Final Report

Audit, Evaluation, and Risk Branch

February 2022

Executive summary

To ensure the integrity and fairness of Canada's tax and benefit systems, the Canada Revenue Agency (CRA) employs a range of compliance measures. A “lead” is information concerning suspected cases of tax and benefit non-compliance obtained by the CRA, independent of these compliance measures. This type of information is kept confidential and might come from internal or external sources. Leads assist the CRA in detecting non-compliance that might otherwise go undetected by current compliance strategies.

The objective of the audit is to provide the Commissioner, CRA management, and the Board with assurance that controls are in place and working as intended for the CRA's current method of obtaining, analyzing, and resolving of internal and external leads.

The audit covered the CRA’s existing leads processes with particular focus on both internal and external leads procured and processed by the National Leads Centre. A detailed review of programs receiving, producing, and forwarding leads within the CRA was also included to ensure that leads are identified, documented, and processed consistently. The Internal Audit Division used data analysis to review three years of leads-related data from April 2018 to March 2021. In addition, a leads file review was conducted on leads from fiscal year 2020 to 2021.

Within the CRA, leads are evaluated and processed in accordance with established procedures. Leads are a vital source of information for some programs, but are rarely used by others. This internal audit found that lead outcomes are not tracked or reported by CRA programs. The value of leads, as well as the impact of leads on non-compliance and on the CRA’s reputation remain unknown at this time. There are also certain gaps when it comes to programs that receive leads and report the results to the National Leads Centre. Although the analysis and processing of leads at the National Leads Centre has certain quality and consistency difficulties, the Leads Section of the Compliance Programs Branch has been proactive in trying to address and correct these issues.

Summary of recommendations

• The Compliance Programs Branch, in collaboration with the Public Affairs Branch, should update the communication work plan for the Leads Program.
• The Compliance Programs Branch should implement a formal Quality Review Program that ensures leads review and analysis processes are being conducted consistently at the National Leads Centre.
• Processes should be developed to promote the sharing of internal leads information between different programs in the CRA.
• The Compliance Programs Branch should create a plan or framework to incorporate leads data into data analysis and business intelligence.
• Consistent policies should be developed concerning the handling and sharing of internal and external leads information between programs in the CRA.
• The CRA workload development areas should follow procedures to report the actions they take on leads to the National Leads Centre.
• The Compliance Programs Branch should assess the value of all leads and their impact on compliance.

Management response

The Compliance Programs Branch agrees with the recommendations in this report and has developed related action plans. The Audit, Evaluation, and Risk Branch has determined that they appear reasonable to address the recommendations.

1. Introduction

The Canada Revenue Agency (CRA) uses a variety of compliance measures to maintain the integrity of Canada’s tax and benefit systems. In addition to these techniques, the CRA obtains information about possible cases of tax and benefit non-compliance, known as a “lead”. This type of information can come from both internal and external sources, and is kept confidential. Leads help the CRA identify non-compliance that might otherwise go unnoticed by internal systems and programs.

The Leads Program is a national-level program that allows the public to report suspected cases of tax and benefit non-compliance and also processes internal leads. This program is administered by the GST/HST Directorate of the Compliance Programs Branch and oversees the business operations of the National Leads Centre. The Leads Section of the Compliance Programs Branch in Headquarters monitors leads statistics, produces reports, and provides policy and functional direction to the National Leads Centre. The National Leads Centre is responsible for capturing, reviewing, triaging, and routing over 30,000 domestic leads a year to over 20 specific workloads for compliance action. This past year, the National Leads Centre processed over 60,000 leads, with the increase being attributed to leads related to COVID-19 benefits.

Internal leads are submitted by CRA employees who have identified potential non-compliant behaviour through the course of their regular duties. Internal leads are used to pass information on from a section that doesn’t deal with a particular tax matter to another section that does. Internal leads are submitted directly to the receiving program or to the National Leads Centre, which will then transfer them to the appropriate area.

For the purpose of this report, an internal lead is one that is generated by CRA employees, while an external lead is submitted by an individual or organization outside of the CRA concerning suspected cases of tax and benefits non-compliance.

2. Focus of the audit

This internal audit was included in the Board of Management (Board) approved Risk-Based Audit and Advisory Plan 2020-2021. The Assignment Planning Memorandum was presented to the Audit Committee of the Board on June 8, 2021, and approved by the Commissioner on June 18, 2021.

2.1. Importance

This internal audit is important because a review of the internal and external leads processes confirms whether controls are in place and working as intended to ensure the effective management and processing of leads. It also confirms whether leads support the CRA in meeting its objective to expand its capacity to access and use data to effectively detect and resolve non-compliance, thereby, upholding the integrity of the tax system.

A substantial increase of external leads was received by the CRA in relation to COVID-19 benefits administered in 2020. The media reported on the potential abuse of COVID-19 benefits and as a result, the efficiency and effectiveness in resolving ineligible COVID‑19 benefit claims could be scrutinized by the media in the near future. Ensuring the leads process has controls in place to handle the influx of leads and is capable of addressing leads related to COVID-19 benefits would help the CRA in maintaining the public’s trust and fairness to all taxpayers.

2.2. Objective

The objective of the audit was to provide the Commissioner, CRA management, and the Board with assurance that controls are in place and working as intended for the CRA’s current method of obtaining, analyzing, and resolving internal and external leads.

2.3. Scope

The audit covered the CRA’s existing leads processes with particular focus on both internal and external leads procured and processed by the National Leads Centre. A detailed review of programs receiving, producing, and forwarding leads within the CRA was also conducted to ensure that leads are identified, documented, and processed consistently. Particular attention was also placed on leads linked to COVID-19-related benefits.

This audit did not include an assessment of the lead intake processes of the Criminal Investigations Directorate or the Offshore Tax Informant Program as these areas have separate criteria outlining whether the lead should be taken into workload.

The Internal Audit Division used data analysis to review three years of leads-related data from April 2018 to March 2021. In addition, a leads file review was conducted on leads from fiscal year 2020 to 2021.

This audit included interviews with relevant management and staff in Headquarters and the Ontario and Western regions. Data and file reviews included leads received and produced from all regions.

2.4. Audit criteria and methodology

The audit criteria and methodology can be found in Appendix A.

The examination phase of the internal audit took place from June 2021 to August 2021.

The internal audit was conducted in accordance with the International Standards for the Professional Practice of Internal Auditing, as supported by the results of the quality assurance and improvement program.

3. Findings, recommendations, and action plans

The recommendations presented in this report address issues of high significance or mandatory requirements.

The Compliance Programs Branch agrees with the recommendations in this report and has developed related action plans. The Audit, Evaluation, and Risk Branch has determined that they appear reasonable to address the recommendations.

3.1. Leads intake and processing

3.1.1 Although formal “lead” definitions exist in the CRA, some definitions are inconsistent between programs.

The internal audit team found that programs have their own definitions for the following terms: internal leads, external leads, informant (tipster) leads, transfers, and referrals. These terms are formally documented and are found to be defined with specified criteria.

However, the lead-related terms are sometimes defined inconsistently across program areas. For example, an external lead as defined by one program is information provided by an external source outside of the CRA. Another program, on the other hand, uses the same definition for informant leads and considers an external lead as one originating from outside of their program, but still internal to the CRA.

Although some programs have different definitions, they are mainly understood by the program’s staff. The area of confusion is the difference between an internal lead and a referral, resulting in these terms being used interchangeably across program areas. Still, most workload development areas and the National Leads Centre will process an internal lead and a referral in the same manner, so the differences do not have a considerable impact on resolving internal leads and referrals. For this reason, consistent definitions for leads and lead-related terms was considered for recommendation; however, the overall risk was deemed low.

3.1.2 Communication strategies that were developed and integrated into a work plan were partially implemented.

The Leads Section was working with its partners in the Strategic Program Communications Division of the Public Affairs Branch to conduct public opinion research and to update external communications in order to develop strategies to improve the quality of leads and communications with taxpayers. During the pandemic, as part of the business resumption plan, the Leads Section and their partners in the Public Affairs Branch updated the CRA’s website to reflect the intake of leads related to COVID-19 benefits and the information tipsters should provide. The Leads Program had external media and social media campaigns planned in collaboration with the Public Affairs Branch, but temporarily postponed the proactive campaigns as the Leads Program was already getting substantial media attention from June 2020 onwards.

The Public Affairs Branch and external service providers on behalf of the CRA have conducted research to study the impact of leads and perceptions of the public. Based on qualitative research, which showed low awareness of the Leads Program by the public, a draft communication work plan was developed in 2017. From 2017 to 2019, the Public Affairs Branch developed and released several of the communications “products” outlined in this work plan. This roll-out included the launch of a new campaign page dedicated to informing Canadians about the Leads Program, and the development of messaging used to respond to enquiries by media and social media users. Due to the COVID pandemic, several tactics in the communication work plan were put on hold. The work plan originally outlined five objectives:

• to highlight the benefits of the Leads Program for all Canadians and encourage greater public participation in the program
• to increase the viability of leads submitted to the CRA
• to appeal to Canadians’ values for fairness in promoting tax compliance and addressing benefit fraud
• to drive Canadians to the Leads website and encourage them to submit a quality lead online
• to engage with stakeholders and help them relay Leads program messages ^{Footnote 1}

Since the communication work plan objectives directly address the issue of low Leads Program awareness, resuming communications efforts should result in coordinated and strategic communication to the public.

Recommendation 1

The Compliance Programs Branch, in collaboration with the Public Affairs Branch, should update the communication work plan for the Leads Program.

Action Plan 1

The Compliance Programs Branch recognizes that, despite a marked increase in media attention and a heightened awareness of the Leads Program since the introduction of COVID-19 relief measures, a consistent and strategic communications approach should be adopted for the Leads Program.

The Leads Section in the Compliance Programs Branch, in collaboration with the Public Affairs Branch, will update the communications work plan to adopt a balanced and proactive communications approach for the Leads Program. Its implementation will take into account the current awareness of the program and leverage other related external communications efforts, while paying close attention to the ever-challenging climate resulting from COVID-19 relief measures and their impact on the Leads Program.

The work plan will include measures to continue raising awareness of the Leads Program, as well as, enabling the submission of high quality, actionable leads.

The target completion date for this action plan is March 2022.

3.1.3 Analysis, prioritization, and routing procedures are inconsistently applied at the National Leads Centre.

Internal and external leads are received and processed by many programs in the CRA. Each program has their own internal leads intake procedures that can differ from each other. Review, analysis, and routing procedures for internal and external leads are documented in the National Leads Centre procedures manual. Outside of the National Leads Centre, the review and analysis of internal and external leads is usually conducted by the workload development sections of their respective programs and completed in accordance with documented procedures.

Leads are split into priority groups and are processed based on their priority level at the National Leads Centre and other program areas. Currently, leads related to COVID-19 benefits are deemed a priority and processed according to documented procedures.

The internal audit team conducted a statistically valid review of 385 randomly selected leads from the leads repository for fiscal year 2020 to 2021. The review of leads from the leads repository found errors such as missed opportunities for secondary routing, misdirected leads, and adequate information treated as inadequate, resulting in leads not being transferred to programs.

The sample used in the lead file review involved the time during the COVID-19 pandemic. Since the introduction of COVID-19 relief measures, the Leads Program saw a significant increase in volume of leads and needed to shift operations to handle the high volumes quickly during these unprecedented times. The National Leads Centre operation had to quickly adapt and change to meet the challenges.

Internal audit found that prior to the COVID-19 pandemic, the quality review function was being conducted by Designated Leads Officers at the National Leads Centre. They reviewed the work of the Leads Intake Officer according to the National Leads Centre procedures manual and provided informal feedback. Quality review activities were restricted in December 2019, in order to focus on priorities and later to manage the Designated Leads Officer inventory during the pandemic.

The Leads Section advised that they consulted with the National Leads Centre and drafted a Leads Program Quality Review Framework and Quality Standards with a planned pilot in the third and fourth quarters of fiscal year 2021 to 2022, pending approval. The planned Leads Program Quality Review Framework contains formal reporting and feedback mechanisms.

The internal audit team confirmed that there were no quality assurance processes or criteria specific to leads being applied by the receiving programs reviewed by Internal Audit. Files or accounts generated by leads were processed and subject to review as regular workload by these programs.

Overall, the leads processing issues, as previously mentioned, could indicate that procedures are inconsistently and incorrectly applied or misunderstood.

In regards to recording and tracking leads, the National Leads Centre documents leads in the leads repository. Programs have different leads tracking sheets and tasking lists for both internal and external leads, which are kept on their Headquarters’ shared drive. The Leads Section monitors the processing and timeliness of leads sent to receiving programs on a regular basis and no major issues concerning timeliness or tracking were identified by the internal audit team. Receiving programs also appear to be addressing leads in a timely manner and actively monitor their leads inventory.

Recommendation 2

The Compliance Programs Branch should implement a formal Quality Review Program that ensures leads review and analysis processes are being conducted consistently at the National Leads Centre.

Action Plan 2

In recognizing the need for a formal Quality Review Program, the Leads Section in the Compliance Programs Branch created the Quality Review Framework and Quality Standards to initiate the formal Quality Review Program with the following goals:

• ensure that the National Leads Centre processes leads according to established procedures and quality standards;
• identify training and learning needs, best practices, emerging trends, and opportunities where policies and procedures can be further refined to improve overall program delivery;
• improve quality and consistency of information provided to other CRA programs to better serve the client programs; and,
• provide management with assurance that quality standards are being met.

The Quality Review Framework contains formal reporting and feedback mechanisms.

Prior to full implementation of the regular Quality Review Cycle, the Leads Section will run a Quality Review Pilot in the third and fourth quarters of 2021 to 2022.

Following completion of the pilot, the Leads Section will fully implement the formal Quality Review Program by the end of 2022 to 2023 to ensure that leads review and analysis processes are being conducted consistently at the National Leads Centre.

The target completion date for this action plan is March 2023.

3.1.4 There is no consistent process to ensure that auditors, examiners, and officers identify internal leads.

During the course of their regular duties, CRA employees create internal leads when they have identified a taxpayer’s potential non-compliant behaviour. Internal leads pass on information about potential non-compliant activities from one section or program to another that could have otherwise gone unnoticed.

Internal leads are received and processed by many programs in the CRA. Each program has its own internal leads intake procedures that can differ between programs. These internal procedures are documented and communicated to staff. The internal audit team found that most programs process internal leads received directly in their respective general mailboxes, and document leads in Excel spreadsheets saved on a Headquarters shared drive These leads are usually reviewed and triaged by a workload development team.

Alternatively, some auditors, examiners, and officers develop internal leads and send them to the National Leads Centre. Between March 31, 2020, and December 31, 2020, 793 internal leads were sent to the National Leads Centre.

Interviewees across several programs have shared that quality internal leads take a significant amount of time to compile and write. No specific timecode is allocated to internal leads, and time used is buried in the file they are working on. Additionally, they stated that not having time or a specific timecode deters auditors, examiners, and officers from submitting leads or taking the time to provide adequate information in the internal lead. Furthermore, staff expressed concern that they were unaware of where to send their internal leads or how to direct the lead to the intended program since there is no centralized information on where to direct leads for specific programs.

Recommendation 3

Processes should be developed to promote the sharing of internal leads information between different programs in the CRA.

Action Plan 3

All impacted Branches are in agreement with the recommendation that processes should be developed to promote the sharing of internal leads information between programs within the CRA.

Currently, there are two main ways for CRA employees to submit internal leads, either directly to the receiving program, or to the National Leads Centre. The Leads Section in the Compliance Programs Branch provides clear direction on how to submit internal leads to the National Leads Centre on its InfoZone page.

The Leads Section has developed a training product on what constitutes a quality lead. In collaboration with impacted Branches, the Leads Section will further refine the training product, along with reviewing the processes and procedures to ensure that internal leads are captured within the leads repository and that the information is shared between programs. Capturing internal leads data within the repository will allow for better tracking and inventory management.

The Leads Section will continue to engage stakeholder branches to leverage opportunities to further promote the sharing of internal leads information and will partner with impacted programs to ensure increased awareness and education of existing internal lead submission mechanisms available to the staff.

The target completion date for this action plan is March 2023.

3.2.Business intelligence and workload development

3.2.1 Business intelligence and data analytics are rarely used by the CRA’s programs to analyze internal and external leads in order to improve tax and benefits compliance strategies.

The Leads Section has attempted to conduct data analytics on leads results, but receiving programs are inconsistently updating the leads repository with acceptance and rejection outcomes and resulting case number identification. The current leads repository holds much of its information in text fields, which poses an additional challenge. As a result, the outputs of the analysis are incomplete and unreliable.

Most of the programs interviewed stated that they were not using leads data to conduct analysis or integrating it into their business intelligence.

The migration of the leads repository to Integras system will facilitate with compiling audit results for data analysis. The Leads Section will be able to link leads to screening and audit case results. Still, not all programs use Integras, such as Non-Filer and Benefits Validation and Compliance of the Collections and Verification Branch. A separate plan will be required for those programs to provide results to the Leads Section.

Recent Leads Program business plans included the objective to continue exploring how it can contribute to business intelligence. By doing so, the Leads Program would also be supporting CRA operations and objectives.

Recommendation 4

The Compliance Programs Branch should create a plan or framework to incorporate leads data into data analysis and business intelligence.

Action Plan 4

The Leads Section, in collaboration with stakeholder programs, has explored and will continue to explore ways to further incorporate leads data into data analysis and business intelligence.

Given the system limitations of the leads repository including various challenges of conducting data analytics on leads results and certain leads data, the Leads Program is in the process of migrating to Integras. The Leads Section expects the migration to Integras in 2022 to 2023 will enable more robust use of data analytics to obtain leads results and identify potential trends or issues from leads data.

The Leads Section will continue to engage Business Intelligence sections and workload development areas to explore opportunities for further use of leads data in data analysis and business intelligence and create a plan by the end of fiscal year 2023 to 2024.

The target completion date for this action plan is March 2024.

3.2.2 Receiving programs are inconsistent in allowing internal leads information to be included in accepted leads cases under development.

The internal audit team confirmed that leads are reviewed by workload development areas within programs based on their documented procedures. Workload development areas also apply risk assessments to leads and assess them for materiality. Apart from the Compliance Programs Branch’s Business Intelligence and Quality Assurance, some programs that were reviewed as part of this internal audit did not explain their risk assessment process in detail and could benefit from more precision in their documented procedures.

The internal audit team also heard from the programs they interviewed that once leads are reviewed and analyzed by the workload development area, the notations on the files or screener’s packages concerning the leads are inconsistent within and between programs. This inconsistency is particularly problematic because employees may not be aware that a case is based on information from a lead or that information is not made available. This results in ineffective practices and possibly lost intelligence from the leads submitted.

The inconsistent practices among programs are due to their interpretation of the Privacy Act. Programs that choose not to include information or notations about leads stated that it was omitted in order to protect the identity of tipsters.

The Privacy Impact Assessment for the Leads Program was reviewed by the internal audit team, and it stated that the level of risk to privacy when leads information is shared within or among programs is 1—the lowest level.

Recommendation 5

Consistent policies should be developed concerning the handling and sharing of internal and external leads information between programs in the CRA.

Action Plan 5

All impacted Branches are in agreement with the recommendation that consistent policies should be developed concerning the handling and sharing of both internal and external leads information between programs within the CRA.

The Leads Section already has robust processes and procedures in place to ensure that the identity of the tipster is protected for external leads and likewise that confidential third party information is protected for internal leads.

The Leads Section will perform extensive outreach and education in collaboration with all impacted program partners to review and update existing procedures, as required, to ensure consistency across CRA on the proper handling of protected and confidential lead information.

The Leads Section will continue to communicate the importance of consistent lead handling procedures. Verification will be performed throughout the fiscal year to ensure partners are compliant with existing program procedures.

The target completion date for this action plan is March 2023.

3.2.3 Due to current policies and practices, there is no formal process to communicate outcomes of leads by the receiving programs, resulting in a performance feedback gap.

The internal audit team found documentary evidence to indicate that a high level of collaboration and communication occurs between the National Leads Centre, the Leads Section, and the receiving programs. However, lead acceptance or rejection outcomes are inconsistently reported back to the Leads Program by the workload development areas of receiving programs. The programs advised that time constraints and lack of resources limited leads screeners from providing complete results.

Receiving programs find it difficult to provide specific feedback on leads cases at the section and divisional levels because the performance results of lead cases are usually amalgamated with the results of non-lead-based cases. This is done intentionally to respect the privacy of tipsters. Historically, programs have not reported on internal leads.

The internal audit team was advised that programs can provide feedback to individual officers on their performance on leads-based cases, although the officer might not know the case is leads related due to privacy reasons.

Recommendation 6

The workload development areas of receiving programs should follow procedures to report the actions they take on leads to the National Leads Centre.

See recommendation in 3.3.1 below.

Action Plan 6

All impacted Branches are in agreement with the recommendation that workload development areas who are in receipt of leads should follow documented procedures and mechanisms to report the actions they take on leads to the National Leads Centre.

The Leads Section, in consultation with stakeholder programs, developed procedures for the receiving programs to report the actions they take on leads sent by the National Leads Centre. The Leads Section routinely monitors the progress made by the receiving programs and reports the results to senior management on a quarterly basis.

With the migration to Integras in spring 2022, the Leads Section will be able to improve the routing and tracking of leads within Integras to partner programs. There will continue to be some manual processes for those stakeholder programs who have a different case management system and the Leads Section remains committed to working with partner programs to ensure that an appropriate feedback loop is implemented.

CRA workload development areas will be required to follow procedures to report the actions they take on leads sent by the National Leads Centre to ensure respective compliance results can be properly monitored and reported by the Leads Section.

The Leads Section will perform verifications to ensure that proper existing program procedures are being followed by program partners.

The target completion date for this action plan is March 2023.

3.3. Performance measurement

3.3.1 Although, performance measures are in place at the National Leads Centre, the overall impact and value of pursuing leads are not measured by the CRA.

The National Leads Centre measures performance impacts of some internal and external leads: the acceptance and rejection rates of leads and frequency at which leads are misdirected. Performance results are reported and shared with senior management. Presently, the Leads Program also reports on the intake volumes and acceptance rates of leads related to COVID-19 benefits.

The impacts of external and internal leads are seldom measured as a specific subset by workload development areas or by the receiving programs. They are included in the overall performance measured for workloads. This is because results from external leads are purposely unidentifiable for privacy reasons. Results from internal leads are not measured, although they are identifiable by the receiving programs. As a result, performance results from leads are unknown. Without a method to assess the performance resulting from internal and external leads, the CRA will not know whether it is worth promoting their importance to Canadians and to encourage staff to develop more internal leads to be used in program workloads.

The acceptance of leads from the National Leads Centre into program workloads varies drastically. Leads acceptance rates can be as low as 5% and as high as 91% depending on the program. The average acceptance rate by receiving programs of leads routed from the National Leads Centre over the last three fiscal years is approximately 67%. There are various reasons for this rate of acceptance, such as the quality of leads and receiving program selection criteria.

Additionally, without measuring leads results, the CRA will not understand their impact on overall compliance and the reputational risk if leads are left unaddressed. This will become an increasingly important issue as the CRA is accountable for compliance actions in regards to COVID-19 benefits fraud.

Recommendation 7

The Compliance Programs Branch should assess the value of all leads and their impact on compliance.

Action Plan 7

Assessing the value of leads and their impact on compliance is important. To this end, the Leads Section in the Compliance Programs Branch measures and reports performance impacts of the internal and external leads the program receives. Especially, leads related to COVID-19 benefits and subsidies received by the Leads Program are processed and reviewed by programs on a priority basis, and the review results are closely monitored and reported by the Leads Program.

When leads are accepted by programs, the relevant case numbers provided by the programs are monitored by the Leads Program. The compliance results from these cases can be incorporated into the regular reporting when sufficient data is available and the stakeholder programs agree that compliance results are relevant to leads.

The Leads Section will continue to engage stakeholder programs to find ways to further assess the value of leads and their impact on compliance.

The target completion date for this action plan is March 2024.

4. Conclusion

The internal audit’s objective was to determine whether controls are in place and working as intended for the CRA’s current method of obtaining, analyzing, and resolving internal and external leads.

Leads are being reviewed and processed according to documented procedures within the CRA. Leads are an invaluable source of information for some programs and are rarely used by others. This internal audit found that the results of leads are not measured and reported across CRA programs. The value of leads is currently unknown, along with the impact on non-compliance and the CRA’s reputation when leads are not actioned.

There are some gaps in reporting outcomes back to the National Leads Centre. The Leads Program hopes to remedy these by improving its reporting capabilities as it migrates the leads repository onto the Integras system. Although there are also some quality and consistency issues with the analysis and processing of leads at the National Leads Centre, there is clear and consistent effort by the Leads Section to remedy or improve upon the existing issues.

5. Acknowledgement

In closing, we would like to acknowledge and thank the Assessment, Benefit, and Service Branch, the Collections and Verification Branch, the Compliance Programs Branch, the Legislative Policy and Regulatory Affairs Branch, the Public Affairs Branch, and the Service, Innovation and Integration Branch for the time dedicated and the information provided during the course of this engagement.

6. Appendices

Appendix A: Audit criteria and methodology

Methodology

The methodology for examination included the following:

• Data analysis: The Internal Audit team used data analysis to identify and understand trends within the external and internal leads workloads. The Internal Audit team also reviewed program statistics for trends in performance reporting where available.
• Documentation and file review: The Internal Audit team tested controls through documentation and lead reviews to verify that leads were created, reviewed, and referred according to documented processes and procedures and that they were completed efficiently and effectively.
• Internal interviews: The Internal Audit team interviewed management and staff at Headquarters and in the Ontario and Western regions to confirm adherence to guidance documentation.

Appendix B: Glossary