receipts, and maintaining books and records in a manner that is compliant with the charity's obligations under the ITA.

Call 3 2008-2009

(1) Projects that focus on the development of tools designed to assist small and rural charities in locating and/or accessing local, regional, and/or provincial information/ resources intended to support charities in meeting their regulatory obligations under the ITA.

(2) Projects with broad national application designed to raise the awareness and capacity of boards of directors regarding their compliance obligations under the ITA.

(3) Projects that foster collaboration with other registered charities to increase the ability of small and rural charities to meet their obligations under the ITA.

Call 4 2009-2010

(1) Explaining the requirements and obligations of charitable registration to organizations that are considering registration.

(2) Teaching registered charities how to avoid making gifts to non qualified donees.

(3) Researching best practices for charities to safeguard against terrorism.

(4) Providing small and rural charities with access to resources.

Call 5 2010-2011

(1) Educating charities on compliant fundraising practices.

(2) Educating charities and/or donors about tax shelter donation arrangements and false receipting.

(3) Promoting transparency and accountability in the sector.

Improvements have been made to operating procedures but additional guidance is required to support the CPOP

The CPOP has made progress in terms of its internal operating procedures. The program has now established both an electronic and hard-copy filing system where all program information is stored. Templates are in place for use by program officers; however, there are still gaps in the operating procedures that need to be addressed (e.g., dispute resolution). The CPOP has developed templates and a document entitled "Guidelines for Recipients" for use by contribution recipients and these have been amended to reflect some of what has been learned to date. The CPOP has also taken steps to provide applicants with better information as to why they were not successful in order to improve transparency and accountability.

In reviewing other grant and contribution programs, the evaluation team found several federal and provincial government organizations that had information that could be useful to the CPOP from a program improvement perspective. For example, the Ontario Trillium Foundation has a webpage entitled "About Unsuccessful Applications". It provides resource material pertaining to some of the reasons why applications are declined. Others have developed guides for applicants and/or contribution recipients that also serve as guidance for program officers in the administration of the program. The Department of Justice Canada has developed "How to Apply for Funding" and Human Resources and Skills Development Canada has developed "A Guide to Managing Your Contribution Funds".

Most of the contribution recipients and applicants interviewed were generally satisfied with the Funding Guide and Application. Alternatively, some ARC members found that there was duplication in the content of the applications that were referred to them for review. It was felt that this may have been due to a lack of clarity in the Funding Guide and Application. The evaluation team also found some inconsistencies in the Funding Guide and Application and other documentation that is available to applicants on the program's webpage (e.g., terms and conditions and eligibility criteria).

Contribution recipients' biggest concern was the amount of detailed financial information and, in some cases the frequency of data, which was required by the CPOP to administer the program. Although improvements have been made by the CPOP, concern was also expressed in terms of delays in the signing-off of contribution agreements and the impact on the timing of the start-up of some projects.

The CPOP requires contribution recipients to develop and implement an evaluation framework that describes, at a high level, the type of information that should be included (e.g., goals, objectives, activities, outputs, outcomes, etc.). The evaluation framework must be submitted within one month for single-year projects and within six months for multi-year projects. Contribution recipients must also provide progress reports and a final evaluation report. For multi-year projects, contribution recipients are also required to submit a mid-term evaluation report. The evaluation found that limited direction has been provided to contribution recipients on what should be included in an evaluation report in terms of performance measurement. As a result, the information collected by contribution recipients to date has not been consistent. Consistency may not be possible in all cases; however, it is important that performance measurement data be collected in a manner that can feed into an overall program performance measurement strategy.

Many interviewees in both the formative and summative evaluations noted that the use of the ARC was a positive feature of the program and it was noted as a best practice. All interviewees strongly felt that the ARC added value and credibility to the selection process and improved the quality of applicants selected for funding. However, the evaluation team found that there is currently limited information available to ARC members with respect to their roles and responsibilities (e.g., terms of reference, conflict of interest policy, confidentiality policy, history of contribution projects to date, etc.).

Terms and conditions need to be reviewed

The terms and conditions for the management of the CPOP were approved by the Treasury Board Secretariat in March 2005. Some aspects of the terms and conditions were not well defined which has lead to difficulties in managing and administering the CPOP.

"Innovation"

The CPOP is the mechanism, as stated in the terms and conditions, by which the Charities Directorate chose to implement the JRT recommendation that "The regulator should find new, innovative ways of delivering education to charities by building partnerships with the sector." The terms and conditions do not; however, make any reference to innovation in the list of application requirements which outline what must be included in applications for funding. On the other hand, the Funding Guide and Application refers to the terms "innovative" or "innovation" throughout the document and identifies "the innovative nature of the project and its cost-effective aspects" as one factor that will be considered when reviewing and recommending applications for funding. The assessment criteria that is published on the CPOP webpage and the assessment sheets used by the ARC also make reference to the innovative nature of the project in one form or another.

The Funding Guide and Application, in its glossary of terms, defines innovation as "The characteristics that make the proposed project different from other projects. Innovations may include adopting new approaches, dimensions, methods or technologies that will affect the effectiveness and efficiency of a project." Nevertheless, the evaluation team found that the concept of innovation and how it was applied as part of the review and approval process was not well understood by many of those interviewed. It was also unclear as to whether interviewees had a good understanding as to what would be considered innovative in terms of "training and education".

The whole concept of innovation also raises the question as to the level of risk the program is willing to take in terms of failure. For example, is the CPOP willing to undertake a project that utilizes new technology to develop and deliver training and education and, if it fails, use it as a learning experience for future projects?

"Partnerships"

The same JRT recommendation makes reference to the regulator finding ways to deliver education to charities by building partnerships with the sector. Most of the interviews with representatives from the voluntary sector felt that the program was having a positive impact on the relationship between the Charities Directorate and the voluntary sector. Contribution recipients have implemented a number of activities (e.g., in-person meetings, teleconferences, etc.) to improve information sharing amongst all of the projects. Contribution recipients were positive with respect to the CPOP's increased participation in these activities.

Contribution recipients were also positive with respect to the increased emphasis the CPOP was placing on meeting with contribution recipients much earlier in the lifecycle of the agreement as part of the monitoring process. The majority of contribution recipients indicated that their relationship with the program had improved significantly over time but that there was still some hesitation on the part of CPOP to fully engage contribution recipients. This may be in part due to some confusion regarding the extent to which the CRA considers contribution agreements to be partnerships.

For example, the CRA report entitled Small and Rural Charities: Making a Difference for Canadians (June 2008) refers to the contribution recipients as partners: "In addition, the CRA will partner with registered charities and non‑profit organizations serving the charitable sector, through the Contribution Program, to deliver educational programs including community based, in-person service for small and rural charities, where feasible." However, Clause 12.0 of the most recent contribution agreements clearly states that recipients should not represent themselves as a partner of the Crown. "No Employee or Agency Relationship: Neither the Recipient nor anyone else who is asked by the Recipient to help with this Project is an employee of the CRA. The Recipient understands that this Contribution Agreement does not make it a partner of the CRA or an agent of the CRA. The Recipient agrees not to represent itself, including in any agreement with a third party, as a partner or agent of the Crown." The evaluation team realizes this is a legal document and that the CRA must ensure that no employee or agency relationship is established with contribution recipients but it raises the question as to what constitutes a partnership in terms of this program.

Other federal and provincial grant and contribution programs are focused on partnerships; however, it appears that additional emphasis is placed on the partnerships entered into among applicants. The Justice Partnership and Innovation Program (JPIP), Department of Justice (DOJ) Canada, strongly promotes partnerships and consortia as part of the application process. Applicants are encouraged to identify potential funding partnerships in their applications. JPIP even offers to help applicants identify potential partners for their projects. DOJ also strongly encourages applicants to form partnerships and receive associated in-kind and financial support to leverage the funding that is being requested from JPIP.

Similarly, the Ontario Trillium Foundation (OTF), Ontario Ministry of Culture, supports projects that help young people navigate and shape their economic future. The Call for Proposal, Economic Opportunities for Ontario Youth, Future Fund 2010‑2011, states that the OTF "…encourages collaborative applications from organizations representing diverse communities ..." and that "Applications should describe the nature of the collaboration and outline the strengths of the partnership."

Perhaps even more importantly than what is considered a partnership, is the risk associated with relying on a third-party to deliver training and education on what many representatives of the Charities Directorate perceive as an important aspect of their mandate. Concerns were raised in particular with respect to the quality control aspect of the training and education and the impact on the Charities Directorate if information was not accurately interpreted by contribution recipients. The CPOP has implemented a quality review process to mitigate this risk.

"Eligible Recipients"

In order to be eligible to receive project funding from the CPOP, applicants must be a registered charity as defined by the ITA or a non-profit organization serving the charitable sector. Most interviewees from the voluntary sector did not feel that the eligible recipients should be changed in any way. The majority did feel; however, that, if there was a change, eligible recipients should not be expanded to include for‑profit organizations.

Some concerns were raised by representatives of the Charities Directorate and the evaluation team with regards to the inclusion of "non‑profit organization serving the charitable sector". The evaluation was unable to find a clear explanation as to why non‑profit organizations were identified as eligible recipients. The Charities Directorate is responsible for administering the provisions of the ITA related to registered charities; however, it does not have the same responsibility for non-profit organizations. Consequently, the Charities Directorate does not have a mechanism in place to verify the compliance history of a non-profit organization in the same manner as it does a registered charity. Similarly, the Charities Directorate does not maintain a list that could be used to reach non-profit organizations to collaborate with them in the same way it does registered charities. The lack of contact information may be the reason why the number of non‑profit organizations that have applied for funding is 29 compared with the 193 registered charities (the remaining 8 did not fall into either category) since the start-up of the program.

"Collaboration"

The terms and conditions for the program state that "Collaboration with the sector will be a defining feature of the planning and implementation of the projects under the Charities Partnership and Outreach Program. Ongoing communication and consultation with the Charities Advisory Committee, the sector, and other partners will be key to effective implementation of the funding program and the projects themselves." Treasury Board supports collaboration with applicants and recipients as a key element of any grants and contribution program. In fact, the Treasury Board Policy on Transfer Payments, which became effective in October 2008, includes significant new responsibilities with respect to ensuring that applicants and recipients are engaged when appropriate.

The evaluation team found that two of the three funding priorities for the third call for applications and one of four priorities for the fourth call were based on collaboration with small and rural charities undertaken by the Charities Directorate as part of the small and rural charities initiative. Although not conducted by the CPOP itself, the results of the collaboration were used by the Charities Directorate to select funding priorities as well as inform contribution recipients in the development and delivery of contribution projects.

The same level of research, analysis, and/or collaboration with the charitable sector was not evident for the remainder of the funding priorities. It is likely that data, such as audit findings, were used by the Charities Directorate to inform the selection of funding priorities; however, the evaluation team was unable to determine the extent to which it had been validated through collaboration with the charitable sector. Some collaboration with the charitable sector may be undertaken by other areas within the Charities Directorate; however, the evaluation team was unable to find evidence that this collaboration had been documented and then used to help identify and select funding priorities.

Five of the 16 contribution recipients are categorized as medium-sized registered charities and 10 as large-sized based on the total revenue reported on their T3010 [Footnote 10]. The remaining contribution recipient is a non-profit organization and similar criteria have not been established in order to classify it as small, medium or large. The criteria used to assess applications for funding makes it less likely for small or medium-sized registered charities to receive funding. Some applicants expressed concern that some of those contribution recipients did not have the reach into certain communities (e.g., multicultural, faith-based, etc.) that smaller organizations with a more specific target group would have.

The CPOP is not aligned with an overall Charities outreach strategy

The CRA views outreach as a dynamic and strategic interaction with target audiences to: increase awareness and encourage voluntary compliance; educate, inform, and promote CRA programs and services; and promote CRA as a leading-edge organization. In terms of promoting the program to potential applicants, the number of applications received for the five calls has ranged from a high of 57 to a low of 28. The number of applications referred to the ARC has ranged from a high of 34 to a low of 12. See Figure 2 for more detailed information on the number of applications received, referred to ARC, and funded.

Figure 2: Applications Received, Referred to ARC, and Funded

Some applicants (both successful and unsuccessful) felt that the Charities Directorate could do more to promote the contribution program. As it is unclear what was expected from a planning perspective, it is difficult to assess whether the number of applicants, and contribution recipients should be considered a success. It should be noted that an increase in the number of applications would lead to an increased workload both on the part of the CPOP but also on the part of the ARC. The majority of ARC members interviewed as part of both the formative and summative evaluations commented that the workload associated with being an ARC member was substantial and required a significant time commitment. This raises the question as to the extent the CPOP wants to promote itself taking into consideration the resulting impact on workload.

As indicated in Appendix D, contributions recipients are from across the country. The number of applications from various provinces and territories is fairly representative of the distribution of registered charities across Canada.

Repeat applicants submitted a total of 81 of the 230 applications. A total of 15 of the 16 contribution recipients have been "repeat" applicants and 8 contribution recipients have been funded more than once. The terms and conditions sets out some limitations in terms of funding that restricts the number of times a contribution recipient can receive funding (i.e., the maximum number of successive years that the Agency will approve contributions to a recipient for a similar project under these terms and conditions shall not exceed three). This also raises the question as to if the program should be attracting new applicants or whether the current restrictions on funding are too limiting.

The program continues to integrate information on CPOP into existing outreach products and activities in order to promote itself and the training and education developed by the contribution recipients. A good example is the information included on the contribution projects under the title of "educating and training for charities" in the Charities Connection (formerly the Registered Charities Newsletter) in September 2010. The evaluation team did not find any evidence that an outreach strategy for the program had been developed and implemented. Nor was there evidence that the needs of the CPOP have been aligned with an outreach strategy for the CISD.

The evaluation team found evidence that the CISD was coordinating the delivery of the information sessions and webinars delivered by employees of the Charities Directorate. For example, the Charities Directorate announced that information sessions and webinars developed and delivered directly by the Charities Directorate - not those funded by the Charities Directorate and developed and delivered by contribution recipients – will be coordinated in the future [Footnote 11]. Information sessions will be presented from September to November of each year and webinars from January to June. The Policy, Planning and Legislation Division (PPLD) in the Charities Directorate is also responsible for a number of outreach activities. Although the target audience is donors (the public) as opposed to registered charities, it does not appear that an outreach strategy for the Charities Directorate has been developed.

The onus for communicating the training and education has, for the most part, been left to each contribution recipient. At the start of each project, contribution recipients are asked to submit a communications plan. Many contribution recipients felt that the Charities Directorate could do more to promote the training and education to assist them in reaching registered charities.

Interviews conducted with representatives of the Charities Directorate outside the CPOP raised the question as to the extent to which the training and education projects had been communicated to the rest of the Charities Directorate. The evaluation team found that there was not a clear understanding of the CPOP itself and what it was trying to achieve.

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Other grant and contribution programs provide options that could be considered for program improvement

The evaluation team was unable to find a contribution program that is directly comparable with the CPOP in terms of program design and delivery. Nonetheless, there are a number of grant and contribution programs administered by federal and provincial governments that could be used to identify alternatives to the CPOP's current delivery model. One best practice that was identified in the formative evaluation and was again mentioned by interviewees in the summative evaluation was that of a 2-tier application process. The applicant would first be required to submit a letter of intent and, if approval to proceed was given by the program, the applicant would then submit a more detailed application. It was felt that a 2-tier process would benefit both the Charities Directorate and applicants by streamlining the process and prevent applicants from putting significant time and effort into an application that is unlikely to receive funding.

The DOJ provides annual funding to one Public Legal Education and Information (PLEI) organization which is recommended by the province. The funding is provided in the form of grants and contributions through the Justice Partnership and Innovation Program (JPIP). The annual funding provided to PLEI organizations is core funding as opposed to project funding; nonetheless, JPIP does provide an example of an alternative program design and delivery. Especially considering that a number of contribution recipients that have received funding from the CPOP are designated PLEI organizations. Many provincial governments, such as New Brunswick's Community Non-Profit Organizations Secretariat and Alberta's Ministry of Culture and Community Spirit, work closely with the non-profit and voluntary sector in their provinces.

Another alternative to the current delivery model would be to revert back to the more traditional delivery model utilized by the CRA to deliver outreach. This would mean that the renewal of the contribution program would not be pursued and all outreach to registered charities would be developed and delivered directly to registered charities by the Charities Directorate. The current CRA investment of approximately $208,000 in salary and operating and maintenance costs could be reallocated to other outreach activities. However, it is unlikely that the same level of outreach could be achieved without the $3 million annual investment in the form of contribution funding from Treasury Board.

In addition, without the ability to fund contribution projects, it would be impossible for the Charities Directorate to achieve CPOP's objective to "improve the capacity of the sector to develop and deliver sustainable compliance-based education programs". The majority of interviewees from the voluntary sector felt that the CPOP was beneficial to charities and has played a role in building a stronger relationship between the Charities Directorate and charitable sector.

5.3 Achievement of Expected Results

Program objectives are difficult to measure

The evaluation team found that the program objectives are not well-defined and, therefore, difficult to measure. For example, the overall objective of the program is "to increase compliance and build a responsive charitable sector". This raises questions as to what is a "responsive charitable sector" and what performance indicators are needed to measure the level of "responsiveness".

In terms of the main objective "to improve the capacity of the sector to develop and deliver sustainable compliance based educations programs", the assumption can be made that because the eligible recipients include both registered charities and non-profit organizations serving the charitable sector that the reference to the "sector" is intended to be the voluntary as opposed to charitable sector. Regardless, the term "capacity" needs to be further defined in order to determine if and how it can be measured.

A study conducted by the voluntary sector raises issues regarding the capacity of the voluntary sector related to training. The study found that many participants found it was often difficult to recruit volunteers who have the skills they need and many organizations have difficulties finding adequate time and money for volunteer training [Footnote 12]. The same study also found that cost and accessibility were frequently mentioned by participants as barriers to training. Although the Capacity to Serve study may be somewhat dated it is hard to imagine that the situation has improved over the years, in particular, in light of the recent economic downturn. It is interesting to note that of the registered charities that participated in the survey conducted as part of this evaluation, 86% did not feel that there were any barriers that prevented them or others in their charity from obtaining information and receiving assistance in complying with the ITA.

Imagine Canada's "Sector Monitor" dated April 28, 2010, stated that many charities are experiencing challenges associated with the economic downturn. The United Kingdom Charities Commission has conducted surveys to establish and track the extent to which charities have been affected overall by the economic downtown. Their 2010 survey found that 59% of charities now say that they have been affected by the economic downturn, a slight increase from 56% in August 2009. The number of charities affected has increased for the fourth consecutive time since the survey was first conducted in September 2008 when 38% reported an impact.

The same issues around capacity can be raised with respect to the second main objective "to increase the capacity of the charitable sector in meeting regulatory compliance requirements in a sustainable fashion". To further complicate the achievement of results, this objective adds the concept of sustainability to the mix. The program provides project funding to contribution recipients to develop and deliver training and education projects. Applicants are asked to address the issue of sustainability as part of the application process; however, the majority of contribution recipients have not been able to sustain their projects once the funding has been discontinued.

The lack of sustainability of the training and education delivered as part of the contribution projects was a concern raised by many contribution recipients. Several had received requests for additional training and education after the funding period had expired. Many thought that a considerable amount of time and money had been invested and that a way to maintain the contribution projects on a longer-term basis should be found. For example, lower dollar funding could be provided through grants - which are less burdensome on the part of the program and recipients to administer than contributions - or contracts which would increase the return on investment.

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Limited progress in measuring program performance

The very nature of this program, which relies on third parties for the delivery of training and education and, as a result, the collection of data in order to assess the overall impact of the program, makes performance measurement a challenge. The Independent Blue Ribbon Panel (BRP) on Grants and Contributions, commissioned by Treasury Board in June 2006 to recommend ways to make the delivery of grant and contribution programs more efficient and accountable, identified that performance measurement was a struggle for many grant and contribution programs. It also stressed the importance of having a performance measurement strategy developed as part of program design in order to ensure appropriate data is collected and reported.

This does not take away from the fact that little progress has been made by CPOP since the formative evaluation in terms of developing and implementing a performance measurement strategy. A performance measurement strategy is even more important now than at the time of the formative given the increased emphasis the Treasury Board Secretariat has placed on ensuring that grant and contribution programs are able to achieve results [Footnote 13]. The CPOP is not using the information provided by contribution recipients to assess performance at the program level. The BRP also noted that, while grant and contribution programs are designed to achieve public policy objectives, it is rare that a single recipient is in a position to meet these objectives alone.

Another element that impacts performance measurement and the establishment of baselines by which to measure change in compliance behavior is the changing funding priorities. As stated previously, there have been five calls for applications. Each call has had different funding priorities and, with the exception of the first call for applications, each call has had more than one funding priority. Consequently, all 28 contribution projects are not aligned with one funding priority. Each funding priority should, in all probability, have its own performance indicators and baseline data, which lessen the program's ability to measure the impact of the program.

6. Conclusion

Ensuring the integrity of the charitable sector is important not only because of the tax benefits associated with being or contributing to a registered charity but because of the larger role the sector plays in the day to day lives of Canadians. The CPOP's objective of raising awareness of the charitable sector and of the regulatory obligations under the ITA is clearly aligned with the Charities Directorate's mission "to promote compliance with the income tax legislation and regulations relating to charities through education … thereby contributing to the integrity of the charitable sector and the social well-being of Canadians." There is a variety of data which suggests that, although compliance by registered charities has improved over the past several years, there is still an ongoing need for assistance to registered charities in understanding the requirements of the ITA. The majority of representatives from the voluntary sector strongly felt that the CPOP was meeting a need by making a variety of resources available to assist registered charities. The feedback data collected by contribution recipients from participants and/or users of the training and education has been overwhelmingly positive.

The CPOP has made progress, particularly in terms of the number of contribution projects that have developed and delivered on compliance-based training and education, since the formative evaluation in April 2008. Although there are gaps in operating procedures these deficiencies can be overcome especially in light of what has been learned by the program over the past several years. However, there are still considerable gaps in performance measurement, which may, in part, be due to program objectives not being well-defined and, not easily measured.

Additionally, the terms and conditions for this program require clarification in order to ensure that they are implemented in a manner that is well understood by all stakeholders. The CPOP has also not been aligned with an overall Charities Directorate outreach strategy. The need to renew the terms and conditions in March 2011 provides an excellent opportunity for the Charities Directorate to reassess the program and determine how it aligns with the strategic direction of the Charities Directorate.

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7. Recommendations

Based on the findings of this evaluation, program management should:

• in light of the program experience over the last five years and the findings of this evaluation, review the terms and conditions including the current objectives to ensure that they are more realistic and measurable;
• once the terms and conditions and objectives are clarified, focus on developing and implementing a performance measurement strategy;
• ensure that the CPOP is aligned with an outreach strategy for the Charities Directorate; and
• continue to make improvements to internal operating procedures and guidance for program participants.

8. Management Response

In light of the program experience over the last five years and the findings of this evaluation, review the terms and conditions including the current objectives to ensure that they are more realistic and measurable

The Charities Directorate agrees with this recommendation. The program was established with broad objectives that were meant to be flexible, to enable the program to explore and adapt itself to the unique circumstances of the sector. The intention at the program's inception was to learn as the program matured and adapt it accordingly. We believe that we have made strides in incorporating what has been learned into each subsequent call for proposals.

It is time to look at the program objectives again, in light of our experience and in light of the findings of the evaluation team, to ensure the program is well-positioned for the future. The Charities Directorate will review the terms and conditions including the current objectives to ensure they are more realistic and measurable, by December 2011.

Once the terms and conditions and objectives are clarified, focus on developing and implementing a performance measurement strategy

The Charities Directorate agrees with this recommendation. The Directorate is currently developing performance indicators, which will be piloted during the current call for proposals. The Directorate will develop a performance measurement strategy by December 2011.

Ensure that the CPOP is aligned with an outreach strategy for the Charities Directorate

The Charities Directorate agrees with this recommendation and is currently taking the necessary steps to align CPOP with the Directorate's outreach strategy. The recent reorganization within the CISD has brought together all of the Division's outreach activities under one manager. In addition, a new Directorate outreach committee has been established, whose mandate extends to CPOP. As well, the Directorate has begun leveraging the products developed by CPOP recipients in many aspects of its work, including the registration process and in field audits.

Continue to make improvements to internal operating procedures and guidance for program participants

The Charities Directorate agrees with this recommendation. The Directorate will continue to make improvements to internal operating procedures and guidance for program participants. The Directorate is piloting internal service standards in relation to financial review of claims and technical review of products.

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Appendix A: Glossary of Terms

Application Review Committee (ARC) – Applications received through the CPOP that meet the screening criteria are forwarded to an Application Review Committee (ARC). The ARC includes representation from the CRA and the sector. Depending on the nature of the applications, representatives from other federal departments, the provinces, territories, and academia may also be involved in the review. The Committee considers factors such as innovativeness, sustainability, and scope of the project when evaluating the applications.

Blue Ribbon Panel (BRP) – The Blue Ribbon Panel was an independent panel commissioned in June 2006 by the President of the Treasury Board Secretariat. The panel conducted a six-month review of the administration of federal grant and contribution programs and recommended measures to make the delivery of these programs more efficient while ensuring greater accountability.

Charitable purposes - The courts have identified four categories of charity: (1) the relief of poverty; (2) the advancement of education; (3) the advancement of religion; and (4) certain other purposes that benefit the community in a way the courts have said is charitable. An organization's purposes must fall within one or more of these categories to be considered for registration as a charity.

Charitable sector – The charitable sector is defined by those charities that are federally registered under the Income Tax Act.

Contribution – Is a transfer payment subject to performance conditions specified in a funding agreement. A contribution is to be accounted for and is subject to audit.

Contribution agreement –Is a written agreement or documentation constituting an agreement between the Government of Canada and an applicant or a recipient setting out the obligations or understandings of both with respect to one or more transfer payments.

Formative evaluation – A formative evaluation is a type of evaluation that has the purpose of ongoing program improvement. It is usually conducted early in the implementation of a program, and used to evaluate if the program is on the right track to achieving its objectives. This type of evaluation usually focuses on issues such as implementation, relevance and possible alternatives or modifications.

Grant – Is a transfer payment subject to pre-established eligibility and other entitlement criteria. A grant is not subject to being accounted for by a recipient nor normally subject to audit by the department. The recipient may be required to report on results achieved.

Official Donation Receipts – Registered charities can issue official donation receipts (also referred to as "tax receipts") to acknowledge gifts. An official donation receipt is subject to particular requirements under the Income Tax Regulations including identification that it is an official receipt for income tax purposes.

Non-profit organization – A non-profit organization is an association, club, or society that is operated exclusively for social welfare, civic improvement, pleasure, recreation, or any other purpose except profit. It is not a charity. No part of the organization's income can be payable to or available for the personal benefit of any proprietor, member, or shareholder, unless the recipient is a club, society, or association whose primary purpose and function is to promote amateur athletics in Canada.

Performance measurement strategy – Is the selection, development and ongoing use of performance measures for program management or decision‑making.

Recipient – Is an individual or entity that either has been authorized to receive a transfer payment or that has received that transfer payment.

Registered charity – A registered charity refers to a charitable organization, public foundation, or private foundation that was established in Canada and is resident in Canada. It is operated for charitable purposes and must devote its resources to charitable activities. A registered charity has received a registration number from the Canada Revenue Agency and is exempt from paying tax on its revenue. It can issue donation receipts for gifts that it receives.

Summative evaluation – Summative evaluations are typically conducted further into the implementation of a program and focus on the achievement of results. This type of evaluation focuses on program results, especially for making decisions about program continuation, expansion, reduction and funding. It addresses outcomes in order to evaluate the program in terms of effectiveness as compared with similar type programs.

Terms and conditions – Is a document, approved by the Treasury Board Secretariat or a minister, which sets out the parameters under which transfer payments may be made for a given program.

Transfer payment – Is a monetary payment, or a transfer of goods, services or assets made, on the basis of an appropriation, to a third party, including a Crown corporation, that does not result in the acquisition by the Government of Canada of any goods, services or assets. Transfer payments are categorized as grants, contributions and other transfer payments. Transfer payments do not include investments, loans or loan guarantees.

Treasury Board Policy on Transfer Payments – The objective of this policy is to ensure that transfer payment programs are managed with integrity, transparency and accountability in a manner that is sensitive to risks; are citizen and recipient-focused; and are designed and delivered to address government priorities in achieving results for Canadians.

Voluntary sector –The voluntary sector is one of the three pillars, along with the public and private sector, which make-up Canadian society. The voluntary sector, in its broadest sense, is composed of all non-profit organizations (including registered charities) that exist in Canada.

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Appendix B: Registered Charity versus Non-profit organization

Registered charities are often referred to as non-profit organizations. However, while both types of organizations operate on a non-profit basis, the two types are defined differently under the ITA.

Appendix C: Contribution Recipients and Projects

Appendix D: Map of Contribution Recipients

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Appendix D provides a map of contribution recipients. There have been five calls for applications under the CPOP and a total of 28 contribution agreements have been signed with 15 registered charities and 1 non-profit organization. Applications were received from various organizations across Canada.

The following organizations received funding: Community Sector Council Newfoundland and Labrador; Legal Information Society of Nova Scotia; Public Legal Education and Information Service of New Brunswick; Actions interculturelles de développement et d'éducation (Quebec); Université du Québec à Montréal and Éducaloi; Canadian Association of the Deaf (Ontario; Centre for Voluntary Sector Research and Development (Ontario) and Canadian Council for International Co-operation (Ontario); Ontario Community Support Association; Imagine Canada (Ontario); Public Legal Education Association of Saskatchewan; Legal Resource Centre of Alberta Ltd; Centrepoint Non-Profit Management (Alberta); Mount Royal University - Centre for Non-Profit Studies (Alberta); and, Fraser Valley Centre for Social Enterprise (British Columbia). Some of these organizations were funded for more than one project.