CISSA-ACSEI And OCASI dISCuSSIOn PAPEr:

Charting a New Direction

Updated September 2017

3CISSA-ACSEI and OCASI: Charting A New Direction

Contents

Context� � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 4

Recommendations for Consideration � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 6

n Length of Contribution Agreements � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 7

n Carry Over of Unused Funds � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 7

n Cash Flow Projections � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 7

n Reinvestment of Contribution Agreement Funds � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 7

n New Program Funding Mechanism � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 8

n Program Outcome Framework � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 8

n Contribution Agreement Budget Line Items � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 8

n Local Immigration Partnership Table Funding � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 8

n Administrative Fee Guidelines � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 8

n Shared Front-End Office Guidelines � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 9

n Contribution Agreement Negotiation Timeframe � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 9

n SPO Issuance of Honorariums � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 9

n Support Services � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 9

n Merge Contribution Agreements � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 9

n Compensation and Service Output Targets � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 9

Conclusion � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �11

4 CISSA-ACSEI and OCASI: Charting A New Direction

Context

The settlement sector has had a longstanding partnership with the Department of Immigration, Refugee and Citizenship Canada over the past many years. As a sector, we have done remarkable work through numerous challenges including the BC and Manitoba repatriation, national implementation of the iCARE database system and most recently, Operation Syrian Refugee – all of these examples illustrate that we are a trusted partner. We believe it is time to enter into a new respectful relationship that would allow some administrative efficiencies for the department and the sector while still maintaining a rigorous focus on outcomes, reporting, accountability and innovation. Achieving strong outcomes for immigrants/refugees and the program are a mutual and central concern by both the sector and the department.

The settlement sector believes there are numerous opportunities within the contribution agreement framework to position ourselves to respond to higher immigration levels while maintaining rigorous accountability for public funds and introducing new outcome based reporting requirements.

The settlement sector and IRCC finds itself at an interesting juncture as we look to the future with significantly higher immigration levels as well as greater importance and national attention on our “collective” work. The following are some of our recent observations:

n Canada faces major economic challenges caused by the gradual retirement of baby boomers. The demographic shift is expected to shrink work-force participation, erode labour productivity and drive up expenditures for things like elderly benefits;

n The Advisory Council on Economic Growth advised the Government of Canada in 2016 to increase immigration levels to 450,000 annually as one step to address the projected challenges to the Canadian economy;

n On October 31, 2016 Minister McCallum announced a new immigration baseline of 300,000 per year starting in 2017 along with a signal of future higher immigration levels and a three-five year (3-5) immigration levels plan;

n The previous federal government introduced significant funding reductions and restructuring within the Department both in Canada and overseas;

n When fully released, over $25 million annually will be redirected to overseas pre arrival services at the expense of post arrival settlement and language programming needs;

n For decades now IRCC has contracted with many of the current service providers and as such, understands the strength and value added contributions that they provide within the context of nation building. Most contracted service providers have extensive working relationships with the department with proven track records of delivering high quality programming that often meets and/or exceeds contractual agreements;

5CISSA-ACSEI and OCASI: Charting A New Direction

From the sector’s vantage point we see a growing need for the department to better engage directly with local communities including on local immigration partnership tables (LIPs) as partners working together on the diverse impact of immigration in this country.

The sector is concerned about a lack of efficiency and opportunity to properly invest and manage additional funds earmarked for Operation Syrian refugees. Contracted service providers were informed four (4) months prior to the end of the 2015-2016 fiscal year and then again for the 2016-17 fiscal year to ramp up services including LINC classes for a three (3) month period before additional services would then have to be completed by the new fiscal year. Beyond the unusual challenges associated with Operation Syrian Refugees, responding to additional IRCC funding in the last quarter of the fiscal year has been common business practice for years.

While the sector appreciates the opportunity to invest additional funds into newcomer settlement needs we feel strongly that there are better ways to do it. Short time funding infusions pose significant human resource challenges for contracted service providers who, in many cases, must rely on recruiting short term contract staff to work on time limited program expansions. It is in our collective best interest to maintain a stable, professional trained and competent workforce within the settlement sector. Contracted service providers having to risk manage and issue layoff notices in uncertain budget times creates unnecessary disruptions and morale issues. This situation adds to the precariousness of work in the sector which impedes the sector’s ability to compete for talent.

6 CISSA-ACSEI and OCASI: Charting A New Direction

CISSA-ACSEI and OCASI would like to acknowledge the progress and improvements that have been introduced in several contribution agreement related areas over the past five years through the collaborative efforts by IRCC and sector colleagues from the National Settlement Council previous working group on Grants and Contributions.

We believe it is important to reflect and build upon two key previous government processes and reports including the Voluntary Sector Initiative (VSI) 2002 Code of Good Practice on Funding and the December 2006 report from the Independent Blue Ribbon Panel on Grant and Contribution Program entitled, “From Red Tape to Clear Results.” Many of the findings and recommendations from the Blue Ribbon panel are as relevant today as they were in 2006, specifically on ways to dramatically simplify the reporting and accountability regime. As stated in the report, it is “possible to simplify administration while strengthening accountability.” This is one of the sectors’ key goals.

“Charting A New Direction” discussion paper brings together current insights and experiences from the sector in no specific order. We offer fifteen (15) areas/recommendations as well as proposed solutions and rationale based on current service provider experiences across Canada. Please note that we drew on current practises of other federal departments for some of our recommendations.

recommendations for Consideration

Recommendations Rationale / ImpactLength of Contribution Agreements

Move to five (5) year contribution agreement (CA’s) with the next CFP in 2019

n Moving from three (3) to five (5) year CA terms better aligns with Treasury Board Program Evaluation cycle;

n Lessens the burden on IRCC operation staff and the settlement sector;

n Responding to emerging newcomer needs or service gaps is addressed within a more flexible CA guidelines and new proposed innovation program funding; and,

n Allow for some adjustments within the budget figures each year; and innovative projects or expansions should be added with additional budget as immigration levels increase

CArry over of unused funds

Allow contracted service providers to carry over all unused funds into the subsequent year of a signed CA term

n No need for lengthy and unnecessary decommissioning fund discussions as unallocated funds would, in most cases, automatically be carried over into the subsequent year.

n Contracted service providers would submit final year-end financial statements outlining how funds would be invested in the subsequent fiscal year. Any slippage, along with plans on how funds would be proposed for reinvestment, would be submitted under a straight-forward reporting function to IRCC.

n Too much administrative time is wasted in negotiating reinvestments plans and/or decommissioning funds;

NOTE: Global Affairs, which contracts five (5) year contribution agreements, allows contracted service providers to carry over funds into subsequent fiscal years. As well, contractors are able to negotiate at the end of their five (5) year CA the ability to invest any remaining unused funds within the subsequent three (3) month period after the agreement has expired.

CAsh fLow ProjeCtions

Remove the need for cash flow projections.

Currently, cash flow projections must be submitted at the beginning of a fiscal year on a best guess scenario of how contracted service providers will roll out programming. Cash flow projections must be resubmitted on a quarterly basis when there are changes of more than fifteen percent (15%). Most contracted service providers will likely divide the CA amount into twelve (12) equal installments onto their cash flow projection unless there are obvious programming and/or arrival spikes during the year.

n Contracted service providers build their own annual and monthly budgets, maintain their own monthly financial statement and variance reporting and undertake annual audited financial statements which, in turn, allows IRCC to undertake periodic financial monitoring on an, as and when, needed basis.

n It is not an efficient use of time to investigate the discrepancies between cash flow projections and actual expenditures, when funds are spent within contract value and budgetary guidelines.

reinvestment of Contribution Agreement funds

Allow contracted service providers to address new and emerging issues e.g. need for additional classes, specific program enhancements, etc within available CA funds without having to negotiate approval. Let contracted service providers report out on how needs were addressed.

Disallow settlement officers ability to question every SPO decisions within the agreed upon 15% rule.

Revise allocations for direct vs indirect service provision to allow for the possibility of greater allocation to indirect, where appropriate.

n Too much unnecessary time is spent negotiating reinvestments based on gaps that agencies bring forward than simply acting on those gaps. This inefficiency delays the start of a program or class and has a direct impact, as an example, on client outcomes and their settlement process.

n Allowing IRCC settlement officers the ability to question every SPO decision although we have in place the ability to move funds around up to fifteen percent (15%) currently contradicts the original intent of this policy change as if it were never in place.

CISSA-ACSEI and OCASI: Charting A New Direction 7

Recommendations Rationale / Impactnew ProgrAm funding meChAnism

IRCC should develop an annual national innovation project budget and proposal process with submission received on a quarterly basis to address new and emerging issues.

n A new more flexible funding mechanism would allow the sector to initiate innovative pilots while being more responsive in addressing new and emerging needs.

n This new suggested funding mechanism would complement proposed changes within existing CA structure to reduce the bureaucracy and increase the flexibility of SPO’s to reinvest funding slippage.

ProgrAm outCome frAmework

Review the current national settlement program outcome framework and work collaboratively with the sector to develop new national outcome measurements.

We need to develop some qualitative outcome indicators. Contracted service providers need to report a combination of quantitative and qualitative.

The current reporting requirements does not tell the full impact of our work across Canada and hence, impacts the departments’ ability to fully articulate the accountability for current funds and the importance of these investments.

n While tremendous inroads have been made in recent years with the introduction of iCARE reporting as well as quarterly and annual narrative reporting e.g. APPR, we feel we need to develop national outcome measurements for settlement programming.

n We also need to review the value of current narrative reporting to determine how it is being used and analyzed by the department. If, for example, contracted service providers are restating the same program gaps over several years e.g. need for trauma support programs in settlement or child care in RAP and there are no changes to the respective Treasury Board Terms and Conditions what is the value of raising the same issues again?

n The proposed new national outcome based reporting could be completed by clients in their own language on line or through telephone surveys conducted by agency staff. These new settlement outcome indicators would include such things as “I have a better understanding of working in Canada,” “I feel more confident in speaking English” – these are examples of the possible types of outcome statements that could be directly attributed to IRCC settlement program investments.

Contribution Agreement budget Line items

Review specific budget line items within current CA’s to determine if any additional line items can be collapsed within broader budget categories.

The sector would also like to explore the notion of negotiating a CA(s) with a global budget that does not breakdown costs between staffing and overhead categories.

n Collapsing line items creates greater flexibility and efficiency for both the sector and IRCC.

LoCAL immigrAtion PArtnershiP tAbLe funding

Funding for local immigration partnership tables should be awarded as grant funding not CA.

n CA funding structure does not work for LIPs and community development type approaches where the deliverables are developmental, flexible, emergent and responsive. Asking LIPs to identify the number and cost of workshops they will hold for a year in advance is counter-intuitive to responding to community needs, interests and requests.

AdministrAtive fee guideLines

Further discussions are needed with the sector on how IRCC defines the cost categories eligible within the administration fees.

The sector would like to request that for instance, telephones, internet charges, computers, program supplies and rent including portion of common area space for program delivery staff and their respective front-line Managers that help deliver programming be included as program delivery costs not administration costs. Front-line staff working with newcomer clients need a phone to deliver their services. As such, for example, the total cost of the phone should be incorporated as a program delivery cost.

n The up to a maximum of fifteen percent (15%) administration fee and the subsequent breakdown of what does or does not belong is still not clear and must be addressed. Inconsistency and time spent splitting these costs creates administrative burden.

n While the Government of Canada / Treasury Board guidelines may allocate all civil servant phones as part of administration this does not translate to the delivery of client service programming.

n IRCC NHQ may think they are assisting the sector to have, for example, all phones, internet, computers placed within admin fee, but in most cases this approach means surpassing the 15% maximum allowable administration fee.

n Too much time is being spent on negotiating what is or is not part of program delivery costs.

8 CISSA-ACSEI and OCASI: Charting A New Direction

Recommendations Rationale / ImpactshAred front-end offiCe guideLines

Develop guidelines and support practices for shared-front office. For example, multi-use buildings – classrooms used by IRCC-funded programming in the daytime and non-IRCC-funded programming after hours. Or staff who are shared between federal-provincial funding.

n In some regions where both IRCC and the Province co-fund settlement services, complications arise due to a lack of clarity and flexibility of co-funded staff and space.

Contribution Agreement negotiAtion timefrAme

IRCC needs to complete CA negotiations six months prior to program commencing and/or provide proper support for SPOs when funding is reduced/cut such as to cover associated costs pertaining to severance, contract penalties, lease commitments etc.

n The notification of program or CA termination and/or significant changes within CA is insufficient to risk manage the HR and lease issues faced by contracted service providers.

sPo issuAnCe of honorAriums

IRCC needs to allow and issue guidelines on SPO issuance of honorariums to newcomers involved in community development work.

n The ineligibility of paying honorarium to newcomers in community development work is a challenge to having flexible, responsive and relevant human resources for emerging newcomer populations and for all youth and marginalized populations. We would like to see openness to concepts of paid peer workers as key informants, community facilitators, service navigators, and outreach animators. We also need to have professional development budgets to give training to peer workers who may have non-traditional training and credentials.

suPPort serviCes

Review support services – twenty percent (20%) cap on client support services.

n The current cap is greatly affecting the ability of organizations to meet client needs, especially for contracted service providers in smaller centre, those with a specific expertise or specialization (eg: those that specialize in community-based ESL with CNC; organizations with expertise in crisis counselling)

merge Contribution Agreements

SPOs hold multiple CA’s in many cases. Currently, there exists a maximum value allowed within a CA held by a not for profit provider. Is it possible to raise the maximum allowable funding value per CA and where requested by a SPO, allow the amalgamation of multiple CA’s into one or two?

n Reducing the number of CA’s creates greater flexibility and efficiencies by SPOs in the delivery of their respective settlement programming.

ComPensAtion And serviCe outPut tArgets

While SPO’s, as employers, set the compensation rates for their respective employees IRCC often sets guidelines on the maximum percentage for wage increases in any given year. The sector would like to work with IRCC to review compensation levels e.g. explore putting in place minimum wage rates as well as national guidelines for service outputs by specific settlement positions. For example, a settlement worker position, regardless of their location in the country, would have the same range of service-client targets.

n With the growing labour market shortages across Canada and increase cost of living, SPO’s are facing increasing challenges to recruit and retain employees. At the same time, like other segments of society, the sector is also facing an accelerated rate of retirements for the foreseeable future. The settlement sector is concerned that with the imposed IRCC wage guidelines and in some regions stagnant wages, we are lagging behind in our compensation further reducing our competitiveness within the social service sector.

CISSA-ACSEI and OCASI: Charting A New Direction 9

ThIS pAgE hAS bEEn lEfT InTEnTIOnAlly blAnk.

10 CISSA-ACSEI and OCASI: Charting A New Direction

11CISSA-ACSEI and OCASI: Charting A New Direction

Conclusion

As already stated, the settlement sector is keen to explore in collaboration with the department the recommendations outlined in this discussion paper. We remain convinced that there are opportunities to chart a new direction that will better position us to respond to higher immigration levels as well as introduce increased efficiencies while enhancing accountability for current investments.