ACOA Internal Audit Directorate

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1 Audit of Innovation (BDP, ISDI, PBS) ACOA Internal Audit Directorate Final Report July 2007

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3 TABLE OF CONTENTS Assurance Statement... 1 Executive Summary... 2 Background... 3 Audit Risk... 4 Audit Objectives... 5 Audit Scope And Methodology... 5 Audit Results... 7 Objective 1:... 7 Objective 2: Objective 3: Objective 4:... 15

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5 ASSURANCE STATEMENT President, Atlantic Canada Opportunities Agency We have completed the Quality Assurance Audit of Innovation, which included the Business Development Program (BDP), the Innovation Skills Development Initiative (ISDI) and the Productivity and Business Skills Initiative (PBS). The overall objective of this audit was to provide assurance that the Agency has exercised due diligence in the delivery of Innovation-related program activity of the BDP, ISDI and PBS, and has complied with established policies and guidelines, as well as the Treasury Board Policy on Transfer Payments. The engagement was conducted in accordance with the Treasury Board Policy on Internal Audit and the Institute of Internal Auditors Standards for the Professional Practice of Internal Auditing. The examination was conducted during the period of October 2006 through February 2007, and covered contributions approved during the three and one-half years, which commenced April 1, 2003 and ended September 30, The audit consisted of an examination of project files in respect of approved contributions from each of the Agency s four regional offices as well as Enterprise Cape Breton Corporation (ECBC). Selected projects were examined in detail in order to evaluate compliance with Agency guidelines through all phases of projects, including assessment, disbursement, monitoring and administration. We concluded that, on an overall basis, ACOA exercises due diligence in assessing Innovation-related applications and in disbursing program funds to recipients. We further concluded that project approvals and amendments are in accordance with established delegated authorities, that contracts contain provisions required by program policies and guidelines, and that monitoring activities are adequate to meet established requirements. In our judgment, sufficient and appropriate audit procedures have been conducted and evidence has been gathered to support the accuracy of the conclusions reached and contained in this report. The conclusions were based on a comparison of the situations, as they existed at the time, against the audit criteria and in consideration of the result of the compliance testing. The conclusions are applicable only in respect of the programs audited. The evidence gathered meets professional audit standards and is sufficient to provide senior management with the proof of the conclusions derived from the internal audit. Chief Audit Executive Internal Audit Directorate Page 1

6 EXECUTIVE SUMMARY The Quality Assurance Audit (QAA) of Innovation focused on the innovation elements of three programs or initiatives, the Business Development Program (BDP), Innovation Skills and Development Initiative (ISDI) and the Productivity and Business Skills Initiative (PBS). These programs and initiatives provide direct financial assistance to small and medium-sized enterprises (SMEs) and are delivered through the ACOA regional offices, with responsibility for development and maintenance of policy and procedures resting with program panagement at Head Office in Moncton. The Audit of Innovation on the delivery of the BDP, ISDI and PBS innovationrelated projects, for the period of April 2003 to October 2006, was completed with the objective to provide assurance that ACOA exercised due diligence in the delivery of the program and followed Treasury Board policy on Transfer Payments. The audit concluded that almost all projects met eligibility requirements and that environmental assessments were conducted. The results also indicated that projects were properly assessed against evaluation criteria and that all information critical to project decisions was consistently and accurately documented. Recommendations were made to improve assessment of both clients and projects to ensure that eligibility criteria are consistently met. The payments system was examined and solid management processes were found to be in place. The audit examined project monitoring and benefits monitoring, and noted some areas which we believe could be improved. Recommendations were made to improve the monitoring process and to emphasize the importance of externally prepared financial statements, documentation of the Account Manager s review of financial statements, risk assessment and monitoring updates, and regular client progress reports. A number of recommendations contained in this Innovation report were also noted in an earlier audit of the BDP. Because both audits examined program activity for a similar period, management action in response to the BDP audit would not have been evident at the time the audit fieldwork was completed for this engagement. Accordingly, this audit could not take into account any corrective measures implemented in response to the BDP audit. Based on the results of the audit, the Internal Audit Directorate has issued a Statement of Assurance that, on an overall basis, the Agency exercised due diligence in the delivery of the innovation element of the BDP, ISDI and PBS. Page 2 Internal Audit Directorate

7 BACKGROUND The Quality Assurance Audit of Innovation, approved by ACOA s Review Committee (currently Audit Committee), is an assurance engagement that was included on the Agency s audit plan for the fiscal year. As a component of the Agency s Program Activity Architecture (PAA), the Innovation activity encompasses a number of contribution programs, including the Atlantic Innovation Fund (AIF), ISDI and PBS, and certain elements of the BDP. Because an audit of AIF was recently completed, that program was excluded from the scope of this engagement. The audit focused on the Innovation elements of the three programs or initiatives; the BDP, ISDI and PBS. The program/initiative objectives of each are as follows. The BDP Innovation element is intended to stimulate the development and use of new or improved technology or products in small and medium-sized enterprises (SMEs) in Atlantic Canada so that they may become more competitive, expand and create more economic benefits for the region. The Innovation element is particularly intended to increase the technology levels in strategic sectors that have been identified by the Agency as having particular growth potential in Atlantic Canada. The key objectives of the ISDI, from a regional perspective, are to enhance the innovation and technology management capabilities of SMEs, increase the region s pool of experienced technology managers and technical expertise, and retain more qualified science and technology graduates within the region s SMEs. The immediate objective of the PBS element is to encourage SMEs to improve their competitiveness by providing training to existing personnel, acquiring skills by hiring new employees, and developing and implementing plans for improved production efficiency, product quality, or environmental management effectiveness. The ultimate objective is to make Atlantic Canadian businesses more successful and more competitive so that they may expand and create additional social and economic benefits for the region. Internal Audit Directorate Page 3

8 During the audit period, the Agency approved contributions for Innovation-related projects under the BDP, ISDI and PBS as follows. Region BDP ISDI PBS Totals Business Support Innovation Other ECBC 262,500 1,421,903 18, ,460 72,375 2,652,988 NB 6,707,808 9,598,606 3,187,924 11,924,592 1,424,793 32,843,723 NL 16,118,883 12,194,322 3,820,731 8,952, ,005 41,952,596 NS 3,609,357 16,319,975 4,463,057 5,900,680 89,000 30,382,069 PE 15,363,104 2,075, ,235 3,398, ,623 21,835,487 HO 324, ,527 TOTALS 42,386,179 41,609,984 11,984,697 31,053,734 2,956, ,991,390 AUDIT RISK The Quality Assurance Audit of Innovation is included in the Audit Plan for as approved by Review Committee (currently Audit Committee). Engagement risk is determined through the use of the Audit Universe Risk Analysis (AURA). The AURA specifies the engagement risk by considering six risk criteria: Level of Funding; Other Audits Performed; 3 rd Party Control and Delivery; Agency Internal Controls; Program Sensitivity; and Agency Strategic Direction. Through the process of the AURA for Innovation, the engagement risk was determined to be high as a result of a significant level of funding, program sensitivity, and the fact that Innovation is a component of the primary strategic outcomes of the Agency. Page 4 Internal Audit Directorate

9 AUDIT OBJECTIVES The overall audit objective is to provide assurance that the Agency has exercised due diligence in the delivery of Innovation-related projects under BDP, ISDI and PBS, and has complied with policies and guidelines established for the Programs, as well as the Treasury Board Policy on Transfer Payments. In order to provide assurance, a number of sub-objectives have been established. ACOA exercises due diligence in assessing applications for contributions. Project approvals and amendments are in accordance with established delegated authorities, and related contracts contain provisions as required by program policies and guidelines. The Agency exercises due diligence in disbursing program funds to recipients. Monitoring activities are adequate to meet the requirements established for each project during the assessment and approval process. AUDIT SCOPE AND METHODOLOGY The engagement was included in the ACOA Audit Plan, approved by ACOA s Review Committee (currently Audit Committee). The audit was carried out during the period of October 2006 through February The audit examined contributions approved from April 1, 2003 through September 31, The audit consisted of an examination of project files relating to approved contributions from each of the Agency s four regional offices as well as Enterprise Cape Breton Corporation (ECBC). Selected projects were examined in detail in order to evaluate compliance with Agency guidelines through all phases of projects, including assessment, disbursement, monitoring and administration. Internal Audit Directorate Page 5

10 The numbers of commercial and non-commercial projects selected for examination, as well as the total-related contributions, are as follows. Region BDP ISDI PBS Total Assistance Business Support Innovation Other $ Selected Projects NB ,388,586 NS ,452,810 ECBC ,679,176 NL ,825,638 PE ,072,129 TOTALS ,418,339 Each regional office was visited in order to: conduct interviews with management to obtain an understanding of systems and processes in place; and complete a detailed examination of project files in order to ensure compliance with Terms and Conditions of the initiatives, program guidelines as well as Treasury Board Policy on Transfer Payments. Page 6 Internal Audit Directorate

11 AUDIT RESULTS OBJECTIVE 1 Provide assurance that ACOA exercises due diligence in assessing applications for contributions. Criterion 1: Eligibility Projects are satisfactorily screened for eligibility and potential environmental impact prior to approval. Under ACOA programming guidelines, program eligibility, as a component of Innovation activity, is an important distinction. Designation as an Innovation activity can render projects eligible for higher rates of contribution for assistance, more flexible terms of repayment, and access to funding for a broader range of initiatives. As a result, eligibility criteria for applicants and activities are, in many instances, more stringent than those of other program elements. In most instances, we were able to satisfy ourselves that selected projects met the eligibility requirements established for the programs; however, we noted a number of cases for which eligibility rationale were not clear. The objective of the Innovation element of the BDP is to stimulate the development and use of new or improved technology or products in small and medium-sized Atlantic Canadian businesses, and both the ISDI and PBS are similarly targeted to benefit SMEs. We noted a number of instances, however, based on the financial history of clients and/or parent companies as well as existing employment levels, where applicants were not readily identifiable as SMEs and for which eligibility rationale was not clearly stated. A number of ISDI projects relating to lean manufacturing (productivity improvements) were approved for which Innovation project eligibility rationale was not clearly described. The Evaluation Guidelines for BDP Innovation projects state that the Agency must be satisfied that the bulk of the developmental work will be carried out in Atlantic Canada and that the benefits will accrue to Atlantic Canada. In this regard, we identified two instances in which the developmental work appeared to have been performed outside of Atlantic Canada, and we were unable to determine from the Project Summary Forms (PSFs) the rationale for the determination of eligibility. Internal Audit Directorate Page 7

12 Recommendation: PSFs should clearly demonstrate that applicants and proposed activities meet all basic program eligibility criteria. In cases where applicant or activity eligibility is not clear, rationale should be detailed. BEST PRACTICE Review and determination of eligibility of project is evident at ECBC by its use of eligibility guidelines. We found the relevant portion of the guidelines photocopied and placed on the individual project files. This process establishes the basis for the assessment of the project and clearly identifies the project s fit with ACOA s eligibility criteria and objectives. Environmental Screening Selected project files were examined to ensure that initial environmental screenings were completed, that projects meeting established criteria under the Canadian Environmental Assessment Act (CEAA) received further detailed screening by Public Works and Government Services Canada (PWGSC), and that mitigation measures specified for projects were included in letters of offer. In all cases, we were able to establish that these requirements were met; however, there were some projects that we could not determine whether they had been registered, as required under the CEAA, in the Canadian Environmental Assessment Registry (CEAR). According to program management, PWGSC provides ACOA with written confirmation, including CEAR reference numbers, that projects have been registered; however, because various means of confirmation have been used to document this process (including notices of commencement, verbal communication and ed messages), it is not always clear that projects have been registered. Recommendations: As part of the screening function performed by PWGSC, ACOA should receive written confirmation, including CEAR reference numbers, that projects have been registered, and should include the CEAR numbers on all PSFs under the Canadian Environmental Assessment Comments section. Criterion 2: All information critical to project decisions, including all significant changes to information submitted by applicants, is documented on Project Summary Forms (PSFs) and / or included in project files. Page 8 Internal Audit Directorate

13 The PSF is the primary means used by ACOA to document key project information. Based on our review, it is clear that project files, including PSFs, contain the required information elements needed to support funding decisions. In almost all cases, details of project costs and funding sources were included in PSFs. The PSFs also included the required financial analyses, program information and sector advice obtained during the evaluation process; however, we noted certain areas in which we believe documentation could be improved. Business/Project Plans Business Plans are required for Innovation-related projects, with programspecific requirements outlined in the guidelines. It was often difficult to determine the source of project costs, particularly in those instances where business plans were not present. Additionally, the assessment process and changes in applicant plans frequently result in changes to project scope, which is not always evident from project files. As a result, the link between original applications and ultimately approved projects is not always maintained. Further, it is important that project files provide documentation that project costs and other assumptions have been challenged by the Account Manager, in order to establish the necessity of costs, consistency with the scope of the project, and basis on which costs have been determined (i.e. supplier quotes). Based on our audit, the extent of the challenge performed was sometimes unclear. Recommendation: Project files should provide documentation of the source of project costs, as well as evidence that costs and other assumptions have been challenged by the Account Manager in order to establish the necessity of costs, consistency with the scope of the project, and the basis on which costs have been determined (e.g. supplier quotes). Other Funding In order to assess overall viability and ensure compliance with established stacking limits, all assistance from other federal, provincial and municipal governments or their agencies must be considered during project assessment and should be stated on the PSF and Statement of Work; however, we noted instances where it was not clear where such other government funding originated, the program from which the funds were sourced, or the intended purpose. Investment Tax Credits (ITCs) represent a source of project financing for many manufacturing and innovation projects, and should be specifically considered in project assessments, where applicable; however, we noted a number of instances whereby ITCs were excluded from project financing summaries and stacking calculations, and other instances in which we could not determine the basis of calculation of the amounts presented. Internal Audit Directorate Page 9

14 For Business Support applicants, the status of their Harmonized Sales Tax (HST), can vary greatly. Depending on the nature of the proposed activity, HST paid by applicants in respect of eligible project costs may be fully refundable, partially refundable, or non-refundable. As a result, the treatment of HST can have a significant impact on eligible project costs and the disbursement of program contributions, yet we noted few instances in which this issue was resolved on PSFs. According to ACOA s guideline for in-kind contributions, a non-cash transaction or in-kind contribution refers to an instance where a proponent receives from a third party or contributes itself, assets or services that will be used or consumed in a project at no cost to the proponent. In-kind contributions are established prior to approval and file documentation includes assessment, calculation and verification of the in-kind value. In most cases, the amounts of the in-kind contributions were found in the financing summaries; however, we could not always verify how the valuations were determined. Recommendations: For projects funded by other government departments or agencies, the source, amount of funding and purpose should be clearly described on both the PSF and Statement of Work. Project files and PSFs should document eligibility for ITCs for all applicable projects, and provide details of all calculated amounts. The HST status of applicants, and the related impact on eligible project costs, should be documented at the time of evaluation. Determination of the value of an in-kind contribution should be documented on the project file, including assessment, calculation and verification of the contribution. Proactive Solicitation According to Business Support program guidelines, eligible projects should directly support one or more strategic priority, and should result primarily from proactive initiatives by the Agency. In this regard, program guidelines imply an additional standard of due diligence be applied to unsolicited proposals, to ensure that recommendations for support are based on achievement of strategic priority objectives. In our view, applications would have been stronger with more background information provided in respect of the origin of projects, details of the discussions that led to the proposals, as approved, and proponents prior involvement with ACOA programs. Recommendations: For non-commercial projects that arise as a result of development activity undertaken by ACOA, details of the discussions that led to the proposals should be documented. Account Managers should provide a brief description of the Agency s experience with the applicant with respect to previous agreements. Page 10 Internal Audit Directorate

15 Criterion 3: Projects are assessed against required criteria in respect of incrementality / need, commercial viability and net economic benefit. As required for all Innovation projects, and as any integral component of all PSFs, the documentation of project assessments against the criteria of incrementality, viability, repayability and net economic benefit was evident for most projects examined as part of our engagement. Incrementality The initial determination of incrementality / need is predicated on applicant certifications that financial assistance from ACOA is a significant factor in the decision to proceed with projects, and may be substantiated through a review of the applicant s alternative investment opportunities and options, financial projections and requirements, availability of financing, and whether irreversible commitments for significant project costs are in place. In some instances, based on the financial status of certain clients, applicant need of ACOA funding was not evident, and we could not locate specific rationale on the PSF as to how incrementality had been established. For example, it is very common to find PSFs detailing a client s need to undertake a project, as opposed to the client s need for government financial assistance under Incrementality and Need. Commercial Viability and Repayability According to program guidelines, commercial viability is to be assessed to provide reasonable assurance of an applicant s ability to remain as a going concern. In this regard, the ongoing viability of an applicant must be clearly demonstrated, taking into consideration such factors as project definition, financial position, availability of other financing, projected operating results, management capabilities, availability of markets, market strategy and implementation plan, and operational requirements. PSFs are structured in a manner that facilitates specific discussion of commercial viability considerations and, as a result, we conclude that such criteria were an integral part of the projects we examined; however, we noted components of financial analyses that we believe could be improved. Projected balance sheets, income statements and cash flows, which include the repayment of Agency contributions, are prepared as part of the PSF as a normal component of project assessment. In some instances, we were unable to determine the sources of information used to prepare the projections, the assumptions used in their preparation, or the extent to which they were challenged by the Account Manager. The sensitivity analysis is a normal component of project assessment included in the PSF and is used as a tool by which to estimate the impact Internal Audit Directorate Page 11

16 of potential deviations from expected results. For all commercial, repayable/provisionally repayable projects entered in QAccess, a sensitivity analysis is mandatory and the Account Manager cannot lock the project in the system until a sensitivity factor is entered. Entering a sensitivity factor of zero is possible, but results in no change between forecast, pessimistic and optimistic figures. In our view, the usefulness of these analyses is sometimes diminished due to insufficient variations in activity levels being considered, the inability of the model to incorporate less favourable cost structures than forecast in the analyses, and the lack of specific conclusions in respect of the sensitivity of projected results. Net Economic Benefit The benefits of a project are to be assessed in terms of the contribution to the net economic benefit to the region, normally expressed in terms of success indicators that best reflect the intended results of the project. Particular attention is to be given to job creation/maintenance and any negative competitive impacts on existing operations within the applicant s market area. Based on our review, we have concluded that ACOA has complied with these requirements. Recommendations: Specific rationale should be provided by Account Managers in support of conclusions that ACOA funding is required to enable projects to proceed. Project files should document the source of information used to project financial results as well as the challenge undertaken by Account Managers in respect of the projections and other assumptions used. Results should be directly linked to the discussion of commercial viability on PSFs. The sensitivity analysis model used in PSFs should facilitate variations in cost structures, and the sensitivity analyses should be completed with sufficient variations in activity levels to adequately assess the full range of plausible results. Results should be directly linked to discussions of commercial viability and risk on PSFs. Conclusions by the Account Manager on the results of the sensitivity analyses should be included in the PSF, or the rationale as to why the sensitivity analysis was not completed. Page 12 Internal Audit Directorate

17 OBJECTIVE 2 Provide assurance that project approvals and amendments are in accordance with established delegated authorities and related contracts contain provisions, as required by program policies and guidelines. Criterion: Approved delegations of authority are observed for all project approvals, signed letters of offer are on file and contain all required elements, conditions, and project amendments completed in accordance with program guidelines and authorities. PSFs, in addition to summarizing the results of project assessments, are used to document the project approval process. Based on the project files examined, it is evident that approvals are made in accordance with delegated signing authorities. Signed Letters of Offer are retained on file for all contributions, and contain the Statement of Work, General Conditions, and relevant specific conditions arising from the project approval and environmental assessment processes. Project amendments, where needed, are also completed in accordance with delegated signing authorities. Under BDP Innovation guidelines, the Statement of Work should define the resulting product and how product sales will be measured to facilitate ongoing project management, in instances where contributions are provisionally repayable. In most cases, the resulting product is described within the Letter of Offer; however, we noted some instances where the resulting products were not defined. Also, program guidelines indicate that project amendments should be signed prior to the expiration date of the original contract and prior to the actual changes taking place. For a number of amendments, it appeared that delegated signatures were not obtained until after changes to the contract had taken place. Recommendations: Letters of Offer/Statements of Work for Innovation projects should describe resulting products and how product sales will be measured. ACOA should monitor contractual agreements and ensure that amendments are prepared and approved in a timely manner. Internal Audit Directorate Page 13

18 OBJECTIVE 3 Provide assurance that the Agency exercises due diligence in disbursing program funds to recipients. Criterion: Proper information is gathered, reviewed and approved in support of the payments of advances and claimed costs. Similar payment processes are used by ACOA for the disbursement of contributions to both commercial and non-commercial applicants. In most cases, costs are supported by detailed listings of expenditures, compliance with required financial conditions is verified, and applicant-prepared progress reports and certifications are obtained. In most regions, the project claim payment process consists of an initial review by an Account Assistant to ensure the completeness and accuracy of information provided by applicants, and to organize the information for Account Managers subsequent review and approval. In our view, this represents an efficient mechanism to eliminate clerical tasks from Account Managers workloads, and provides for a sufficient segregation of duties to be an effective control. In one region, however, because the Account Managers do not normally sign the payment checklists, it was sometimes difficult to determine the extent to which the Account Managers reviewed claimed costs, or the extent to which claimed costs were analyzed in relation to eligible cost categories as detailed in Statements of Work. For advance payments, the Letter of Offer spells out the terms associated with an advance payment, including the timeline for substantiating the advance with progress claims. In most cases, the advance payment process adheres to the Letter of Offer; however, we did find instances where, based on forecast expenditures in the related advance requests, progress claims were not submitted within reasonable timelines to settle the advance payments and, on a limited number of occasions, advance payments were made without the advance clause appearing in the Letters of Offer. The task of managing advances is further hindered by system limitations, which do not allow program officers to track the status of advances. Recommendations: Account Managers should document their review of claimed costs in respect of the amounts, composition and distribution according to eligible cost categories, and should indicate their review and approval of the work performed by Account Assistants by signing the payment checklist. Page 14 Internal Audit Directorate

19 Clients should be reminded in the payment cover letters of their obligation to submit progress claims to substantiate advances within the timeline prescribed in their Letters of Offer. The functionality of the Agency s corporate system should be enhanced to track the status of advances. ACOA should not process advance payments when the Letter of Offer does not specifically include an applicable advance payment clause. OBJECTIVE 4 Provide assurance that monitoring activities are adequate to meet the requirements established for each project during the assessment and approval process. Criterion 1: Financial statements are obtained from applicants on an annual basis, and monitoring activities are untaken and documented at prescribed intervals. The ongoing monitoring of commercial projects is normally completed on an annual basis, and includes the submission to ACOA of externally prepared financial statements by applicants. In the majority of projects examined, this process was followed, including the entry of summarized financial information into QAccess, and the completion of the related automated monitoring module; however, we could not always determine the extent to which the financial statements had been reviewed by the Account Managers. With respect to Innovation-related projects, both the client and project undergo a risk assessment at the time of application and again at pre-determined intervals defined in the PSF. The risk assessment focuses on elements of management, finance, marketing, and facilities, and an overall comment on the strengths or weaknesses of the client and project. We found that most initial risk assessments were complete, but could not always locate the pre-determined updates or determine if the risks were re-evaluated. It appears system functionality promotes the use of previously created risk assessments, which in many cases, impedes the ability to do risk updates. This process adds little value and can result in information which is no longer relevant being applied to subsequent assessments. We also noted instances in which financial statements were several months overdue or had not been submitted by applicants, or where interim statements or statements from prior fiscal years had been used for purposes of annual monitoring. In our view, the absence of recent reliable financial information significantly restricts the usefulness of the monitoring function for such clients. Internal Audit Directorate Page 15

20 Recommendations: As part of the monitoring process for Innovation projects, risk assessments should be updated according to established intervals. Where no significant changes have occurred, the QAccess risk update should include a brief overall conclusion. In preparing the Letter of Offer, Account Managers should be cognizant of the limitations of internally prepared financial statements, and be encouraged to specify externally prepared financial statements prepared in accordance with generally accepted accounting principles, whenever possible. Financial statements to be used for this purpose should be those for the most recently completed fiscal year and should include all statements, schedules, note disclosures and assurance reports. Criterion 2 Progress reports are obtained from applicants during the period for which project activities are undertaken, and final reports are obtained at the conclusion of each project. In general, the monitoring of non-commercial projects is dependent on the payment process. Formal monitoring reports are undertaken only in respect of repayable contributions, whereas applicant-prepared progress reports are normally required by the Agency to substantiate the payment of interim claims, and final project reports are required to substantiate final disbursements. For the non-commercial project files examined as part of this audit, we noted three instances where progress reports did not accompany the client s first claim. The lack of progress reports can hamper the Agency s ability to monitor project progress through the payment process. Account Manager approval of payments also indicates approval of the related progress and final reports, though the extent to which the reports have been reviewed by Account Managers is often unclear. Recommendation: Project files should adequately demonstrate the progress of projects before disbursements are made. Account Managers should document their review and approval of reports submitted pursuant to non-commercial requirements, including specific conclusions in respect of benefits realized. Page 16 Internal Audit Directorate

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