Follow-up audit of sensitive expenditures

Vetted report

November 2017

Table of contents

1. Acronyms and abbreviations
2. Executive summary
3. Management's response to the audit
4. 1 Background
5. 2 Objective, scope, methodology and statement of conformance
   • 2.1 Objective
   • 2.2 Scope
   • 2.3 Methodology
   • 2.4 Statement of conformance
6. 3 Audit findings
   • 3.1 Governance
   • 3.2 Policy and procedures
   • 3.3 Human resource management
   • 3.4 Financial and asset management
7. 4 Conclusion
8. 5 Recommendations
9. Appendix A – Audit objective, lines of enquiry and audit criteria
10. Appendix B – Current status of previous audits' action plans

Acronyms and abbreviations

CAP

Contract and Aboriginal Policing

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CFAO

Chief Financial and Administrative Officer

CM&C

Corporate Management & Comptrollership

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CROPS

Criminal Operations

DSEFSAM

Delegation of Sensitive Expenditures Financial Signing Authorities Matrix

FAA

Financial Administration Act

FP

Federal Policing

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NHQ

National Headquarters

RCMP

Royal Canadian Mounted Police

SE

Sensitive Expenditures

TB

Treasury Board

TEAM

Total Expenditure and Asset Management System

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Executive summary

The Royal Canadian Mounted Police (RCMP) works to ensure the safety and security of Canadians and their institutions, domestically and globally, through intelligence-based prevention, detection, investigation, and law enforcement measures. To this end, the RCMP carries out some of its operations and activities in a covert manner, designed either to infiltrate criminal or terrorist organizations or to disguise the intelligence gathering activities of the police.

Covert operations and activities can include the development of paid sources, the protection and/or relocation of witnesses, the purchase of items for evidentiary or intelligence purposes, and undercover operations. Expenditures for these types of activities are known as sensitive expenditures (SE), and are defined as an expenditure made in support of operations, incurred for law enforcement or security purposes, which could be jeopardized if payment were made using standard overt RCMP procedures.

RCMP Internal Audit has previously conducted four audits of SE, resulting in 13 audit recommendations with 19 components for which management action plans were developed. The recommendations centered on governance, roles and responsibilities, compliance, monitoring and reporting.

The objective of this follow-up audit was to assess whether the implementation of the management action plans associated with the four previous SE audits has addressed the risks and control weaknesses identified in those audits, and whether any new risks have emerged. The audit scope included SE transactions that occurred during the period of January 1, 2016 and December 31, 2016.

The audit concluded that the management action plans associated with the four previous SE audits have, for the most part, addressed the risks and control weaknesses that were identified in those audits. While the sampled SE transactions were generally compliant with policy, opportunities for improvement remain regarding: the overall governance regarding the use of SE; updates to and maintenance of SE policy; the development of training, tools and guidance for SE Coordinators and SE users; and the overall management of covert assets. An in-progress assessment of the new form 1454 would also be beneficial to determine whether the new form is working as intended, errors have been reduced, risk areas remain, and whether workarounds have been implemented by its users. *

The management responses included in this report demonstrate the commitment from senior management to address the audit findings and recommendations. A detailed management action plan is currently being developed. Once approved, RCMP Internal Audit will monitor its implementation and undertake a follow-up audit if warranted.

Management's response to the audit

Corporate Management and Comptrollership:

The Follow-up Audit of Sensitive Expenditures has noted the progress made in addressing the risks highlighted in previous audits and identifies opportunities to further strengthen the governance of sensitive expenditures.

Corporate Management agrees with the findings and recommendations and we will work with our colleagues in Operations to implement the three recommendations in the audit that are jointly directed to the Deputy Commissioner Federal Policing and the Chief Financial and Administrative Officer.

A detailed action plan, which will include specific timelines and milestones, will be developed and presented for review to the Departmental Audit Committee. Following approval, the management action plan will be implemented by Corporate Management, in coordination with Federal Policing, and will address the recommendations directed to both areas.

Dennis Watters
Chief Financial and Administrative Officer

Federal Policing:

Federal Policing acknowledges and accepts the observations noted in the Follow up Audit of Sensitive Expenditures report. The report concludes that our National Sensitive Expenditure Program would benefit from enhancements to the governance framework by documenting the roles and responsibilities and accountabilities of all involved in the process. While National Headquarters Federal Policing Sensitive Expenditure Policy Centre has taken many steps to improve and correct the current processes, additional actions have been identified and will be considered that will address the observations contained in the report. A communication strategy will be developed to provide clarification around the changes being made to the sensitive expenditure process. We are committed to developing a robust and rigorous framework governing sensitive expenditures that will fully address Treasury Board (TB) expectations and allow the RCMP to be fully accountable.

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The audit makes several recommendations related to Financial Administration Act and sensitive expenditure policy compliance and standard operating procedures. In response to previous audit findings, the Sensitive Expenditure policy centre has undertaken a national pilot project over the past 21 months involving a revised form 1454 (a document based programmed management tool). The implementation of the new form has not been without its challenges. As such, Management accepts the recommendation to undertake an in-progress assessment of the new form 1454 to determine its overall effectiveness, seek further areas for improvement and determine overall training requirements related to policy and procedures.

Following on that point, Management also accepts the recommendation to formalize and enhance training offered to Sensitive Expenditure coordinators, users and supervisors. Also highlighted was the role to be played by Corporate Management and Comptrollership in providing assistance and support to the sensitive expenditure program with respect to formalized training programs and the delivery of the same to all end users, supervisors and managers. Consultation with the Chief Financial and Administrative Officer and his staff will take place to address their renewed involvement in the process so they can better support the Program.

A comprehensive review of the * will also be conducted. In consultation with divisional Criminal Operations officers, an analysis will be undertaken to determine the most appropriate means of achieving the appropriate level of visibility and oversight regarding the centralized stewardship of these assets through * or, an alternative solution.

Federal Policing appreciates the efforts and insights of the Internal Audit team, accepts the results of this audit and will address the noted recommendations through action plans that are clear, achievable and representative of the importance the RCMP places on the special authorities granted by TB and its ability to be fully accountable and meet TB expectations.

Gilles Michaud
Deputy Commissioner Federal Policing

1 Background

The RCMP works to ensure the safety and security of Canadians and their institutions, domestically and globally, through intelligence-based prevention, detection, investigation, and law enforcement measures. To this end, the RCMP carries out some of its operations and activities in a covert manner, designed either to infiltrate criminal or terrorist organizations or to disguise the intelligence gathering activities of the police. Treasury Board (TB) has recognized the inherent challenges presented by these types of operations and has provided the RCMP with special authorities and dispensations. Paramount among these are exemptions from certain external reporting provisions such as the requirements to report covert assets and inventories in integrated information systems and public disclosure related to specific types of contracts.

Covert operations and activities can include the development of paid sources, the protection and/or relocation of witnesses, the purchase of items for evidentiary or intelligence purposes, and undercover operations.^{Footnote 1} Expenditures for these types of activities are known as sensitive expenditures (SE), and are defined as an expenditure made in support of operations, incurred for law enforcement or security purposes, which could be jeopardized if payment were made using standard overt RCMP procedures.^{Footnote 2} SE can occur in all aspects of policing, in all RCMP divisions, as well as in National Headquarters (NHQ).

SE are generically recorded in the RCMP's departmental financial system (Total Expenditure and Asset Management system, commonly referred to as TEAM) without identifying details. They are recorded against one of two budgetary reporting objects. One is used to record expenditures for sensitive technical equipment and contracts, the other to record all other types of sensitive expenditures (subsequently referred to as 'general SE').

RCMP Internal Audit has previously conducted four audits of SE,^{Footnote 3} resulting in 13 audit recommendations with 19 components for which management action plans were developed. The recommendations centered on governance, roles and responsibilities, compliance, monitoring and reporting. A summary of the original audit recommendations, along with related findings and any concerns identified in this follow-up audit, is included in Appendix B.

In May 2016, the Commissioner approved the 2016-2019 Internal Audit Risk-Based Audit Plan, which includes a Follow-up Audit of SE.

2 Objective, scope, methodology and statement of conformance

2.1 Objective

The audit objective was to assess whether the implementation of the management action plans associated with the four previous audits has addressed the risks and control weaknesses identified in those audits, and whether any new risks have emerged.

Appendix A presents the audit objective, lines of enquiry and audit criteria.

2.2 Scope

The audit focussed on assessing the implementation of the management action plans undertaken in response to the recommendations made in the four previous audits. The audit also focussed on whether management actions had addressed the issues that led to the recommendations. SE transactions examined in support of this audit occurred between January 1, 2016 and December 31, 2016.

This follow-up audit focused exclusively on general SE.

2.3 Methodology

Planning for the audit was completed in April 2017. In this phase, the audit team conducted interviews, process walkthroughs and examined relevant policies, directives, procedures and results of previous audit work performed.

Sources used to develop audit criteria and audit tests included relevant TB policy frameworks and directives^{Footnote 4} and related RCMP policies. The audit objective, lines of enquiry and audit criteria are available in Appendix A.

The examination phase, which concluded in July 2017, employed various auditing techniques including interviews, documentation reviews, data analysis and transaction testing. Site visits took place at three divisional headquarters as well as at NHQ to review files and assess practices. Upon completion of the examination phase, the audit team held meetings to validate findings with personnel and debriefed senior management of the relevant findings.

Table 1 provides a summary of the transactions tested during the audit. Sampling methodology involved a combination of random and judgmental sampling based on data extracts obtained from the TEAM financial system. The SE types reflected in the sampled transactions included: *

2.4 Statement of conformance

The audit engagement conforms to the Institute of Internal Auditors' International Professional Practices Framework and the Treasury Board of Canada Directive on Internal Audit, as supported by the results of the quality assurance and improvement program.

3 Audit findings

3.1 Governance

Roles and responsibilities

Sound governance structures are required to ensure that SE transactions are compliant with the RCMP's special delegated authorities. Governance should be supported by policy and program design, training, as well as clear roles, responsibilities and accountabilities. Regular monitoring and reporting activities, including performance measures, should also promote the appropriate use of SE.

Federal Policing (FP), Corporate Management & Comptrollership (CM&C) and the divisions share responsibility for the governance of SE.

Federal Policing

The Deputy Commissioner FP is responsible for ensuring oversight, accountability, and training are in place which confirm SE are used appropriately and only as needed to maintain the covert nature of a transaction. * FP's focus is on ensuring sensitive operations and associated expenditures remain covert, leading to successful investigations and the safety of police officers. Within FP, the SE Policy Centre develops SE policy and provides support and direction regarding the appropriate use of SE. The SE Policy Centre has recently moved within FP, and now reports to FP Resource Management & Administration rather than to Federal Policing Special Services (under Covert Operations). This change in reporting structure may increase the SE Policy Centre's actual or perceived segregation from operations, and reduce the potential for operational necessities to influence financial processes and compliance. It may also create stronger functional ties to the CM&C group.

Corporate Management & Comptrollership

The Chief Financial and Administrative Officer (CFAO) is responsible for the sound management and stewardship of all RCMP financial and materiel resources. The Corporate Accounting, Policy and Control branch, reporting under the CFAO, develops policies and processes, and provides oversight to ensure responsible spending and safeguarding of RCMP finances and assets, including those acquired using SE funding.

National, regional or divisional CM&C do not currently engage in SE activities at the outset of the transaction. Interviews with senior officials within CM&C and FP indicated that front-end guidance is not offered by CM&C for SE-related transactions. Moreover, there would be benefits to having greater engagement from CM&C to help ensure adherence to administrative policy requirements at the onset of high-profile projects. Without such guidance, SE Coordinators and SE users are left to navigate the complex policy frameworks and special exemptions that may apply.

CM&C has not implemented a governance framework that adequately addresses its responsibilities related to the use of SE. More specifically, Corporate Accounting, Policy and Control is responsible for ensuring that risk-based financial controls are in place for proper account verification of SE, in accordance with the Financial Administration Act (FAA).^{Footnote 5} When exercising payment authority pursuant to section 33 of the FAA, finance officers are required to review the account verification for all high-risk transactions, including SE. To maintain the covert nature of these transactions, section 33 position holders (finance officers) rely on the divisional SE Coordinators to perform this review function on their behalf when they exercise Endorsement of Payment Request authority.^{Footnote 6} While we found that there is currently a high degree of compliance with this requirement, increased oversight and monitoring by CM&C to ensure that divisional SE Coordinator positions^{Footnote 7} are well-trained and have an up-to-date Endorsement of Payment Request authority in TEAM would be beneficial. Such assurance is critical to continue the reliance placed on this key control surrounding proper account verification of high-risk SE transactions.

Leveraging corporate expertise with the new placement of the SE Policy Centre under FP Resource Management & Administration may promote a consultative approach required to ensure compliance with applicable policy frameworks.

The Divisions

The divisional Criminal Operations (CROPS) officers are responsible for the management and oversight of covert operations and related SE, with the SE Policy Centre at NHQ providing support as required. SE Coordinator positions have been established and staffed at the divisional level to review all SE transactions in accordance with national SE policy.^{Footnote 8}

Since April 2012, all divisional SE Coordinators, as a condition of their position, must sign a letter acknowledging their roles and responsibilities for proper account verification of SE. We found that for all sampled transactions, all SE Coordinators signed this letter and had valid Endorsement of Payment Request authority within TEAM. Interviews with SE Coordinators in the sampled divisions indicated good awareness of their role and responsibilities in exercising this authority. *

Clearly assigning roles, responsibilities and accountabilities

While TB and national SE policy set out the expectations for the various roles, responsibilities and accountabilities among the three areas involved in SE, opportunities exist to foster greater engagement amongst the key stakeholders involved in SE. There are benefits to using tools to clearly assign roles, responsibilities and accountabilities, including formal acceptance, among the various stakeholders involved. For example, using a visual tool would provide role clarification and promote a structured approach for stakeholders to follow when exercising their roles. In this way, management would ensure that all parties are involved in key SE processes at the appropriate time, which would in turn promote enhanced SE-related governance.

Monitoring and reporting

Previous audits documented the need for increased monitoring and reporting of SE activities at the divisional and national level. While one sampled division annually conducts fourto five management reviews that include an SE component, the remaining visited sites were not monitoring or reporting on their use of SE. Such reporting at the divisional level would assist in budget forecasting, and the development of performance metrics in relation to SE could be further explored by management. Without formal performance metrics in place, management's ability to assess or evaluate the effectiveness and efficiency of the use of SE and related controls is limited.

Consistent coding in TEAM results in reliable information for internal and external monitoring and reporting purposes. The sampled divisional SE Coordinators demonstrated a good understanding of the coding that should be applied for SE claims. The vast majority (91%) of sampled transactions were appropriately coded. Any errors observed were largely attributed to interpretation of SE coding definitions. While miscoding is insignificant from a financial statement perspective, increased consistency would allow for enhanced monitoring and reporting on the use of SE across the divisions. The SE Policy Centre has identified an interest in increasing monitoring and oversight of the specific SE general ledger codes by leveraging FP Resource Management & Administration's expertise in data analytics and trend analysis.

Segregation of duties

National SE policy states that SE Coordinators may not report directly to any manager who has exercised section 32 or 34 authority on a transaction for which they are exercising Endorsement of Payment Request authority.^{Footnote 9} In two of the four sampled divisions, the SE Coordinators reported to line officers who exercised section 32 or 34 authorities on 13 sampled transactions. As such, the review completed by the SE Coordinators in exercising their Endorsement of Payment Request authority did not maintain proper segregation of duties.

While additional resources or divisional restructuring may not be feasible to maintain segregation of duties, other mitigating measures could be considered to ensure that additional oversight over SE transactions is applied. For example, the Corporate Accounting, Policy and Control branch has proposed changes to the Delegation of Sensitive Expenditures Financial Signing Authorities Matrix (DSEFSAM) that may provide SE Coordinators with departmental and/or divisional authority. Applying this would allow another divisional SE Coordinator to exercise the Endorsement of Payment Request authority on SE claims when the segregation of duties issue is identified. There may be other options that stakeholders could and should explore to address this issue.

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3.2 Policy and procedures

Established policy and procedures

The national SE policy was published in January 2011 and provides a framework for the use of SE in terms of financial, asset, materiel and real property management as well as procurement. While procedures established in the sampled divisions are consistent with current national policy, existing divisional policy supplements should be reviewed for relevance and alignment, and updated or removed accordingly.

Other beneficial policy enhancements include updates to reflect current unit and position titles, and to update links to other policy references. There are also opportunities for standard operating procedures to be developed and disseminated, including guidance on best practices, to inform SE Coordinators and other stakeholders in support of their SE responsibilities.

Document retention procedures

The Directed Annual Audit of Sensitive Expenditures 2011-2012 found that there was a risk that SE claims * were not being retained for the required period.* As such, there was a risk that documents would be destroyed when they should have been retained for a longer period of time *. This follow-up audit found that the retention issue has been addressed in the sampled divisions. The SE Coordinators made procedural changes regarding retention practices for SE claims *, and documents are now retained for the required period of time. SE policy would benefit from being updated to reflect the procedural changes to promote a consistent application across all divisions.

SE Coordinators were appropriately retaining all * ATI Act Section 16(1)(b) ATI Act Section 16(1)(b) ATI Act Section 16(1)(b)claims for six previous years plus the current year. Clarification is still required as current policy may lead users to interpret a retention period of only two years^{Footnote 10}, which would result in financial documents being destroyed earlier than they should be.

Policy compliance

High FAA compliance rates were observed for the sampled transactions. The vast majority (96%) of sampled transactions were pre-approved by a signatory with appropriate commitment authority (section 32), and certified by a signatory with appropriate certification authority (section 34). The non-compliant transactions related to specimen signature cards which were either not in TEAM, or were not active at the time of signing section 32 or 34. All sampled transactions had evidence of the Endorsement of Payment Request authority performed by the SE Coordinator. Notwithstanding, for reasons previously outlined, the quality and reliance which can be placed on these certifications varied.

It is incumbent on the user to be well-versed in and apply the spirit of relevant policies, including how the various TB exemptions can be applied. The majority of interviewed SE users indicated that they rely on their divisional SE Coordinator for policy interpretation. It was found that 98%^{Footnote 11} of the sampled transactions were compliant with relevant SE policy and all but one of the sampled transactions maintained the covert or discreet nature of the expenditure.* As was the practice in one division*

All sampled transactions demonstrated value-for-money through, for example, the inclusion of multiple quotes on the file (or referenced in the unit-level files). Moreover, all sampled transactions included an appropriate rationale that clearly articulated the need for the expenditure to be deemed sensitive, and 95% were consistent with what was originally planned and approved. The high compliance rates were largely attributed to the advisory role of the SE Coordinators as well as ongoing learning and awareness by various SE user groups. Applying the new form 1454 Request and Authority for Payment also contributed to the increased compliance rates.

New form 1454 Request and Authority for Payment

The SE Policy Centre developed the new form 1454 as part of a management action plan to address audit findings regarding compliance from the first SE audit. At the time, a project management plan was not formalized and its development has since spanned a number of years.^{Footnote 12} It remains a pilot project to allow SE users and SE Coordinators to adapt to new business processes brought about by the new form. The roll-out of the new form 1454 has been underway since January 2016, and the extent of implementation varies with most divisions having implemented it in selected units since spring 2016. The new form 1454 was designed with two goals in mind: to document pre-approval of all aspects of the transaction and to summarize all expenses with requisite details.

The new form 1454 incorporates many automated controls. It is designed to provide verification against the DSEFSAM and to identify position holders with appropriate signing authority for the transaction. Specific sections of the form must be completed before the user can proceed to a subsequent stage of the form (i.e.: pre-approval is required before proceeding to the reimbursement stage). Business rules are incorporated from various RCMP policies, including the Operational, Financial and Asset Management Manuals. Mathematical calculations are automated. In addition, the form minimizes duplication and data entry errors, as tombstone data entered by the user is automatically carried forward to subsequent stages of the form.

In the sampled divisions, users described challenges in adapting to the new form 1454 and the associated process. They indicated that the new form is lengthy and cumbersome to read and complete with ease. While the new form 1454 includes description boxes that outlinethe authorities and responsibilities of users and signatories, these descriptions are long and difficult to read. Numerous signatures are required throughout the different stages of the form to substantiate the expenditure process. This may dilute the importance of the sign-off, as the more times an individual is required to sign a document, the less likely they may be to pay attention to what they are signing. The new form 1454 is focused on the financial authorities rather than the justification or rationale for the expenditure. The rationale should document particulars about the transaction, including why the expenditure must be processed sensitively, the options that were considered and the decisions made throughout the process. Although all sampled transactions included an appropriate rationale that clearly articulated the need for the expenditure to be deemed sensitive, including the option for a more substantial rationale in the new form 1454 would promote consistency and might better demonstrate stewardship and accountability over SE.

While the new form 1454 is well suited for planned expenditures, interviewees stated that it is challenging to apply to unplanned operations that inherently require fluidity and nimbleness. In light of the expressed concerns, the SE Policy Centre should perform an in-progress assessment of the new form 1454 to determine whether it is working as intended, if errors have been reduced, if risk areas remain, and whether workarounds have been implemented by its users. A cost-benefit analysis could also be performed as part of the in-progress assessment. This analysis should examine the impact of the new form 1454 on workloads and whether there are redundancies to eliminate or efficiencies to be made. A risk-tolerance for applying the new form 1454 for unplanned expenditures or low-dollar amounts could also be considered. Options for such transactions could include the use of a modified form 1454 focusing on key control elements such as the rationale, and clearly identified section 32 and section 34 authorities.

An overall change management process regarding the new form 1454 is fundamental to its success. Firstly, from a design perspective, any changes to the DSEFSAM or to business rules from policy updates will have an impact on the complex automated controls that are embedded in the form. Secondly, from a process perspective, there is a need to ensure that users are trained and that an effective communication strategy exists for applying the process using the new form 1454. While the impact of the new form 1454 has not been fully assessed by the SE Policy Centre, there are indications from both the SE Policy Centre and the divisions that the workload will increase once fully implemented.

3.3 Human resource management

Divisional SE Coordinators

SE Coordinators perform a post-review of SE transactions and exercise Endorsement of Payment Request authority to provide assurance to financial officers when they exercise section 33 payment authority. Following a recommendation from the first SE audit, all divisions established and staffed SE Coordinators. However, the number of positions staffed and the category of employee varies considerably across the divisions.

For example, in three sampled divisions, one full-time employee occupied the SE Coordinator position. In two of these divisions, it was a public servant position, and in the third, it was a regular member position. A fourth division employed one regular member and four public servants in the SE Coordinator unit. This provided a balance of operational knowledge and expertise, as well as the administrative and financial experience and stability associated with employing public servants. The benefits of having both categories of employee in the SE Coordinator position should be considered in divisional staffing models.

The SE Coordinator position is a key control function in proper account verification, and is heavily relied on by financial officers when exercising section 33 payment authority. Accordingly, succession planning for these positions should be an ongoing consideration. Our examination found no evidence that succession planning is currently being considered.

SE-related training

Two recommendations from the first SE audit related to training. At the time, FP and the Chief Human Resources Officer were responsible to ensure that SE-related training was created and provided to all SE Coordinators in a timely manner and included in operational and supervisory training where appropriate. A formalized SE training program remains to be developed and SE-related training has not been included in relevant operational and supervisory training programs, including training for the officer cadre. There may be opportunities to include SE training in existing courses, thereby reducing the required resourcing associated with developing a standalone SE training program. While management's efforts to address these recommendations led to the development of the new form 1454, opportunities remain regarding the original intent of the recommendations and management action plans.

National SE policy specifies that FP is responsible for ensuring the appropriate training of SE Coordinators,^{Footnote 13} CM&C is responsible for ensuring the appropriate training of SE Coordinators with respect to financial and administrative requirements,^{Footnote 14} and the divisions are responsible for ensuring the hiring of SE Coordinators who are appropriately trained.^{Footnote 15}

Previous SE audits reported that no formalized SE-related training is offered to SE Coordinators, users or supervisors. Instead, they primarily learn how to perform their duties on-the-job, from their predecessors and colleagues. The same holds true at the time of this follow-up audit. Accordingly, improvements could be made by FP and CM&C to deliver on their SE-related training responsibilities.

Recently, the SE Policy Centre delivered workshops to divisional SE Coordinators and select users and supervisors regarding the implementation of the new form 1454. The training session's content was geared towards explaining the design of the new form 1454 and how it relates to the SE process. The SE Policy Centre sought input and feedback from relevant business lines during the forms' development; however, no other business line was involved in the development or delivery of the training session. Delivery of the training session was dependent on prioritization by the division as it was provided only when a requesting division had the funds to bring the SE Policy Centre representatives to their division. In the future, the SE Policy Centre has considered developing an online course for accessible SE-related training; however, this initiative remains in a conceptual stage.

While CM&C is responsible for training SE Coordinators with respect to their financial and administrative requirements, they have not been engaged in facilitating such training. Of the sampled divisions, E Division was the only division providing SE-related training to new unit commanders and those units identified as requiring an update or refresher on SE processes or use.^{Footnote 16} Also, there is still no SE-related training for SE supervisors that outlines the additional safeguards or responsibilities to be aware of when exercising section 32 or 34 authorities over SE transactions. Interviewees in all sampled divisions indicated that additional training would be beneficial and would serve to promote a comprehensive understanding of the signatories' responsibilities for exercising section 32 and 34 authorities regarding the use of SE.

Notwithstanding the high compliance rates that were noted from the sampled transactions, developing and offering formalized SE training is considered a best practice to mitigate the inherent high-risk nature of SE transactions. *

Tools and guidance

In the absence of formalized training, SE-related tools and guidance for SE coordinators and users should be developed and disseminated. As previously mentioned, SE users are not well-versed in the relevant policies and rely on their divisional SE Coordinators for policy interpretation. Development of best practice guidance would be beneficial in this regard and would ensure that business practices are consistently applied and risk-managed.

*

Communication amongst stakeholders

Opportunities exist to improve communication between CM&C and divisional counterparts to minimize operational impacts when policies and procedures change. * When asked, NHQ Corporate Accounting was aware of the issue and had developed a Communiqué that was sent to divisional Accounting Services for dissemination to stakeholders.* However, these procedural updates had not been provided to users in the field.

In previous audits, most SE Coordinators indicated having minimal contact with the SE Policy Centre, but this follow-up audit observed improved communication between them. The interviewed divisional SE Coordinators indicated they communicate as required with the SE Policy Centre on issues requiring clarification, and most communicate directly with users and/or supervisors in order to resolve SE claim-related issues. The new form 1454 has been a regular topic of discussion between the divisions and SE Policy Centre. These discussions range from feedback regarding the increased workload, to the impact of form changes on current business practices. Notwithstanding, opportunities exist to enhance communication and information sharing.

3.4 Financial and asset management

Management of covert assets

The management of covert assets * is important to ensure sound stewardship of resources. While national SE policy requires the * they only maintain records for the assets that they manage. When covert assets are procured by a unit, the covert asset records are maintained at the unit-level. As a result, a consolidated divisional record of covert assets does not exist, and the covert asset records that were reviewed as part of this audit did not provide adequate visibility regarding all covert assets in the sampled divisions. An assessment of covert asset records held at the unit level was not performed by the audit team. Additionally, in the absence of a consolidated record regarding divisional covert assets, controls that should be in place surrounding the tracking of assets from acquisition, usage, transfer, surplus and disposal were not observed or tested as part of this audit.

The first SE audit reported that most of the divisions and units visited had their own inventory tracking systems for covert assets. These systems were independent of each other and were not accessible by other units or divisions. This audit further noted that covert assets *

This follow-up audit again observed an absence of national or division-wide visibility over covert assets. Without proper management, there is an increased risk that covert assets may be acquired in duplicate, may not be fully utilized, * As a mitigating measure, * in the sampled divisions indicated that *acquired using SE. This practice maximizes the use of covert assets, and promotes stewardship and fiscal responsibility. Notwithstanding, the lack of a division-wide perspective could be an issue if a division, or the RCMP as a whole, were required * While this information may be available, considerable effort would be required to compile it.

Consultation with the divisions would be beneficial to determine what is important for national visibility and oversight of covert assets. This information should be recorded and tracked to facilitate informed decision-making. Use of a common inventory management system for covert assets would facilitate oversight with regards to asset acquisition, maintenance, disposal and overall inventory control. While recognizing the exemptions from TB directives and policies, an inventory management framework for covert assets should be consistent with the spirit and principles of conventional asset management. Building and maintaining an inventory record is a necessary first step in managing national assets. Management should consider whether the * or other form(s) of covert asset record management system, will be used in this regard.

*

Asset Inventory Control

The new form 1454 includes the 1454-Asset Inventory Control, intended to streamline the records management process when a covert asset is acquired. It was designed to be sent to the *, who is responsible for updating the divisional covert asset records, and to the * Administrator at NHQ for * record entry. In doing so, the 1454-Asset Inventory Control promotes the completeness of covert asset acquisitions at the divisional and national level when it is used as intended.

However, in one sampled division where the new form 1454 was fully implemented, the 1454-Asset Inventory Control was not utilized as intended. Instead, it was filed without further action along with the remainder of the SE claim in the SE Coordinator's office. When asked, the SE Coordinators indicated that they were not informed of the aforementioned process, and assumed that claimants had already forwarded the 1454-Asset Inventory Control to the appropriate individuals for inventory tracking prior to sending it to the SE Coordinators for review. Although unit-level inventory records may have been updated, it is clear that * was not updated using the 1454-Asset Inventory Control. A communication strategy regarding the design and use of this aspect of the new form 1454 would promote the completeness of divisional and national covert asset records.

Completeness of file records

In consideration of the inherent risk relating to the use of SE, strong records management practices were expected. However, in one sampled division, 5 of 24 sampled files could not be located by the SE Coordinator. Certain elements were also not provided for two of the remaining 19 sampled files. This is an indication of deficiencies in record management in this division.

As a mitigating measure in relation to the completeness of files, all SE claims are reviewed by the divisional SE Coordinators, and finance officers will not exercise payment authority pursuant to section 33 without the SE Coordinator's sign-off of Endorsement of Payment Request authority. As the missing and incomplete sampled files were selected from completed transactions posted in TEAM, which would have entailed the specific review of expenditures by the SE Coordinator and their corresponding sign-off of Endorsement of Payment Request authority, it is apparent that the account verification process was carried through.* Based on the audit team's site visits in the sampled divisions and at NHQ, the missing and incomplete files are not indicative of a pervasive issue with respect to overall records management across the divisions. Accordingly, the specific records management issue identified was raised with the relevant division's senior management for corrective action.

4 Conclusion

The audit concludes that the management action plans associated with the four previous SE audits have, for the most part, addressed the risks and control weaknesses identified in those audits. The original 19 audit recommendations were centered on governance, roles and responsibilities, compliance, and monitoring and reporting.^{Footnote 17} Still, opportunities for improvement remain in these areas.

While the sampled SE transactions were generally compliant with policy, opportunities for improvement remain regarding: the overall governance regarding the use of SE; updates to and maintenance of SE policy; the development of training, tools and guidance for SE Coordinators and SE users; and the overall management of covert assets. An in-progress assessment of the new form 1454 would also be beneficial to determine whether the new form is working as intended, if errors have been reduced, if risk areas remain, and whether workarounds have been implemented by its users.*

5 Recommendations

1. The Deputy Commissioner Federal Policing, in coordination with the Chief Financial and Administrative Officer, and in consultation with the divisions, should enhance overall governance over sensitive expenditures (SE) by further clarifying and documenting the roles, responsibilities and accountabilities among all parties involved in key SE processes and updating SE policy accordingly.
2. *
3. The Deputy Commissioner Federal Policing should perform an in-progress assessment of the new form 1454 to determine whether it is working as intended, errors have been reduced, and whether risk areas remain.
4. The Deputy Commissioner Federal Policing, in coordination with the Chief Financial and Administrative Officer should formalize the delivery of training for stakeholders involved in SE, notably the SE Coordinators, SE users and SE supervisors.
5. The Deputy Commissioner Federal Policing should consult with divisional Criminal Operations officers to determine information elements that are important for divisional and national visibility and oversight of covert assets, and record and track these centrally in the * or alternative solution.

Appendix A – Audit objective, lines of enquiry and audit criteria

Audit Objective:

To assess whether the implementation of the management action plans associated with the four previous audits has addressed the risks and control weaknesses identified in those audits, and whether any new risks have emerged.

Lines of Enquiry:

1. Status of management action plan implementation:
   • Management action plans have been implemented as originally specified or as subsequently amended and approved.
2. Validation of risks being addressed:
   • Corrective actions implemented as identified in the management action plans appear to have addressed the risks related to the previous findings / observations.

Audit Criteria:

1. Governance:
   • Effective oversight mechanisms are established to manage the use of SE.
2. Policy and Procedures:
   • Policies and procedures for SE are established, relevant, aligned, maintained, clearly communicated and followed.
3. Human Resource Management:
   • Key positions and activities are identified and are adequately staffed.
   • Employees are provided with the necessary training, tools and guidance to facilitate their use of SE.
4. Financial and Asset Management:
   • File records are complete and accurate; and related SE are approved and processed in accordance with relevant policy.
   • The national inventory management system for covert assets is developed, deployed, maintained and used by National Headquarters and in the divisions.
   • Assets, including information technology and systems, are life-cycle managed and protected.

Appendix B – Current status of previous audits' action plans

The following table summarizes the original audit recommendations, related findings and remaining concerns identified in this follow-up audit.

Survey of Policing Partners and Stakeholders 2019-2020

The RCMP's Survey of Policing Partners and Stakeholders includes general questions evaluating the RCMP, as well as more specific questions about the RCMP business lines with which they work (e.g., Federal Policing, Contract and Indigenous Policing, Technical Operations). There were 742 respondents.

Policing partners and stakeholders are representatives of other police services and government agencies and departments the RCMP works with, as well as non-governmental organizations which have a strong interest in RCMP activities, such as civil liberties associations and legal organizations.

Notes

• Data was collected between January 28, 2020 and March 16, 2020
• Questions were answered on a 5-point scale and summarized to agree/neutral/disagree to facilitate review
• Percentages exclude those who replied "don't know" or "no opinion"
• Percentages may sometimes not add to 100 due to rounding
• For new questions in 2019-20, cells are greyed out for previous years
• Results that went up in 2019-20 are highlighted in green, those that went down are highlighted in pink

Sondage auprès des partenaires policiers et des intervenants de 2019-2020

Le Sondage auprès des partenaires policiers et des intervenants comprend des questions générales visant à évaluer la GRC et des questions précises sur les secteurs d'activité de la GRC avec qui ils travaillent (p. ex. Police fédérale, Services de police contractuels et autochtones, Opérations techniques). Au total, 742 personnes ont répondu au sondage.

Les partenaires policiers et les intervenants sont des représentants d'autres services de police et d'organismes et ministères gouvernementaux avec lesquels la GRC collabore et d'organisations non gouvernementales pour qui les activités de la GRC présentent un grand intérêt, comme les associations des libertés civiles et les organisations juridiques.

Notes

• Les données ont été collectées entre le 6 février 2020 et le 16 mars 2020
• Les questions ont été répondues sur une échelle à cinq point et résumées à d'accord, neutre et en désaccord pour en faciliter le revue
• Les pourcentages listés n'incluent pas les réponses "Ne sais pas" ou "Sans opinion"
• Les pourcentages ne s'additionnent pas toujours à 100 % dû à l'arrondissement des chiffres
• Pour les nouvelles questions ajoutées 2019-2020, les cellules des années précédents ont été grisées
• Les résultats qui on monté en 2019-2020 sont surlignés en vert et ceux qui ont descendu sont surlignés en rose

Sondage auprès des partenaires contractuels de 2019-2020

Le Sondage auprès des partenaires contractuels est mené auprès des maires, des dirigeants autochtones et de représentants du gouvernement local, provincial et territorial responsables des contrats avec la GRC pour leur territoire de compétence respectif. Au total, 688 personnes ont répondu au sondage.

Notes

• Les questions ont été répondues sur une échelle à cinq point et résumées à d'accord, neutre et en désaccord pour en faciliter le revue
• Les pourcentages listés n'incluent pas les réponses "Ne sais pas" ou "Sans opinion"
• Les pourcentages ne s'additionnent pas toujours à 100 % dû à l'arrondissement des chiffres
• Pour les nouvelles questions ajoutées 2019-2020, les cellules des années précédents ont été grisées
• Les résultats qui on monté en 2019-2020 sont surlignés en vert et ceux qui ont descendu sont surlignés en rose

Survey of Contract Partners 2019-2020

The Survey of Contract Partners is a survey of mayors, Indigenous leaders, as well as local, provincial and territorial government representatives who are responsible for RCMP contracts within their respective jurisdictions. There were 688 respondents.

Notes

• Data was collected between February 6 and March 16, 2020
• Questions were answered on a 5-point scale and summarized to agree/neutral/disagree to facilitate review
• Percentages exclude those who replied "don't know" or "no opinion"
• Percentages may sometimes not add to 100 due to rounding
• For new questions in 2019-20, cells are greyed out for previous years
• Results that went up in 2019-20 are highlighted in green, those that went down are highlighted in pink

Canadians’ Views of RCMP Policing Services 2019-2020

Canadians' Views of RCMP Policing Services is a public opinion survey of adult residents of Canada, with a focus on areas policed by the RCMP. A random sample of respondents (1,317 by phone and 1,671 online) was allocated to the 14 divisions of the RCMP, with 70% of the sample drawn from areas where the RCMP is the police service of jurisdiction.

Contact with the RCMP

Notes

• Results in this table are the overall results (combination of online panels and telephone interviews)
• Data was collected on January 10-27, 2020
• Percentages exclude those who replied "don't know" or "no opinion"
• Results are "weighted" - they are adjusted so that age, gender, and region better match the Canadian population
• For new questions, cells are greyed out for previous years

Sondage d’opinion des citoyens canadiens sur les services de police de la GRC de 2019-2020

Le Sondage d'opinion auprès des citoyens canadiens sur les services de police de la GRC consiste à sonder l'opinion des Canadiens adultes, plus particulièrement dans les régions où la GRC assure des services de police. Un échantillon de répondants (1 317 par téléphone at 1 671 en ligne) était réparti entre les 14 divisions de la GRC, 70 % de cet échantillon provenant de ces régions.

Contact avec la GRC

Notes

• Les résultats dans les tableaux ont été obtenus en utilisant une combinaison de réponses par téléphone et en ligne
• Les données ont été collectées du 10 au 27 janvier 2020
• Les pourcentages listés n'incluent pas les réponses "Ne sais pas" ou "Sans opinion"
• Les pourcentages ne s'additionnent pas toujours à 100 % dû à l'arrondissement des chiffres
• Les résultats sont pondérés - ils sont ajustés pour que l'âge, le genre et la région soient plus représentatifs de la population canadienne
• Pour les nouvelles questions ajoutées 2019-2020, les cellules des années précédents ont été grisées

Internal Audit, Evaluation and Review – Internal Audit Performance Results

Internal Audit, Evaluation and Review (IAER) publishes the performance results of its Internal Audit (IA) function, as required by the Directive on Internal Audit. This helps ensure that that the public is aware that heads of government organizations are receiving assurance and that activities are managed in a way that demonstrates responsible stewardship. The Treasury Board of Canada Secretariat's website provides additional information on why we publish key compliance attributes for internal audit.

Last updated: December 31, 2022

Vérification interne, Évaluation et Examen – Résultats de rendement de la vérification interne

La VIEE publie les résultats de rendement de sa fonction de vérification interne (VI), conformément à la Directive sur l'audit interne. Ainsi, le public et les chefs des organisations gouvernementales savent que les activités sont régies d'une façon qui démontre une gestion responsable des ressources. Le site Web du Secrétariat du Conseil du Trésor du Canada fournit des renseignements supplémentaires sur les raisons pour lesquelles nous publions les principaux attributs de conformité de l'audit interne.

Dernière mise à jour : 31 décembre 2022

Horizontal Evaluation of the National Anti-Drug Strategy

RCMP Component Piece

March 15, 2018

Table of contents

1. 1.0 Background and Context
   • 1.1 Program Description
   • 1.2 Purpose and Scope of the Evaluation
   • 1.3 Methodology and Approach
2. 2.0 Findings
   • 2.1 Relevance
   • 2.2 Tracking and Reporting
   • 2.3 Achievement of NADS Intended Outcomes
   • 2.4 NADS Knowledge Exchange Strategy
   • 2.5 RCMP NADS Funding
3. 3.0 Conclusion
4. 4.0 Endnotes and bibliography

Acronyms and abbreviations

CAP

Contract and Aboriginal Policing

CBSA

Canada Border Services Agency

CDS

Canada's Drug Strategy

CPC

Canadian Police College

DRE

Drug Recognition Expert

FPPE

Federal Policing Public Engagement

KES

Knowledge Exchange Strategy

MGO

Marihuana Grow Operation

NADS

National Anti-Drug Strategy

NYIDP

National Youth Intervention and Diversion Program

PDA

Prescription Drug Abuse

PRIME

Police Records Information Management Environnent

PROS

Police Reporting and Occurrence System

RCMP

Royal Canadian Mounted Police

1.0 Background and Context

Canada's Drug Strategy (CDS) was first launched in 1987 to address substance use and abuse through coordinated activities undertaken by a number of departments, agencies, and non-governmental organizations. The strategy was based on four fundamental program components: prevention, treatment, enforcement, and harm reduction. CDS was renewed in 1992, 1997, and 2003. In 2007, the Government of Canada announced new resources and the refocusing of existing programs and initiatives to create a new National Anti-Drug Strategy (NADS). NADS included core federal programming initiated under CDS as well as new initiatives in support of prevention, treatment, and enforcement efforts. Stemming from the 2013 Speech from the Throne, the Government of Canada expanded NADS to address prescription drug abuse (PDA). Following the NADS 2012 Impact Evaluation, the Strategy was further modified to include Knowledge Exchange Strategies (KES) to ensure that the results and information developed from the federal investment are accessible and used by stakeholders and other government departments.

NADS is a horizontal initiative of 13 federal departments and agency partners that is led by the Department of Justice Canada (Justice). Activities are grouped under three main Action Plans: Prevention, Treatment, and Enforcement.^{End note aBibliography 1}

1.1 Program Description

The Royal Canadian Mounted Police (RCMP) received approximately $128.4 million between 2011-12 and 2015-16 to support its contribution to Prevention, Treatment, and Enforcement activities. These activities were primarily delivered through two separate RCMP business lines: Federal Policing and Contract and Aboriginal Policing (CAP).^{End note b}

1.1.1 Federal Policing

The majority of NADS-related funding received by the RCMP was allocated to Federal Policing to support the NADS Prevention and Enforcement Action Plans. Under the Prevention Action Plan, Federal Policing supports various initiatives across Canada aimed at enhancing public awareness of the nature, extent, and consequences of substance use and abuse.^{Bibliography 2} Under the Enforcement Action Plan, NADS funding helps increase the RCMP's capacity to proactively target organized crime involvement in illicit drug production and distribution operations.^{Bibliography 3}

In 2012, when NADS was last evaluated, the RCMP's Drug Awareness and Drug Enforcement units were engaged in prevention and enforcement activities, while the RCMP's Drugs and Organized Crime Awareness Service was primarily responsible for NADS-related prevention activities. In 2013-14, Federal Policing underwent an organizational restructuring which entailed changing the way resources were deployed. In lieu of having staff focused on specific commodities (i.e., drugs), investigative resources under the restructured Federal Policing model, are allocated towards the highest-level threats to the safety and security of Canadians (e.g. organized crime networks involved in illicit drug trafficking). In addition, a new unit that specializes in engagement, called the Federal Policing Public Engagement (FPPE) unit was established.

1.1.2 Contract and Aboriginal Policing

CAP is responsible for providing program support to policing services under contract. This comprises Canada's three territories, eight provinces (except Ontario and Quebec), more than 190 municipalities, 184 Aboriginal communities and three international airports. Under the NADS Treatment Action Plan, CAP was responsible for the National Youth Intervention and Diversion Program (NYIDP). The NYIDP provided front-line RCMP employees with tools and training to consider alternatives to charging youth and to refer at-risk youth to community and treatment programs. Funding for this component sunsetted in March 2012.

Additionally, CAP's National Traffic Services implemented and manages the Drug Recognition Expert (DRE) program which provides training for police officers to identify drug-impaired persons usually focusing on drivers.

1.2 Purpose and Scope of the Evaluation

The 2016 evaluation of NADS led by Justice will assess the performance of funded activities conducted under NADS by the 13 participating departments and agencies from fiscal years 2011-12 to 2015-16. In alignment with its internal horizontal engagement protocols, the RCMP's National Program Evaluation Services was responsible for the collection and analysis of all internal RCMP information. The results of these evaluative activities are presented in this component piece which will serve as the RCMP's contribution to the overall evaluation of NADS.

1.3 Methodology and Approach

The methodology for the RCMP's component piece was developed in alignment with the 2015 NADS Performance Measurement Strategy and the data collection instruments provided by Justice for the 2016 evaluation of NADS. Data collection and research were conducted under the 2009 Treasury Board Secretariat Policy on Evaluation, Directive on Evaluation Function, and Standard on the Evaluation for the Government of Canada, while the component piece has been prepared in accordance with the requirements of the 2016 Policy on Results. Internal and external documentation were reviewed, and evaluators conducted semi-structured interviews with eight RCMP employees directly engaged in NADS-funded activities at the national level as well as three consultations with individuals from corporate services directly involved in supporting NADS activities.

2.0 Findings

2.1 Relevance

Overall, the goal of NADS is to "contribute to safer and healthier communities by helping prevent use, treat dependency and reduce production and distribution of illicit drugs as well as by addressing prescription drug abuse."^{Bibliography 4} A review of key documents highlighted the relevance of NADS to the mandate and strategic priorities of the RCMP. Addressing crime associated with illicit drugs is aligned with the RCMP's mandate and within its roles and responsibilities; particularly the facets of preventing and investigating crime, enforcing laws, and providing vital operational support services to other police and law enforcement agencies within Canada and abroad.^{Bibliography 5} NADS is also aligned with the RCMP's strategic priorities of 'Serious and Organized Crime' and 'Youth' (via outreach and engagement and intervention and diversion).^{Bibliography 6} Six of seven interviewees who were asked about the continued need for the RCMP to work under NADS indicated there was a need. Four interviewees noted that there is a continued need for the partnerships and/or reporting together under NADS, while three interviewees pointed to the need for the formal funding.

This is further supported by executive direction; in the 2016-17 Annual Federal Policing Budget letter to Division Commanding Officers, it was noted that horizontal initiatives including NADS "continue to be an important requirement of the Federal Policing program. Federal Policing remains accountable for delivering and reporting results…"

2.2 Tracking and Reporting

Police-reported drug offences are recorded by RCMP staff in a records management system (called PRIME in British Columbia and PROS in the rest of Canada). These systems "integrate the entire scope of RCMP processes for collecting, managing, sharing and analyzing operational police information." In addition to the intended purpose of supporting policing operations, RCMP data and information is of particular interest to other government departments and international organizations. The RCMP, therefore, is called to produce unique reports on the topic of its drug prevention and enforcement work to address the needs of external audiences. This includes NADS annual reporting for Justice, which publishes an annual report providing an account of the collective performance of the 13 NADS partners^{End note c}.

2.2.1 Reporting Challenges

To support public reporting concerning the activities and outcome of NADS, federal partners developed a NADS Performance Measurement Strategy. Although the RCMP was an active participant in this work, after implementation it became apparent that the indicators established were labour-intensive to collect. Each year, the RCMP was required to complete six different NADS reporting templates including a Performance Indicator Reporting Table for each of the three action plans, and an end-of-year reporting template for each of the three action plans. The roll-up of all partners' templates was then used by Justice Canada to develop the NADS Annual Report.

Consultations concerning NADS reporting activities revealed a number of challenges when working to ensure information provided in the RCMP's NADS templates is timely, valid and consistent. The main challenge reported was that data to support all of the NADS indicators is not easily retrievable from a single, central database. To complete NADS templates, the RCMP relied on data extractions from its PROS/PRIME systems. However, the RCMP's records management systems were designed to capture information in support of police operations and not the performance indicators identified for NADS reporting. To retrieve additional information, RCMP staff from the 14 Divisions across Canada gathered data manually via various tools and spreadsheets.

When specifically reviewing the data gathered to support drug seizure reporting, there were challenges noted concerning how the RCMP was retrieving PROS/PRIME occurrence information and the interpretation of results. For example, a key challenge in reporting on the types of drugs seized is the reliance on using the PROS/PRIME data as the drug classification information entered is speculative on the part of the officer. A more reliable data source may be Health Canada who is responsible for testing and confirming the type of drugs seized in cases that lead to charges being laid. Similarly, studies completed in 2014-15 and 2015-16 by Federal Policing's Situational Awareness Support Unit concerning the RCMP's drug seizures revealed a number of discrepancies in how the number, quantity and value of drug seizures were reported. The studies corrected the reported information for those years; however, an ongoing exercise may be necessary to ensure systems data is validated moving forward.

When reviewing prevention related reporting, evaluators also noted inconsistencies. For example, information on outreach activities varied from the number of presentations given to the number of attendees, to the number of trainers trained. Furthermore, information covered some Divisions but not all, making it impossible to aggregate the actual reach of the RCMP's awareness raising activities across Canada. Moreover, the utility of some of the indicators in the reporting templates were questioned. For example, data on 'the number of awareness presentations' does not, as indicated by one of the key informants, serve as an indicator of the quality or impact of the programs. Captured in isolation, the information does not serve to determine whether and which activities are making a difference in communities. By way of example, in 2012-13, the RCMP gave 3,461 awareness presentations reaching 37,667 youths, 27,686 parents, and 8,612 professionals.^{Bibliography 7} These numbers, if consistently reported year-to-year, could provide an indication of the reach of prevention activities.

Finally, when asked whether NADS reporting could be made more effective and/or efficient, interviewees directly involved in NADS suggested that the templates be revised, indicators made generic, and reduced to focus primarily on RCMP data that can be retrieved from electronic systems.

2.3 Achievement of NADS Intended Outcomes

2.3.1 Prevention Action Plan Results

The intermediate NADS outcome for which the RCMP contributes to for prevention purposes is to enhance capacity among targeted populations to make informed decisions about illicit drug use and PDA to reduce risk-taking behaviours. Through the RCMP's FPPE and the National Aboriginal Policing and Crime Prevention Services Directorate, Federal Policing Services and CAP Services respectively provided community outreach programming to increase awareness, enhance public safety and reduce victimization of Canadians. This was achieved by mobilizing the public in addressing concerns and developing mutual goals. In collaboration with other government partners, the RCMP participated in workshops and discussions on controlled drugs and substances and produced training tools and products relevant to the role of police officers.

Community Outreach for Prevention Purposes

Federal Policing, CAP, and RCMP Divisions developed educational materials intended to increase knowledge about drugs and organized crime as well as raise awareness about the negative impacts of illicit drugs. While interventions were especially aimed at youth, the RCMP also engaged adult leaders and mentors. For example, in 2014-15, the RCMP trained, presented to, or engaged with 5,000 public safety, health care, educational institution employees, non-governmental organizations, and community-based resource people. In addition, the RCMP created the Centre for Youth Crime Prevention as an online hub for youth, educators and police to access crime prevention and victimization tools and resources, including on drugs and substance abuse.^{Bibliography 8}

Given the importance of community-relevant prevention programming, each RCMP Division is encouraged to develop outreach activities and materials that make sense for their jurisdiction. Outreach materials were adapted to community needs and to provide up-to-date drug information as the drug market changed. In addition to materials disseminated, as of 2014-15, there were 14 formal programs that Divisions could use/tailor for their outreach needs. These included the following: Aboriginal Shield, Drug Abuse Resistance Education - DARE, Drugs & Sports, Drug Awareness Officers Training, Drug Endangered Children, Drugs in the Workplace, Kids & Drugs, Racing Against Drugs, Prescription drug abuse-related initiatives, Synthetic Drug Initiative, Community Prevention Education Continuum, a mobile application for drugs and organized crime awareness, organized crime presentations, and counter-gang programs.^{Bibliography 9} Some programs and awareness activities have built-in performance metrics such a pre and post surveys of knowledge.

Community Outreach for Enforcement Purposes

From 2011-12 to 2014-15, Federal Policing engaged in numerous public outreach activities related to Enforcement. The purpose of these efforts was to exchange information, engage in joint efforts, and to identify areas of common concern and jurisdiction. An example is the Synthetic Drug Initiative which brought together partners from public and private sectors to tackle activities related to the importation, exportation, production and distribution of illicit substances of abuse.

The RCMP also facilitated the creation of a new body called the National Council against Marihuana Grow Operations and Clandestine Laboratories that held its first meeting in November 2012. The coalition of community, industry, and government groups share best practices on increasing public awareness about the societal hazards of marihuana grow operations (MGOs) and clandestine drug laboratories, and advocate for a national approach aimed at helping prevent, detect, and deter such criminal acts.

Additionally, a public website that identifies which residences have been subject to a judicial search warrant in relationship to an MGO was developed in 2011. Although no longer active, in its first year, the website received more than 400,000 visits and was referenced by more than 300 separate sources.

2.3.2 Treatment Action Plan Results

As previously noted, the RCMP's involvement in the Treatment Action Plan ended in fiscal year 2011-12. In keeping with the scope of this evaluation, evaluators looked at results achieved in fiscal year 2011-12 by the RCMP's NYIDP. The key objective of this program was to reduce crime and incarceration rates for youth by getting the right youth to the right services at the right time. The rationale for RCMP involvement in this area was based on research that "strict sanctions have little to no effect on young offender recidivism rates and in some cases actually increase recidivism." The model seeks to make full use of community resources to address the underlying causes of crime. It seeks to ensure the strategic use of resources by referring moderate-risk youth to community services so that only high-risk youth are sent into the correctional system.^{Bibliography 10}

In its final year of funding, the RCMP developed and started implementing a screening tool for police officers to be able to assess youth's level of criminality and risk to the community, and began working with provincial and community partners to develop community mobilization protocols to improve interventions with youth. Community mobilization committees were developed to provide opportunities for RCMP employees to become familiar with community programs available to accept referrals, and facilitate the identification and referral of at-risk youth to treatment programs. Specifically, after an RCMP employee completes the risk screening tool to determine whether an at-risk youth would likely benefit from being diverted away from the criminal justice system, with the permission of the guardians, the youth's file is brought to the attention of the community committee. Committee members, typically made up of provincial and local service providers, will then present all potential services and discuss the best possible options for the youth. Official referrals are then made and the RCMP employee would informally follow-up with the youth.

2.3.3 Enforcement Action Plan Results

Training

One of the key inputs into the RCMP's enforcement activities was developing highly-trained RMs. RMs occupying illicit drug enforcement positions need an intrinsic understanding of organized crime in order to move investigations forward, as well as an understanding of chemistry and how to safely enter and dismantle ad hoc clandestine labs. As a result, extensive training is necessary to ensure the integrity of investigations, the health and safety of RMs, and the overall sustainability of the RCMP's illicit drug response capability. As such, anyone who occupies a position on a synthetic team must be trained. Specifically, the Ontario Police College and the Canadian Police College (CPC) offer eleven related courses such as Drug Identification training and Advanced Drug Investigative Techniques.

Similarly, to assess drug-impaired driving, the RCMP provides and certifies DREs. The RCMP also worked closely with the CPC to design training on the risks associated to exposure, handling and hazards associated with chemicals and grow op installations. News alerts and internal webpages were also disseminated to RCMP officers to keep them updated on emerging drugs, such as fentanyl, while providing guidance for safe interventions.

Drug seizures

Information obtained from the Situational Awareness Support Unit indicates that the RCMP's drug-related seizures increased from 2014-15 from 35,178 to 37,194 with cannabis, cocaine, methamphetamine, and anabolic steroids remaining the most frequent types of drugs seized. The estimated street value of seizures also increased from 2014-15 from $152 million to $154 million. Drugs were seized most frequently in Montreal, Toronto, and Hamilton. The Evaluation team did not seek to assess the accuracy and validity of the data provided.

It was noted in annual NADS reporting that partnerships, including federal and municipal partnerships, were a key factor that supported the RCMP's ability to engage in enforcement activities. Specifically, the RCMP worked with municipalities where threats were identified, as well as through the Canadian Integrated Response to Organized Crime, a joint initiative of the Canadian Association of Chiefs of Police and the Criminal Intelligence Service Canada, aimed at developing operational coordination between local, municipal, and federal enforcement agencies.^{Bibliography 11}

Each year the RCMP seeks to measure the number of joint forces operations that it engages in by fiscal year. The RCMP's involvement ranged from 18 to 32 joint forces operations per fiscal year during the reference period. For example, the RCMP worked with the Canada Revenue Agency to leverage revenue strategies to prosecute those involved in drug operations such as tax evasion. The RCMP worked jointly with Canada Border Services Agency (CBSA) to target precursors arriving at tactical points of entry into Canada (Project Catalyst). From 2012-14, in the response to crime groups exploiting the Marihuana Medical Access Regulations, the RCMP supported Health Canada in the drafting of amendments to the Marihuana Medical Access Regulations.^{End note d}

Investigation of major organized crime groups supported by partnerships

Developing the RCMP's intelligence capacity to support enforcement activities was a focus during the time under review. For instance, many of the discovered MGOs were a result of proactive intelligence gathering. Similarly, the RCMP focused on developing its connections with community organizations and the private sector in order to support intelligence gathering activities related to synthetic drugs (e.g., Canadian Association of Chemical Distributors, Canadian Fertilizer Institute, and Chemistry Industry Association of Canada). For instance, an initiative titled Chem Watch was implemented to sensitize the industry on the issues at hand and engage these players in addressing the problems linked to the diversion and the use of their chemicals in the illicit production of synthetic drugs. As a result of these types of engagements, industry partners provided intelligence that supported seizures. In addition, the RCMP established an "alert-bulletin" system for a series of unregulated essential chemicals that has been sought after by organized crime for the production of synthetic drugs. This resulted in many tips which allowed investigators to establish new investigations.

Interception and disruption of major international drug trade investigations

From 2011-15, the RCMP leveraged partnerships with various international organizations (e.g., the G8, United Nations Office on Drugs and Crime, Organization of American States) and individual countries (e.g., India and China) in order to circumvent the illegal diversion of chemicals from those countries into Canada.

The RCMP's International Liaison Officers provided direct assistance and support by working with counterparts in the countries within their areas of responsibility to advance police operations, support intelligence gathering and the sharing of best practices. Furthermore, as a means of fostering relations and encouraging information sharing, the RCMP invested in building capacity in source countries, focusing on synthetic drug operations and chemical diversion programming. The RCMP also welcomed international delegations to Canada to share procedures and investigative methods when dealing with MGOs (e.g., European Union Seminars on Cannabis and Organized Crime in 2011-12). Additionally, RMs engaged with international chemical companies with the goal of developing a mechanism for "real-time" information exchanges on precursor chemical shipments destined for Canada. Finally, the RCMP worked with international partners to support enforcement activities in Canada. For the last several years, the RCMP has participated in INTERPOL's Operation Pangea, which targets online counterfeit and unlicensed medicines. In 2013-14, Operation Pangea VI spanned 100 countries and resulted in the seizure of counterfeit and illicit drugs, with an estimated street value of $36 million USD.^{Bibliography 12}

Drug Recognition Expert Program

Each year, CAP receives NADS funding to support its National Traffic Services to specifically contribute to the RCMP's national strategy to reduce the number of impaired drivers on Canadian roadways.^{Bibliography 13} The strategy focuses on increasing public awareness and organizing enforcement initiatives across Divisions, with special attention paid to the growing concern of drug-impaired driving. During the reference period, the program had 471 DREs across Canada. In 2015 there were 1,889 operational DRE evaluations. Of these 1,889 evaluations there were 1,615 cases that were pursued by DRE investigators for charges and provincial administrative sanctions. Over the time of the evaluation review, the RCMP worked closely with Justice to explore new tools to facilitate the detection and identification of drug-impaired drivers and RCMP continued to update its courses for the DRE program.^{Bibliography 14}

2.4 NADS Knowledge Exchange Strategy

The NADS KES was born out of the findings and recommendations of the 2012 NADS Evaluation. The 2012 evaluation identified challenges in disseminating knowledge, best practices, and research findings to potential users, and recommended that a mechanism for disseminating knowledge between federal partners be established to ensure that the results and information developed from the federal investment are accessible and used by stakeholders and other government departments. Since KES was developed, RCMP representatives have attended three meetings, the most recent being in November 2015.

Interviewees expressed general concern that the challenge in harnessing NADS' KES is the diversity of roles and responsibilities of the 13 partners involved. Instead, interviewees found knowledge exchange through targeted partnerships to be of more value. The RCMP contributed to KES goals through working partnerships with policing agencies, enforcement-relevant partners such as CBSA, academic institutions, non-governmental organizations, and community groups. The RCMP also worked to circulate information more broadly through NADS-related web-content to partners and share educational and awareness materials across Canada as well as with international partners in the United States, United Kingdom, North Africa, the Caribbean, Mexico, Taiwan, and Hong Kong.

2.5 RCMP NADS Funding

Broadly, the RCMP receives on-going funding for its drug-related prevention and enforcement activities from three funding sources: the 2003 CDS, the 2007 Enforcement Action Plan of the National Anti-Drug Strategy, and the 2007 Investments in the Prevention and Treatment Action Plans of the National Anti-Drug Strategy which ended in FY 2011-12.

The RCMP received a total of $3.6 million over five years (2007-08 to 2011-12) from the Treatment Action Plans in order to support CAP's efforts to "enhance the ability of RCMP officers to refer youth with substance abuse problems into assessment and treatment as well as to assist their reintegration into the community." No ongoing funding was allocated for treatment to the RCMP after 2012.

In accordance with the NADS funding commitments, the RCMP planned spending was $25.4 million in annual ongoing funding for public engagement and enforcement activities from 2012-13 to 2014-15; however, this amount decreased to $21.7 million (including $2.8 M for PWGSC) in 2015-16 due to cost containment and efficiency exercises.^{Bibliography 15}

Table 2 below provides actual spending for RCMP NADS activities from 2011-12 to 2015-16. A comparison of spending to planned spending results in a variance of up to $9.0M in a given year. Explanations provided for the variances included funding re-allocation based on re-prioritization, budget pressures and the Deficit Reduction Program.

3.0 Conclusion

Addressing crime associated with illicit drugs is within the mandate and roles and responsibilities of the RCMP. As such, key interviewees emphasized the continued need for the RCMP to work under the NADS framework.

The RCMP collects data and information on drug enforcement and prevention activities, not only to support police operations, but also to address external needs. To support these internal and external reporting needs, the RCMP continues to focus on improving the consistency and accuracy of its data.

The RCMP contributed to the NADS outcomes under all three Action Plans. Under the Prevention Action Plan, the RCMP contributed to knowledge products, resources, and tools to inform, support, and deliver outreach aimed at preventing illicit drug use. Nevertheless, the evaluation revealed that prevention activities, delivered by CAP and Federal Policing, would benefit from improved coordination. Although involvement ended in fiscal year 2011-12, the RCMP contributed to the Treatment Action Plan via the NYIDP. Finally, under the Enforcement Action Plan, the RCMP engaged in numerous activities related to training, drug seizures, investigations of major organized crime groups, the interception and disruption of major international drug trade activities, and the enforcement of impaired drivers.

4.0 End notes and bibliography

Date modified:

1969-12-31