Internal Audit Report - Audit of the Building Canada Fund - Communities Component

February 2012

Approved by the Deputy Minister on February 21, 2012

Table of Contents

  1. Executive Summary
  2. Background
  3. Audit Objectives
  4. Audit Scope
  5. Audit Approach
  6. Audit Findings
  7. Audit Opinion
  8. Statement of Assurance

Appendix A: Audit Criteria

1 Executive Summary

The Government of Canada's Budget 2007 announced the Building Canada Plan which is a seven-year, $33 billion initiative to provide long-term, predictable, and flexible infrastructure funding to provinces and territories. Under the Building Canada Plan, $8.8 billion was allocated to the Building Canada Fund (BCF) which includes the Major Infrastructure Component and the Communities Component (CC). The Communities Component targets local priorities and is restricted to communities with less than 100,000 people (based on the 2006 Census). In Budget 2009 – Canada's Economic Action Plan, the federal government announced an additional $500 million to "top-up" the Communities Component as a means of stimulating the Canadian economy over the 2009-10 and 2010-11 fiscal years. In December 2010, the federal government announced an extension to the CC Top-Up program whereby projects originally required to be completed by March 31st, 2011 could be granted an extension to October 31st, 2011.

The objective of the BCF-CC Audit was to provide a reasonable level of assurance that:

  • Infrastructure Canada (INFC) has assurance that the BCF-CC program is administered in compliance with the relevant terms and conditions of the program by the program management and delivery partners and that the terms and conditions related to the CC Top-up and CC Top-up Extension are met.
  • Program information used in INFC decision-making, monitoring and reporting is adequate and updated in a timely manner.

The audit was conducted in accordance with the Internal Auditing Standards for the Government of Canada and the International Standards for the Professional Practice of Internal Auditing.

Based on the audit evidence, it was found that most program information used in INFC decision-making, monitoring and reporting was adequate although there was limited evidence that the data was updated in a timely manner. In addition, while most terms and conditions related to the CC Top-up and CC Top-up Extension were met, INFC had limited formal assurance that the BCF-CC program has been administered in compliance with its funding and service level agreements.

The audit also identified areas where management could strengthen program delivery for BCF-CC and future programs:

  • Procedures may be required to discard redundant agreement requirements and to improve INFC's ability to enforce performance of key CA and SLA terms and conditions.
  • Procedures may be required to formalize the analysis of the program audit reports in order to ensure that the specific assurance required is received from each province.
  • INFC needs to formalize its documentation strategy to support program delivery.

It is recognized that the introduction of the Economic Action Plan funds to the BCF-CC program required management to focus on delivering the Top-Up funds, monitoring the progress of Top-Up projects, and managing potential risks to project completion within the timelines set by Parliament. Overall, management was successful in adapting to the changing program requirements.

Management is in agreement with the audit findings and recommendations. Management has developed action plans to address the recommendations and these action plans have been included in the report.

Original signed by

Inanc Yazar
Director of Internal Audit
for Infrastructure Canada

Date

Laura Ruzzier
Chief Audit and Evaluation Executive
for Infrastructure Canada and Transport Canada

Date

2 Background

The Government of Canada's Budget 2007 announced the Building Canada Plan which is a seven-year, $33 billion initiative to provide long-term, predictable, and flexible infrastructure funding to provinces and territories. Under the Building Canada Plan, $8.8 billion was allocated to the Building Canada Fund which includes the Major Infrastructure Component and the Communities Component (CC). The Communities Component targets local priorities and is restricted to communities with less than 100,000 people (based on the 2006 Census).

In Budget 2009 – Canada's Economic Action Plan, the federal government announced an additional $500 million to "top-up" the Communities Component as a means of stimulating the Canadian economy over the 2009-10 and 2010-11 fiscal years. In December 2010, the federal government announced an extension to the CC Top-Up program whereby projects originally required to be completed by March 31st, 2011 could be granted an extension to October 31st, 2011.

The program is administered and delivered by Infrastructure Canada, the provinces, and the Federal Delivery Partners (FDP). INFC has signed both Infrastructure Framework Agreements and Contribution Agreements with the provinces. These agreements outline the program roles and responsibilities of each party. In August 2010, INFC entered into a Service Level Agreement with the four FDPs which defines their roles and responsibilities with respect to the program's oversight, financial management, environmental assessments, information management, and performance reporting.

In addition, there are a number of governance and oversight mechanisms in place for the Communities Component program which include the Joint Secretariats, the Communities Component Oversight Committees, the Service Level Agreement Management Committee, the Communities Component and Communities Component Top-Up Committee, and the INFC-FDP Director General Level Committee.

3 Audit Objectives

The objective of the BCF-CC Audit was to provide a reasonable level of assurance that:

Objective 1: INFC has assurance that the BCF-CC program is administered in compliance with the relevant terms and conditions of the program by the program management and delivery partners and that the terms and conditions related to the CC Top-up and CC Top-up Extension are met.

Objective 2: Program information used in INFC decision-making, monitoring and reporting is adequate and updated in a timely manner.

4 Audit Scope

The scope of the audit involved an examination of the work undertaken by INFC in relation to the BCF-CC program for the period from program approval to June 2nd, 2011. The audit included an examination of pertinent program documentation, as well as the management systems, practices and controls in place related to INFC's program administration and delivery.

The audit did not include an examination of the procedure and practices in place within the program delivery partners' organizations.

5 Audit Approach

The audit was conducted in accordance with the Internal Auditing Standards for the Government of Canada and the International Standards for the Professional Practice of Internal Auditing.

The examination phase of this audit began in June 2011 and was substantially completed in November 2011. The examination employed various techniques including interviews and review of financial and non-financial documentation.

A risk-based judgmental sampling methodology was used to determine the samples used during the examination phase of the audit. The sample included examples of reporting, auditing, financial, and oversight documentation from several program delivery partners.

The sample served as an indicator of the documentation in place to support program delivery. Since this was not a statistical sample, the results cannot be extrapolated to all program documents from all program delivery partners.

For purposes of this report, the residual risk ranking associated with findings used a low, moderate, high three-point scale and were subjectively judged based on knowledge of the program delivery gathered during the audit. The subjective criteria are:

High Threats/Opportunities may have very significant impacts on INFC's Priorities and Strategic Outcomes, are imminently likely and either no or uncertain mitigation measures are in place.
Moderate Threats/Opportunities may have significant impacts on INFC's Priorities and Strategic Outcomes, have a longer-term likelihood and reliable mitigation measures can be established.
Low Threats/Opportunities may not create a significant residual risk to INFC's Priorities and Strategic Outcomes in the immediate to medium term if mitigation measures are implemented.

6 Audit Findings

6.1 Opportunities to Simplify Program Design

The Clerk of the Privy Council stated in his 2010-2011 Public Service Renewal Action Plan that "the way ahead will involve empowering public servants at all levels to find new, more cost-effective ways to deliver better services to Canadians and provide higher quality advice to our Government." Innovation is one specific area that supports workplace renewal. It is about doing things differently in ways that are more effective and more efficient and reducing unnecessary rules and reporting.

It was expected that program design would share program delivery responsibilities between the program delivery partners in an efficient manner that did not create redundancy or unnecessary administration.

Audit Observation - Opportunities to Simplify Program Design

Observation
Low Risk

The Building Canada Fund - Communities Component program was designed to share program delivery between the provinces, the Federal Delivery Partners, and INFC. Additional program oversight was implemented with the creation of ten provincial Oversight Committees and nine supporting Joint Secretariats.

Composition and Responsibilities of Oversight Bodies

It was found that the Oversight Committees were composed of FDP and INFC members and their Joint Secretariats were composed of members from each province and the regional FDP. While each Committee and its Secretariat provided additional oversight to the project selection process, the financial claim processes, and the auditing requirements of the Contribution Agreements, each body required its own Terms of Reference, formal meetings, the preparation of meeting minutes, and administrative efforts.

The work of each Oversight Committee and Joint Secretariat was performed by the three program delivery partners who administer the program and did not need to be formally reported back to them. The additional formality of meeting minutes and written decisions and recommendations as mandated in the Contribution Agreements did not appear necessary.

The Joint Secretariat and the Oversight Committee were established as separate oversight bodies with defined roles in the Contribution Agreement between each province and Canada, as represented by the Minister of Transportation, Infrastructure, and Communities.

It was found that Contribution Agreement deliverables that required submission of documentation to INFC from an oversight body were accepted by INFC from individual program delivery partners. Given that INFC was not enforcing the distinction between the oversight bodies and the program delivery partners, the additional resources required to establish and administer these separate oversight bodies did not appear necessary.

The administrative redundancy was caused by INFC in its efforts to demonstrate strong stewardship of the program. The program design included additional oversight bodies comprised of the three program delivery partners who worked to reduce the risk associated with project assessment, project selection, and claims. The oversight bodies also oversaw risk mitigation measures such as financial and compliance audit requirements. The subsequent reduction of operational efficiency was not considered.

The impact of an Oversight Committee and its Joint Secretariat in each province is that the increased expense and effort of administering nineteen oversight bodies is likely not justified when the same roles and responsibilities could be assigned directly to the program delivery partners who currently make up the oversight bodies.

Design of Quebec Contribution Agreement

Contribution Agreements were used to establish the terms and conditions that the provinces and Canada were to adhere to during program implementation. A template was designed by INFC to indicate key terms and conditions that would require consideration during agreement negotiations with each province. It was understood that since CAs were negotiated separately with each province, their contents varied but the main terms and conditions were to be included in each agreement.

It was found that the CA between Quebec and Canada had several distinct terms and conditions with respect to program oversight, reporting, and audit requirements. The oversight was modified to eliminate the need for a Joint Secretariat. The reporting requirements were streamlined for the annual, quarterly, and monthly reporting and the fiscal year forecasts. The program auditing responsibilities were re-allocated to INFC and the recipient audit requirements were no longer needed given Quebec's existing audit strategy.

The Quebec CA was not patterned on the Communities Component CA template because the template did not incorporate the distinct terms and conditions of previous Quebec funding agreements.

The impact of Quebec's streamlined CA is that program delivery involves less overall program administration by Quebec and INFC.

Acceptance Criteria for Program Deliverables

The CA required that the provinces submit specific deliverables during the life of the program. It was found that there were no terms or conditions that INFC could use to accept or reject the deliverables based on their quality.

The CAs did not include acceptance criteria or quality assessment criteria for the deliverables because INFC has historically relied on good working relationships with the provinces to negotiate the desired changes to the CA deliverables.

There is a risk to INFC that a province may not be willing to make changes to the quality of its deliverables if the deliverables do not meet INFC's expectations. This situation may occur if the change requires additional cost or increased work. INFC would have no options to address this situation because the requirements of the CA were satisfied when the deliverable was submitted to INFC.

Lessons Learned for Future Program Design

For future programs, the Assistant Deputy Ministers of Policy and Communications and Program Operations Branches should consider potential redundancies created by the establishment of additional oversight bodies composed of organizations who are already involved in the administration of the program. If work is required to be performed jointly, those tasks could be assigned to the organizations directly in the agreements that define their role and responsibilities in program delivery.

For future programs, the Assistant Deputy Ministers of Policy and Communications and Program Operations Branches should consider, at the planning stage, the different agreements that have been signed by different provinces in order to address potential limitations that may apply to the program delivery in some provinces. This consultative process will address regional differences prior to CA negotiations.

For future programs, the Assistant Deputy Minister of Program Operations Branch should develop formal understandings with its program delivery partners which explain how INFC would assess the quality of reporting and audit deliverables.

6.2 Enforcement of CA Terms and Conditions

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

It was expected that program management would promote program accountabilities by enforcing the requirements of key agreements in order to ensure that program delivery was performed as per the approved terms and conditions.

Audit Observation - Enforcement of Contribution Agreement Terms and Conditions

Observations
Low Risk

During program design, potential risks to the program were considered and mitigated as appropriate by the terms and conditions put in place by the program delivery partners and agreed to in the Contribution Agreement between the provinces and Canada, as represented by the Minister of Transportation, Infrastructure, and Communities. As the program changed with the introduction of the Top-Up funds, the CAs were amended to reflect the new terms and conditions required to address the new potential risks. The CAs were amended a second time to address the next significant program change which was the introduction of a construction extension for qualifying Top-Up projects. With the subsequent introduction of the Service Level Agreement, additional terms and conditions were put in place between INFC and the regional Federal Delivery Partners to further update the program design.

While it was found that INFC did enforce some reporting requirements, there were many financial and non-financial reporting requirements, auditing requirements, and a project selection requirement that were not enforced during the program. INFC did enforce the requirement to submit almost all of the annual progress reports by the provinces and the financial forecasts by the regional FDPs. It was found that the submission of non-financial reporting with specific informational requirements was not always enforced for provincial quarterly progress reports, monthly construction and signage reports, or monthly narratives. The submission of financial reports with specific reporting frequencies or their submission prior to the implementation of the Service Level Agreement was not always enforced. Multi-year financial forecasts were not reported using the frequency established in the SLA. Cash flow forecasts and the specific supporting information required for claim processing were not enforced. In addition, the auditing requirements identified in the original provincial CAs and their first amendments were not enforced by INFC for most provinces. It is acknowledged that with the newest deadline to deliver program audit reports in the latest amendments to the CAs, the provinces are in compliance with their agreements. While most of the reporting needs could be satisfied using alternative reports, the gaps in the project rating, claim reporting, and auditing processes were not mitigated.

INFC management informally determined that appropriate alternate mechanisms were in place to satisfy the spirit of the CA requirement and that some CA requirements were not necessary for program implementation. Management felt that the use of rating criteria approved for other INFC programs and multiple levels of claim review were acceptable substitutes to specific terms and conditions of the CA. Moreover, Management determined that some CA requirements were not needed for decision-making or risk management purposes such as redundant reports or frequent updates to long-term financial forecasts. Consequently, Management did not follow up when CA requirements were not met.

The impact of INFC's lack of enforcement of the terms and conditions of the CA and SLA is that not all aspects of program implementation may have been sufficient to mitigate potential program risks.

Recommendations Management Action Plan

1.a It is recommended that the Assistant Deputy Minister of Program Operations Branch identify those CA or SLA terms and conditions where compliance from the program delivery partners is not required. These terms and conditions could be discarded via written agreement by the parties to the CA or the SLA.

1.a (i) The Program Operations Branch (POB) will undertake a review of the SLA to identify terms and conditions where FDP compliance is not required.

(ii) Once review of the SLA is complete, POB will engage FDPs to amend the SLA to remove all identified clauses where compliance is not required.

(iii) POB will also review CAs to identify terms and conditions where the compliance of the provinces is not required.

(iv) Once review of the CAs is complete, POB will identify those terms and conditions that are not deemed necessary in a written agreement with the provinces.

Assistant Deputy Minister Responsible: Assistant Deputy Minister, Program Operations Branch
Due Date: (i) May 2012
(ii) October 2012
(iii) May 2012
(iv) October 2012

1.b It is recommended that the Assistant Deputy Minister of Program Operations Branch implement procedures that analysts can use to monitor the program delivery partners' compliance with necessary terms and conditions of the CA or SLA. The procedures should include guidance on how to enforce performance when it does not occur.

1.b Post substantial completion of the audit testing, POB has developed three key tools to monitor program delivery partners' compliance with terms and conditions of the SLA. As INFC has largely delegated oversight of compliance with the CA to FDPs, these tools ensure that:

  • INFC has a mechanism in place to regularly monitor whether or not the FDPs have met their SLA obligations;
  • INFC and the FDP are able to discuss and coordinate the Federal position in advance of dealings with the province; and,
  • There is a forum to address performance issues related to the CA and/or the SLA

(i) In September 2011, post substantial completion of audit testing, POB introduced a quarterly report on the status of the Building Canada Fund – Communities Component (BCF-CC). This report is written by POB analysts and is designed to increase oversight of FDP compliance with SLA requirements. Going forward, POB will update the report's structure to ensure it adequately addresses whether terms and conditions of the CA have been met.

(ii) POB has been working with FDPs to update requirements for the FDP Annual Performance Report (currently Schedules F and G of the SLA). This report is written by FDPs and will be based on a new set of service standards that accurately reflect SLA requirements.

(iii) In November 2011, post substantial completion of audit testing, POB and FDPs approved an INFC-FDP Engagement Protocol. This document establishes several guiding principles of engagement, including a commitment to "escalate issues through respective governance structures as efficiently as possible in support of timely resolution" and recommends that regional resolution processes be developed bilaterally with each FDP. Going forward, POB will ensure that these bilateral resolution processes are implemented.

Assistant Deputy Minister Responsible: Assistant Deputy Minister, Program Operations Branch
Due Date: (i) June 2012
(ii) October 2012
(iii) June 2012

6.3 Assurance on the Work of the Program Delivery Partners

The Treasury Board Policy on Internal Control requires that risks relating to the stewardship of public resources are adequately managed through effective internal controls.

Given the multiple delivery partners responsible for program implementation, it was expected that INFC would require external audits to provide assurance with respect to program delivery.

Audit Observation - Assurance on the Work of the Program Delivery Partners

Observation
Medium Risk

The program design included a requirement in each provincial CA that program audits be performed to provide assurance with respect to financial data and overall management of the program by the province. It was found that the frequency and due dates for the program audits were modified repeatedly and that all but two program audits had not been performed prior to substantial completion of this audit. No external assurance with respect to program delivery was available to INFC.

Throughout program implementation, INFC's interactions with other program delivery partners provided informal opportunities to evaluate their partners' program management. It was found that INFC could gain some informal assurance that program delivery partners were considering the terms and conditions of the CA as the partners performed their program responsibilities. The scenario sheets prepared by the Joint Secretariat provided some informal assurance with respect to project assessments. The meeting minutes of the Joint Secretariats, the Oversight Committees, the Service Level Agreement Management Committee, and the INFC-FDPs Director General Level Committee indicated that some CA terms and conditions were addressed during each committee's discussions. The Annual Performance Reports addressed the informational requirements listed in the CAs. Together, this evidence provided limited assurance to INFC with respect to program delivery.

The lack of completed program audits was attributable to the assumption that audits do not add value if projects had not begun construction or did not have significant financial activities and to the increased focus on successfully delivering the Economic Action Plan commitments via the Top-Up funds. Once projects had started construction, the program audits were further delayed as the development of the audit plan took longer than expected.

There is a risk to INFC that the long delay in performing program audits may limit the program delivery partners' ability to address potential program implementation weaknesses that have occurred and for which the processes are now completed. For example, the project selection process, the contracting procedures, and the construction projects funded by Top-Up funds are completed and changes may not be practical if weaknesses are identified during a program audit.

The informal assurance available to INFC from its program delivery partners provides INFC with preliminary feedback on specific elements of program delivery. Formal assurance with respect to comprehensive program delivery will only be available in 2012 when program audit reports are due.

Lesson Learned for Future Program Design

For future programs, the Assistant Deputy Minister of Program Operations Branch should formalize the audit guidance provided in this program and other INFC programs for use in future agreements. Guidance should identify key events that can trigger the need for an audit such as project selection and contracting and should list the key program terms and conditions that require assessment during an audit.

Recommendations Management Action Plan

2. It is recommended that; in order to ensure that the Assistant Deputy Minister of Program Operations Branch receives the specific assurance that is required for program delivery; procedures be formalized to provide analysts with the tools required to evaluate key elements of program audit reports once they are received.

2. POB will work to identify key elements of program audit reports as well as means of effectively evaluating these key elements in consultation with the Audit and Evaluation Branch. POB will then develop procedures to assist its analysts in verifying whether program audit reports contain all necessary information and in conducting an effective review of the audit report. These procedures will also be shared with regional Oversight Committees to aid FDPs in preparation of future audit reports.

Manager Responsible: Assistant Deputy Minister, Program Operations Branch
Due Date: June 2012

6.4 Documentation

The objective of the Treasury Board Policy on Information Management is to achieve efficient and effective information management to support program and service delivery; foster informed decision making; facilitate accountability, transparency, and collaboration; and preserve and ensure access to information and records for the benefit of present and future generations.

It was expected that key documentation would be available to support program delivery including decision-making and performance of key Contribution Agreement or Service Level Agreement requirements.

Audit Observation - Documentation

Observation
Low Risk

The terms and conditions of the program were established in the Contribution Agreements between the provinces and Canada, as represented by the Minister of Transportation, Infrastructure, and Communities. Later in the program, additional responsibilities were established between the regional Federal Delivery Partners and Infrastructure Canada in the Service Level Agreement.

It was found that some documentation practices supported decision-making and monitoring with most of the key documentation. The scenario sheets used to document the evidence that application assessments were performed with appropriate consultation were documented to support the initial phase of the project selection process. Most provinces had documentation to support that Building Canada funds were committed prior to committing Top-Up funds. The FDPs ensured that almost all the key project data fields were populated in the project database in compliance with the SLA. In addition, almost all annual progress reports were received from the provinces.

Several examples of weak documentation that might not support the terms and conditions of program implementation were also found. Some documentation did not exist such as evidence of some approvals of rating guides during the project selection process, evidence of report review that occurred verbally, and reports that met the informational requirements of the quarterly reports for only some provinces. Some documentation could not be located such as evidence of timely receipt of some annual, quarterly, and monthly progress reports that were received from the provinces and evidence of most of INFC's review and follow-up when it was required. Some documentation was not provided to INFC as per the deadlines established in the CA such as elements of the documentation required for projects to qualify for an extension to the construction deadline and specific monthly signage and construction reports from some provinces. It is recognized that INFC requested and received some of the missing project extension documents prior to substantial completion of the audit.

The inconsistent approach to documentation stemmed from differences in how INFC analysts monitored each province's performance. In addition, there was a shift in responsibility during program implementation that increased the role and responsibilities of the FDP. This allowed several CA requirements that were the responsibility of INFC to be overlooked.

The impact of inconsistent documentation standards is that key program decisions may not be supported without appropriate documentation. In addition, key program processes such as project assessment and monitoring processes are subjective which may invite challenges to the results of the work performed. Without appropriate supporting documentation, it may be difficult to defend INFC's work.

Recommendations Management Response

3. It is recommended that the Assistant Deputy Minister of Program Operations Branch identify the key documents required to defend, if required, its program implementation and all key decisions that have been made. In addition, a documentation standard to formalize the need to store these key documents is required.

3. (i) Assisted by the audit findings, POB will review and update its existing project files to ensure key documents required to defend its program implementation and decisions are kept.

(ii) POB will also complete a longer-term, cross-program information management initiative to identify, organize, preserve and dispose of key documents holdings in compliance with Treasury Board and INFC policies.

Assistant Deputy Minister Responsible: Assistant Deputy Minister, Program Operations Branch
Due Date: (i) April 2012
(ii) March 2013

7 Audit Opinion

Based on the audit evidence, it was found that most program information used in INFC decision-making, monitoring and reporting was adequate although there was limited evidence that the data was updated in a timely manner. In addition, while most terms and conditions related to the CC Top-up and CC Top-up Extension were met, INFC had limited formal assurance that the BCF-CC program has been administered in compliance with its funding and service level agreements.

The audit also identified areas where management could strengthen program delivery for BCF-CC and future programs:

  • Procedures may be required to discard redundant agreement requirements and to improve INFC's ability to enforce performance of key CA and SLA terms and conditions.
  • Procedures may be required to formalize the analysis of the program audit reports in order to ensure that the specific assurance required is received from each province.
  • INFC needs to formalize its documentation strategy to support program delivery.

It is recognized that the introduction of the Economic Action Plan funds to the BCF-CC program required Management to focus on delivering the Top-Up funds, monitoring the progress of Top-Up projects, and managing potential risks to project completion within the timelines set by Parliament. Overall, Management was successful in adapting to the changing program requirements.

8 Statement of Assurance

In the professional judgment of the Chief Audit and Evaluation Executive, sufficient and appropriate audit procedures have been performed and evidence gathered to support the accuracy of the conclusions reached and contained in this report. The audit findings and conclusions are based on observations and analyses of conditions as they existed on the audit date, against established criteria agreed upon with Management.

The findings are only applicable to the entity examined. The evidence was gathered in accordance with the Internal Auditing Standards for the Government of Canada and the International Standards for the Professional Practice of Internal Auditing.

Appendix A: Audit Criteria

Audit Criteria

  1. The Joint Secretariat performs first level due diligence for project identification and selection and claim review and approval, when required, in an accurate and objective manner.
  2. The Federal Delivery Partners assess, track, and process claims from the Provinces in an accurate manner and report financial and non-financial information accurately and completely.
  3. Provinces meet the Contribution Agreement's terms and conditions related to CC funds.
  4. Provinces meet the Contribution Agreement's terms and conditions related to the CC Top-Up and Provinces that required an extension of the CC Top-Up deadline meet the Contribution Agreement's terms and conditions for the extension.
  5. INFC has assurance that data populated in SIMSI is complete, accurate, and updated in a timely manner.
  6. Where official data is not stored in SIMSI, appropriate controls are in place to help ensure accurate reporting.
  7. Annual, quarterly, or monthly progress reports are received on time, reviewed, and accepted by INFC. Follow-up is performed, as required.
  8. Program and Recipient Audits are received on time, monitored, and accepted by the Oversight Committee. The Audit Report's Management Action Plans are evaluated and monitored, as required.
  9. The Joint INFC-FDP DG Level Committee Meetings occur on a periodic basis and operational issues are reviewed. Follow-up is performed, as required.
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