Evaluation of the Grant to Compensate Members of the RCMP for Injuries Received in the Performance of their Duties - Full Report

July 19, 2019

Table of contents

• Acronyms/Definitions
• Executive Summary
  • Introduction
  • Program Profile
  • What we examined
  • What we found
• 1.0 Introduction
  • 1.1 Purpose of the Evaluation
  • 1.2 Evaluation Scope and Context
• 2.0 Evaluation Methodology
  • 2.1 Evaluation Approach and Design
  • 2.2 Data Sources
  • 2.3 Considerations and Limitations
• 3.0 Program Overview
  • 3.1 Program Description
  • 3.2 Program Profile and Funding
• 4.0 Findings
  • 4.1 Relevance
  • 4.2 Performance – Efficiency and Economy
• 5.0 Conclusions and Recommendations
• 6.0 Management Response and Action Plan
  • 6.1 Management Response
  • 6.2 Action Plan for CHRO
• End Notes

Acronyms/Definitions

ARLU

Annual Reference Level Updates

CHRO

Chief Human Resources Officer

FAA

Financial Administration Act

LO

Liaison Officer

MOU

Memorandum of Understanding

OSI

Operational Stress Injury

OSFI

Office of the Superintendent of Financial Institutions

PTSD

Post Traumatic Stress Disorder

PMEC

Performance Measurement and Evaluation Committee

RCMP

Royal Canadian Mounted Police

RCMPPCA

Royal Canadian Mounted Police Pension Continuation Act

RCMPSA

Royal Canadian Mounted Police Superannuation Act

VAC

Veterans Affairs Canada

VRAB

Veterans Review and Appeal Board

Executive Summary

Introduction

This report presents the results of the Evaluation of the Grant to Compensate Members of the RCMP for Injuries Received in the Performance of Their Duties conducted by National Program Evaluation Services of the Royal Canadian Mounted Police (RCMP) in 2018-19.

Program Profile

The Grant to Compensate Members of the RCMP for Injuries Received in the Performance of Their Duties is a quasi-statutory payment program introduced in 1959. The objective of the grant is to provide financial and health care assistance to members of the RCMP and their families in the event of a service-related death and/or injuries/illness leading to a loss of quality of life. The RCMP is responsible for providing approved health care benefits to current and former members who became entitled to an award due to injury or death pursuant to Part II of the RCMP Superannuation Act.

Regular and civilian members of the RCMP (and their surviving dependents) apply for a Disability Pension through Veterans Affairs Canada (VAC) who are responsible for the adjudication of claims in accordance with the Pension Act for any permanent work-related illness, injury or death. Since VAC does not have the legislative authority to provide pension awards to eligible civilian and regular members, the RCMP transfers funds to VAC for the cost of Disability Pensions and Special Awards to RCMP members by the way of an Interdepartmental Settlement. The funds of the Grant are transferred to VAC for administration, management, and disbursement of funds.

RCMP internal responsibilities of the Grant are shared between various directorates under the authority of the Chief Human Resources Officer (CHRO).

During fiscal year 2017-18, RCMP Disability Pension and Special Award expenditures were $212.9 million; an increase of 15% from $185.5 million in 2016-17. There has been a 31% increase in RCMP Disability Pension recipients from 2012-13 to 2017-18, an increase on average of 6% in each of the past five years. As of March 2018, there were 14,656 RCMP Disability Pension clients of which 13,570 were regular and civilian members and 1,086 were survivors.^{Footnote 1}

What we examined

The objective of the evaluation is to provide a neutral, timely and evidence-based assessment of the relevance and performance of the Grant from April 1, 2013 to March 31, 2018. The following evaluation questions were examined:

1. Is there a continued need for the Grant?
2. Is the objective of the Grant consistent with departmental and government-wide priorities?
3. Are the roles and responsibilities of the RCMP and VAC clearly defined and understood?
4. To what extent is the Grant achieving its goal?
5. Are delivery and payments of disability pensions and special allowances to RCMP clients satisfactory and in accordance with established service standards?
6. What are the oversight and reporting mechanisms in place for the Grant?
7. Does the current transfer mechanism support the timely, cost effective, and efficient transfer of funds to VAC?

The Grant was previously evaluated in 2013-14. The following recommendations were made:

1. Roles, authorities and responsibilities of RCMP Human Resources policy centers involved in the administration and management of the Grant need to be articulated and clarified to allow for better internal oversight, meaningful involvement and enhanced opportunities to provide input in development of VAC disability policies and processes that impact RCMP clients
2. The RCMP must leverage VAC information and complete analysis to develop an understanding of disability data, key causes of disability conditions as well as age and gender effect on work related injuries that cause disability.

What we found

1. There continues to be a significant and increasing need for the Grant to compensate regular and civilian members of the RCMP and their survivors for injuries received in the performance of their duties.
2. The objectives of the Grant are aligned with RCMP and the Government of Canada's strategic outcomes and legislative authorities.
3. Overall roles and responsibilities between the RCMP and VAC are clearly defined. However, communication and information-sharing were lacking in key areas and the Grant's governance was not clearly articulated.
4. The Grant is achieving its goal to provide financial assistance to RCMP members and their survivors in the event of injuries/illness and/or death occurring while on duty; however, the timeliness of services to RCMP clients decreased over the period of review.
5. Internal controls and reporting mechanisms were in place for the delivery of the Grant. While data is collected by VAC, its use by the RCMP could be further explored.
6. The current transfer mechanism is timely, cost-effective and efficient. No other viable alternatives were identified.

Based on the findings of the evaluation, it is recommended that the Chief Human Resources Officer (CHRO):

1. Develop an internal governance model that clearly outlines the involvement of RCMP branches/directorates in the administration and management of the Grant.
2. Enhance consultations between partners involved in the Grant to mitigate information gaps and inform decision making.
3. In addition to the efforts taken as a result of the recommendation from the 2013-14 evaluation, further explore the use of available VAC data to identify emerging areas of risk and support the prioritization and development of injury prevention measures.

1.0 Introduction

1.1 Purpose of the Evaluation

This report presents the results of the Evaluation of the Grant to Compensate Members of the RCMP for Injuries Received in the Performance of Their Duties conducted by National Program Evaluation Services of the Royal Canadian Mounted Police (RCMP) in 2018-19. The evaluation was conducted in compliance with the Section 42.1 of the Financial Administration Act that requires all ongoing programs of grants and contributions to be evaluated every five years. The objective of the evaluation was to provide a neutral, timely and evidence-based assessment of the Grant.

The evaluation commenced in September 2018 and concluded in July 2019 with a presentation to the RCMP Performance Measurement and Evaluation Committee (PMEC). The report received the Commissioner's approval on August 7, 2019.

1.2 Evaluation Scope and Context

The evaluation focused on the relevance and performance of the Grant against its stated objective to provide financial and health care assistance to regular and civilian members of the RCMP and their families in the event of illness or death occurring as a consequence of their duties. The scope of the evaluation covered the five-year period from April 1, 2013 to March 31, 2018.

The evaluation assessed:

1. Relevance of the Grant:
   • A continued need for the Grant
   • The alignment of the Grant with departmental and government-wide priorities
   • Alignment and clarity of roles and responsibilities as they pertain to the Grant
2. Performance of the Grant in terms of:
   • Effectiveness:
     • The extent to which the Grant is achieving its stated goal
     • Whether compensation claims and payments of disability pensions and special allowances to RCMP clients are administered within established service standards
     • Whether RCMP clients receiving disability pensions are satisfied with the VAC services received
     • Oversight and reporting mechanisms in place for the Grant
   • Efficiency:
     • Whether current transfer mechanism supports the timely, cost effective, and efficient transfer of funds to VAC.

The evaluation was undertaken in line with the Treasury Board Policy on Results (2016), which requires departments to measure and evaluate performance, using the resulting information to manage and improve programs, policies and services.

Previous Evaluation

The previous evaluation completed in 2014 found that there was a significant and increasing need for the Grant and that it was achieving its objective. It also found that VAC services were conducted according to policy; however, RCMP internal governance needed to be better defined and communicated. In addition it noted that the RCMP would benefit by making better use of disability pension related information and reports produced by VAC. The Program responded to the recommendations by completing and communicating a VAC/RCMP disability management business process map to all stakeholders. It also initiated and conducted an annual analysis of VAC data on the top 10 RCMP disability conditions to improve the prevention of work related injuries and communicated the analysis through the RCMP Occupational Health and Safety Annual Performance Reports.

2.0 Evaluation Methodology

2.1 Evaluation Approach and Design

A theory-based approach was used for this evaluation. NPES applied triangulation as an analytical method, where multiple lines of evidence helped corroborate findings. The objective of the evaluation was to assess the relevance and performance of the Grant to compensate members of the RCMP for injuries received in the performance of their duties. Qualitative and quantitative information was utilized to inform findings, to provide recommendations for improvement, and to help inform senior management decision-making.

2.2 Data Sources

The following lines of evidence were used to determine the findings and recommendations:

1. Document Review: Internal and external documents, such as foundational documents, performance related reports, previous assessments, operational documents and policies, were reviewed and analyzed. Secondary research was also reviewed to gather contextual information about the Grant and to inform evaluation questions. The review of secondary research and documentation from VAC was used given that the entire Grant is transferred to VAC for administration, management, and disbursement of funds.
2. Key Informant Interviews: A total of nine interviews were conducted with RCMP (n=7) and VAC (n=2) personnel involved with the administration of the Grant.
3. Data Analysis: Administrative, financial and performance measurement data from both RCMP and VAC was analyzed to create a profile of RCMP clients and inform the evaluation about the Grant's relevance and performance. Secondary analysis of VAC client surveys were reviewed to profile opinions and satisfaction of RCMP clients regarding VAC services.

2.3 Considerations and Limitations

A key consideration of the evaluation was to evaluate the role of the RCMP relating to the Grant, which is to administer the transfer of funds to VAC. It was beyond the scope of this evaluation to examine the qualifying criteria, processing, adjudication, and administration and management practices at VAC.

Health care benefits administered by VAC to all former RCMP regular member disability pensioners and both serving and former RCMP civilian disability pensioners are not funded by the grant and therefore were not included in the scope of the evaluation.

The evaluation also relied on the secondary research and documentation obtained from VAC. The RCMP was not able to independently assess the validity of the data.

Furthermore, RCMP disability benefit client figures presented in this report are not comparable to other reported RCMP figures such as those in the annually published VAC Facts and Figures (F&F) Book. This is due to the F&F using a service hierarchy, which may result in RCMP members with military service being reported under a different service category. Additionally, survivor counts may differ between overall RCMP and RCMP Disability Pensioner figures as some RCMP members may be receiving Disability Benefits as a surviving spouse of another RCMP member. As a result, the evaluation relied on the RCMP Demographic Profile data provided by VAC Statistics Directorate to more accurately reflect RCMP clients receiving disability benefits.

In order to mitigate the limitations, the evaluation used multiple lines of evidence, triangulation of data and validation of various directorates involved. National Program Evaluation Services used this approach in order to demonstrate reliability and validity of the findings and to ensure that conclusions and recommendations were based on objective and documented evidence.

3.0 Program Overview

3.1 Program Description

The Grant to compensate members of the RCMP for injuries received in the performance of their duties is a quasi-statutory payment program introduced in 1959. The objective of the grant is to provide financial and health care assistance to members of the RCMP and their families in the event of a service-related death and/or injuries/illness leading to a loss of quality of life.

The RCMP is responsible for providing approved health care benefits to current and former members who become entitled to an award due to injury or death. Part II of the RCMP Superannuation Act and Section 5 of the RCMP Pension Continuation Act provide the authority for a serving or discharged regular or civilian member of the RCMP who becomes permanently disabled as a result of, or through aggravation of, a duty-related illness or injury, to apply for Pension Act benefits.

In 2002, Veterans Affairs Canada (VAC) assumed full responsibility for the adjudication, calculation of benefits, and provision of disability pensions to all eligible RCMP clients. VAC provides disability pensions to four types of clients: veterans of the Second World War and/or the Korean War; civilians who served in close support of the Armed Forces during wartime; Canadian Forces (CF) members and veterans; and current and former members of the RCMP and their survivors.

A serving and/or former member of the RCMP may be eligible for Disability Pension benefits from VAC if he/she has or later developed a permanent disability resulting from an injury or disease that:

• arose out of, was directly connected with, or was aggravated by RCMP service
• was in whole or in part a consequence of the injury or the disease or was aggravated by the disease or illness
• was attributable to, incurred during, or aggravated by service in a Special Duty Area or Special Duty Operation

Regular and civilian members of the RCMP (and their surviving dependents) apply for a Disability Pension through VAC in accordance with the Pension Act for any permanent work-related illness, injury or death. Since VAC does not have the legislative authority to provide pension awards to eligible civilian and regular members, the RCMP pays VAC for the cost of Disability Pensions and Special Awards to RCMP members by the way of the Grant. The transfer of funds is done by way of an Interdepartmental Settlement.^{Footnote 2 Footnote 3}

The expenditures of the Grant also include tax-free monthly allowances to eligible serving and former regular and civilian RCMP members in the form of three types of Special Allowances:

1. Exceptional Incapacity Allowance. Members may qualify for this allowance if they have a disability pension for condition(s) that total 98% or have a combination of a disability pension and a disability award/pain and suffering compensation for conditions that total 98% or more and have an exceptional incapacity that is a result of, in whole or in part, the condition(s) for which they are receiving a disability benefit.
2. Attendance Allowance. Members may qualify for the allowance if they have a disability pension of 1% or more, are totally disabled, and need assistance with activities of daily living.
3. Clothing Allowance. Members may qualify for an allowance if they are receiving a disability pension/award or pain and suffering compensation assessed at 1% or more for a condition that causes wear and tear on their clothing or requires them to wear specially made clothing.

Serving or former regular and civilian RCMP members may be eligible to receive other VAC health services and benefits. Provisions of these benefits is not funded by the Grant and is outside the scope of this evaluation.

3.2 Program Profile and Funding

The RCMP transfers funds to VAC for the cost of Disability Pension and Special Awards by way of an Interdepartmental Settlement.^{Footnote 4} The entire Grant is transferred to VAC for administration, management, and disbursement of funds.

In 2017-18, VAC provided disability pensions to 14, 656 RCMP clients which represented 8% of all Disability Pension clients served by VAC.^{Footnote 5} The number of RCMP Disability Pension recipients has increased by 31% from 11,218 in 2013-14 to 14,656 in 2017-18, an average increase of 6% in each of the past five years.^{Footnote 6} 93% of disability pension recipients are current or former RCMP regular and civilian members and 7% are survivors and dependants (Table 1). The ratio of disability pension recipients has remained constant since 2009.

This Grant represents over 92% of the RCMP's grants and contributions as of 2017-18.^{Footnote 7} Grant expenditures increased from $132.1 million in 2013-2014 to $212.9 million in 2017-2018, a 61% increase. In 2017-18, 96% ($205.2 million) of the Grant's dollars were spent to pay disability pensions to current and former members, and survivors, and the remaining 4% ($7.7 million) were spent on the payment of special awards (Table 1).

Table 1: RCMP Disability Pension and Special Awards Expenditures for RCMP Clients

In 2017-18, the majority (9,473) of RCMP regular and civilian members receiving a disability pension were released (or former) members and 4,097 individuals were still serving (Graph 1). While the number of RCMP Disability Pension recipients increased year over year, the ratio of released to still serving recipients has remained consistent since 2012-13 (70% released; 30% still serving). Over the five year period of this evaluation, the number of disability pension recipients among the released regular and civilian members has grown at a rate of 40% compared to currently serving members at a rate of 26%. The rate of growth of released members has accelerated by 8% since the previous evaluation in 2012-13, which had a five-year growth rate of released members at 32%, while still serving members were relatively the same at 27%.^{Footnote 9}

As of March 2018, the average age of a still serving member receiving a disability pension is 48 years old and the average age of a released member is 66 years old.^{Footnote 11} Since March 2013, the largest age segment of still serving members receiving a disability pension is less than 45 years old. In 2017-18, this age segment constituted 37% of still serving members receiving a disability pension.

In 2017-18, females constituted 13% of the former and current RCMP regular and civilian members receiving a disability pension,^{Footnote 12} a gradual increase from 8% in 2008. Although RCMP disability pension clients have been predominantly male (2017-18 – 87%), female clients have been growing at a faster rate (63%) compared to male clients (26%) over the five-year period of 2013-14 to 2017-18 (Table 2).

Table 2: Age and Gender of RCMP regular and civilian members in receipt of a Disability Pension

4.0 Findings

4.1 Relevance

All lines of evidence suggest an increasing need for the Grant to compensate RCMP regular and civilian members and their survivors for injuries received in the performance of their duties. The number of RCMP clients and level of compensation have increased steadily during the period of this evaluation. Program documentation illustrated that over the last five years, the number of RCMP clients has increased by 31% while the cost of the Grant increased by 61% from $132.1 million to $212.9 million. The increase in the client base and the cost of the Grant have been on a similar trajectory since 2008-09, which is primarily due to new entrants^{Footnote 13} and to a lesser extent changes in disability class^{Footnote 14} and indexation of benefits.^{Footnote 15}

The average annual cost of a disability pension for an RCMP regular/civilian member has increased from $11,084 in 2013-14 to $13, 717 in 2017-18.^{Footnote 16}

Since 2013, the top three conditions for which RCMP male clients qualified to receive a disability pension have been hearing loss, tinnitus, and Post Traumatic Stress Disorder (PTSD).^{Footnote 17} The top three disability conditions for female clients include PTSD, Lumbar Disc Disease, and Depressive Disorder. The most frequent conditions for both male and female clients remained consistent over the last ten years.

Between 2013 and 2018, conditions such as Osteoarthritis Knee, PTSD, and tinnitus increased by more than 50%. During this same time period, PTSD continues to be the most prominent medical condition among serving members, while hearing loss is the most prominent medical condition among released members. As of March 31, 2018, 5,107 RCMP regular and civilian members were receiving disability pensions for mental health conditions, including PTSD.^{Footnote 18} This accounts for 35% of all RCMP disability pensioners, veterans and survivors.

Almost all interviewees (8/9) agreed there is an ongoing need for the Grant to ensure there is financial security for members who were disabled as a result of their work, and that legislative requirements continue to be adhered to by the organization. Additionally, interviewees spoke about the need for the RCMP to remain involved in an oversight capacity to ensure that the RCMP's unique interests are being considered and addressed, and to have access to data/information from VAC to inform decisions on improving safety for members.

VAC and RCMP forecasts suggest that the number of RCMP regular and civilian members and their survivors receiving a disability pension will continue to grow. The number of RCMP clients is forecasted to increase 5% in 2018-19 and continue to increase at about 6% per year over the next five years to reach approximately 18,700 by 2022-23 (Graph 2).^{Footnote 19}

Similarly, within five years, the Grant's annual expenditures are expected to increase more than twofold from $212 million to $482 million (Graph 3). The actual expenditures increased by 61% from 2013-14 to 2017-18, at a historical five year average of 12.5% ($18.9 million).^{Footnote 20} Expenditures are expected to increase by 82% between 2018-19 and 2022-23, at a forecasted year over year average of 18% ($54 million).^{Footnote 21}

The Grant is aligned with the RCMP Strategic Outcome "Incomes are secured for RCMP members and their survivors affected by disability or death" and with the Government of Canada high level outcome "Income security and employment for Canadians". This Program ensures that RCMP employees and their families are provided income security, and that an appropriate level of support is afforded to those who are affected by circumstances beyond their control and as a result of their employment with the RCMP.

The Grant also contributes to the RCMP's mandate related to the protection of members in the event they become disabled as a result of carrying out their duties associated with ensuring a safe and secure Canada.^{Footnote 22}

In addition, the Grant continues to align with legislative and regulatory authorities of the RCMP as per Part II of the RCMP Superannuation Act. The adjudication, calculation and payment of disability pensions for RCMP clients are conducted in accordance with the Pension Act, and compensation provided in accordance to Part I of the RCMP Pension Continuation Act (RCMPPCA).^{Footnote 23}

The majority of interviewees (6/9) also recognized the RCMP's involvement in the Grant as an obligation to continue to meet legislative and transfer payment requirements that provide compensation to members and their survivors in the event of injury and/or death as a result of carrying out their duties.

Internal responsibility for the Grant has been shared between various RCMP directorates and falls under the authority of the CHRO. At the time of the evaluation, there were three main directorates directly involved in the financial administration, management and reporting and to a lesser extent a fourth directorate involved in reporting.

1. National Compensation Services: is responsible for the functional supervision and support of the RCMP Liaison Officer. Prior to April 2016, this position was under the responsibility of Occupational Health and Safety.
2. Financial Management: is responsible for determining and adjusting the funding needed for the Grant based on the estimates received by VAC and the Office of the Superintendent of Financial Institutions (OSFI) and then submitting Supplemental Estimates. In addition, Financial Management is responsible for seeking funding for the Grant from Treasury Board of Canada.
3. Corporate Accounting: is responsible for entering the Grant into the financial system, assuring that financial transactions between VAC and the RCMP are recorded, and that amounts receivable and overpayments are reported in Public Accounts.
4. Workplace Safety, Health and Well-Being: is responsible for the tri-annual occupational health and safety reports pursuant to the Canadian Occupational Health and Safety Regulations and annual divisional report cards.

An Executive Liaison Officer position was created in 2018 to further support members regarding the availability of VAC benefits and to strengthen the relationship and communication between VAC and the RCMP.

The overall roles and responsibilities of the RCMP and VAC in regard to the transfer and the administration functions are clearly defined in the 2002 and 2018 Memoranda of Understanding (MOU) as well as in the accompanying appendices.^{Footnote 24} The RCMP is responsible for providing approved health care benefits to current and former members who became entitled to those benefits. It also specifies that the RCMP transfer the responsibilities of administration, adjudication and payments of awards and health care benefits to VAC. The RCMP transfers funds to VAC for the cost of a Disability Pension through an Interdepartmental Settlement, and an annual reimbursement for the provision/administration of services provided to RCMP clients.^{Footnote 25}

According to an internal RCMP assessment, a deficiency existed in the 2002 MOU in relation to defining the roles and responsibilities for financial administration. The deficiency is currently being addressed through a joint working group between VAC and the RCMP seeking to create the required legislated authorities.

While the majority of interviewees (6/8) reported that their individual (directorate) roles and responsibilities were clear, more than half (5/8) nuanced this response by identifying two significant issues:

1. A lack of communication and information-sharing relating to service delivery changes. For example, unanticipated service delivery changes were not consistently communicated, which created challenges in securing funds and developing forecasts.
2. A lack of internal documentation outlining the governance and roles and responsibilities relating to the Grant.

As was previously noted in the 2013-14 evaluation, the 2018-19 evaluation found that the Grant's governance was not articulated in program documentation, including the specific roles and responsibilities of the various directorates involved.

4.2 Performance – Efficiency and Economy

All interviewees agree that the Grant is achieving its goal to provide financial assistance to RCMP members and their families. Half of those interviewees particularly stated that the Grant is meeting its goal in terms of securing and transferring funds to pay for the disability pensions.

RCMP clients are accessing the Grant in increasing numbers each year and the vast majority of claims were found favourable. As previously noted, the number of disability pension recipients increased from 11, 218 in 2013-14 to 14, 656 in 2017-18. Analysis of administrative data shows that 88% of first applications decisions for the RCMP applicants are favourable (Table 3) compared to 71% in 2013-14. In addition, the rate of favourable claims for the RCMP was higher than VAC's overall disability pensioner rate of favourable claims (78%) in 2017-18.

Consistent with the previous evaluation in 2012-13, approximately 200 RCMP applicants per year are required to submit additional documentation supporting their first application for the Departmental Review. In 2017-18, an all-time high of 90% of these reviews were ruled favourable for RCMP applicants. The rate of favourable decisions decreases with the higher level of appeal. In 2017-18, only 37% of Veterans Review and Appeal Board (VRAB) reviews and 24% of VRAB appeals for RCMP applicants were ruled favourably.

Table 3: Rate of Favourable Decision for First Applications by RCMP Applications

The evaluation also examined the opinions of the RCMP clients. Secondary analysis of the 2017 VAC Client Survey noted an area for service delivery improvement, particularly in the area of timeliness in obtaining information and services. For example, 23% of RCMP respondents were dissatisfied or very dissatisfied with the time it takes to obtain information or a service.

Over the five-year period under review, the achievement of service standard targets established by VAC has gradually declined, and targets are currently not being met. Service standard targets for first application decisions (80% to be processed in 16 weeks) decreased from 83% in 2013-14 to 33% in 2017-18 for all VAC disability pension clients. A similar trend can also be observed with the RCMP clients. Within the evaluation time period, VAC saw a 47% increase in RCMP new applications from 2014-15 (1,304) to 2015-16 (1,929) and has remained at approximately 1,856 new applications per year.^{Footnote 26} As observed below, the increase in applications corresponds to a decrease in timeliness and ability to meet service standards (Graph 4).

The percentage of RCMP first applications decisions processed within the 16 week service standard decreased from 55% in 2015-16 to 39% in 2016-17 (Table 5), which is significantly lower than the VAC service standards (80%). In terms of timeliness of payments, in 2016-17, 84% of RCMP first application payments were processed within 7 days of a favourable decision. VAC has remained consistent since 2011-12, with roughly 96% of RCMP first application payments being processed within 14 days of a favourable decision.

Table 5: RCMP First Application Decisions and Payments

Despite the increase in the number of clients and services received, the annual amount transferred from the RCMP to VAC for the provision and administration of services had not increased since 2003-04. To address this gap, an updated MOU in 2018 provided $1.85 million in increased funding from the RCMP to VAC for a total of $2 million annually for services provided to RCMP clients. The increased funding more accurately reflects the work VAC does in support of RCMP clients. The funding is anticipated to increase VAC's capacity to provide services to RCMP clients, reducing backlogs and service delivery delays.

An internal RCMP assessment (2018)^{Footnote 27} found that controls were in place for initiation of expenditures, commitment control and the management of payments. The assessment made recommendations related to ongoing monitoring of the financials associated to the grant to ensure the completeness and accuracy of expenditures. The RCMP's Financial Management directorate implemented these recommendations accordingly.

The internal assessment also identified a deficiency in reporting between VAC and the RCMP regarding the effectiveness of controls related to Sec 34/33 of the Financial Administration Act. The deficiency was addressed by requiring VAC to include a signed letter of attestation to the RCMP providing reasonable assurance of: 1) the effective functioning of its internal controls; and 2) the administration and provision of program services and benefits on behalf of the RCMP.^{Footnote 28}

Interview and document analysis further confirmed that internal controls and reporting mechanisms exist. The RCMP receives monthly VAC reports and annual Actuarial Reports from OSFI. These reports include disability pension expenditures, the number of RCMP clients, and the forecasts of clients and expenditures. On an annual basis, the RCMP also develops forecasts for the Grant for monitoring purposes. Other reporting included ad hoc analysis by the RCMP Liaison Officer (LO) to VAC and a tri-annual RCMP Occupational Health and Safety report.

Conversely, the evaluation found that the RCMP was not using VAC disability data to its full extent. For example, interviewees noted that there is the potential for the RCMP to further leverage VAC data in the development and prioritization of preventative measures for injuries received. The 2013-14 evaluation also recommended the leveraging of VAC disability data. While this recommendation was partially addressed, the evaluation found that there is still room for improvement. Specifically, the planned action completed from the 2013-14 MRAP included an annual analysis of VAC data on the top 10 RCMP disability conditions, which were documented in the RCMP Occupational Health and Safety Annual Performance Reports. However, over the period of the evaluation the RCMP Occupational Health and Safety Performance Reports became less frequent, transitioning from an annual to a tri-annual publication due to resource constraints and competing priorities.

As previously illustrated, the number of RCMP recipients and disability pension expenditures continue to increase annually. In this regard, further analysis of VAC data would support the prioritization efforts of preventative measures based on the occupations that are at most risk and providing linkages to associated pension costs. For example, further analysis on types of conditions and associated pension costs (injury cost breakdown), types of positions held when injury occurred and associated sources of the injury would further support the RCMP's ability to prioritize and develop injury prevention measures.

The majority of interviewees (5/8) agreed that the current transfer mechanism supports timely, cost-effective and efficient transfer of funds to VAC. However, some interviewees mentioned that the least effective and efficient process of the transfer mechanism is forecasting and corporate budgeting (i.e. rationalizing the need for additional funding). These were seen as areas for improvement.

Analysis of financial documentation and RCMP data shows that the transfer payments from the RCMP to VAC for the Grant have been timely. For example, in the past two years, 88% of VAC quarterly advance requests were processed within two business days of the request.

In terms of cost-effectiveness, the current transfer mechanism continues to be highly economical when comparing the administrative fees paid to VAC to the Grant's total expenditure. Since 2003-04, the RCMP has been paying an annual fee $150,000 via a permanent Annual Reference Level Update adjustment.^{Footnote 29} In 2017-18 this fee constituted 0.07% of the Grant's total expenditure.

It was determined that VAC required additional funding to avoid reduced service delivery and backlogs. To address this funding gap, in 2018 the RCMP began paying VAC an additional annual fee of $1.85 million (in addition to the $150,000 annual amount the RCMP permanently transferred to VAC via the Annual Reference Level Update). This new annual fee constitutes 0.9% of the Grant's total expenditure.

Almost all interviewees (4/5) and documentary evidence confirm there are no viable alternative mechanisms that would improve timeliness, cost effectiveness and efficiency for transferring the funds. One interviewee noted that a possible alternative to achieve more timely and efficient transfer of funds is for the Grant to become a statutory program within VAC, but its potential lack of viability was noted.

5.0 Conclusions and Recommendations

The evaluation found that there continues to be a significant and increasing need for the Grant to compensate RCMP regular and civilian members and their survivors for injuries received in the performance of their duties. The number of RCMP clients and level of compensation have increased steadily during the period of this evaluation, with forecasts suggesting the number of RCMP members and their survivors receiving a disability pension will continue to grow.

The Grant is aligned with the RCMP Strategic Outcome "Incomes are secured for RCMP members and their survivors affected by disability or death" and with the Government of Canada high level outcome "Income security and employment for Canadians". It continues to contribute to the expected results of the RCMP and align with legislative and regulatory authorities.

The overall roles and responsibilities of the RCMP and VAC related to the Grant's transfer and administration functions are clearly defined. Internally to the RCMP, individual (directorate) roles and responsibilities were also clear, however communication and information-sharing were lacking in key areas. The Grant's RCMP internal governance was also not articulated to the various directorates involved.

Overall, the Grant is achieving its goal to provide financial and health care assistance to RCMP members and their survivors. RCMP clients are accessing the Grant in increasing numbers each year and the vast majority of claims made are favourable.

The evaluation found the timeliness of services to RCMP clients decreased over the period of review. Secondary analysis of the 2017 Client Survey noted areas for service delivery improvement, particularly in the area of timeliness in obtaining information and services. In addition, the achievement of VAC established service standard targets gradually declined and are currently not being met; however, an annual fee increase from the RCMP to VAC for provision and administration of services has occurred to increase VAC's capacity to provide services to RCMP clients, thereby reducing backlogs and service delivery delays.

Internal controls are in place for the financial activities of the Grant. The RCMP receives monthly and annual reporting, while conducting its own ad hoc analysis and reports relating to the Grant. However, the evaluation found that the RCMP was not using VAC disability data to its full extent, similar to the findings of the previous 2013-14 evaluation.

Based on the findings of the evaluation, it is recommended that the Chief Human Resources Officer:

1. Develop an internal governance model that clearly outlines the involvement of RCMP branches/directorates in the administration and management of the Grant.
2. Enhance consultations between partners involved in the Grant to mitigate information gaps and inform decision-making.
3. In addition to the efforts taken as a result of the recommendation from the 2013-14 evaluation, further explore the use of available VAC data to identify emerging areas of risk and support the prioritization and development of injury prevention measures.

6.0 Management Response and Action Plan

6.1 Management Response

6.2 Action Plan for CHRO

End Notes

Date modified:

2019-10-24