Currently, the enforcement case management function at ISB is presided over cases using Microsoft Excel and various SharePoint sites (all sites are not uniform in their design) to track and manage these cases regionally and nationally. For ISB to be effective in its obligation to conduct proper enforcement activities, a tool set more suited to the unique needs of enforcement investigations is necessary.
The electronic solution is required to collect and track evidence, control system access, and protect data together with providing support for multi-jurisdictional collaboration while operating within the given legal and Charter constraints.
A uniform national enforcement case management solution is required and must:
1. Be available within time and budget constraints provided by TBS.
2. Ensure that information collected in an investigation is stored and tracked in such a way as to be suitable for use in any case brought to court.
3. Ensure that information collected in an investigation is controlled such that only authorized individuals may have access (Jarvis and Ling (2002)).
4. Ensure that the manner in which information is collected, stored, and reported on is consistent nationally and reports are readily available.
The estimated project completion date for the recommended option is December 2022 with the solution being available to support the Beta testing starting in June 2021 and full production availability by March 2022 at a total cost estimate of 2.8 million dollars.
ISB is seeking the approval from Director General Project Oversight Committee (DGPOC) to proceed to stage 2/3 – Initiation and Planning with the recommended solution of selecting a third-party vendor product that is specialized in the Enforcement workspace.
ISB needs a solution to address the following key challenges:
• National consistency of information contained in the system
• Control over the information maintained in the system, keeping an audit trail on evidence contained such that its utility in court proceedings is assured
• Elevated risk of securing data across diverse case systems
• Compatibility with external agencies
• National standards for reporting and quality monitoring
The Enforcement function is in need of an effective case management system capable of supporting effective workload management, unified case management, the release of quality court documents, tracking of evidence and reporting. The Office of the Auditor General (OAG), in its 2017 spring report “Managing the Risk of Fraud”, noted the following “fraud in a federal government organization can cause the loss of public money or property, hurt employee morale, and undermine Canadians’ confidence in public services. Therefore, federal organizations must manage their fraud risks.”1 The lack of an effective case management system within ISB is limiting the ability of ISB to support robust investigations and achieve ESDC strategic objectives.
In 2016, ISB completed an audit of the enforcement function that was executed by former Canada Revenu Agency (CRA) executive Dennis Meunier. This audit resulted in what has been termed the Meunier Report. The Meunier report provides 44 recommendations to ISB on how to improve the enforcement function and a related project – Enforcement as a Practice (EaaP) has been started to implement these improvements. The EaaP project has scheduled a Beta trial starting on June 7, 2021 and has requested that the electronic solution be in place so the software and new processes can be validated together.
Finally, an internal audit conducted by ISB in 2014 highlighted that the results of investigations could be better leveraged to strengthen program integrity and prevention measures. In addition, mechanisms are required to support the alignment of regional investigative practices to national standards for the consistent treatment of all Canadians. The legacy case management systems in use today were not designed to enable statistical or data analysis of the case data, including results of investigations, thus severely limiting the ability of ISB to detect fraud trends and other anomalies that could have otherwise been used to strengthen fraud prevention.
1 Office of the Auditor General of Canada (OAG), Managing the Risk of Fraud, Report 1 in Reports of the Auditor General of Canada – Spring 2017, para. 1.1.
The lack of a case management system for the Enforcement function under ISB, inconsistent case management, and the outdated legacy and manual systems used by the branch for EI, CPP, and OAS, provide an opportunity to improve the way that ISB manages its investigations. A new, modern case management system will improve workload and quality management, allow for the tracking of evidence, support real-time reporting and give ESDC the ability to better leverage its investigation data in support of enforcement activities.