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PACP Committee Report

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Government Response to the Report of the Standing Committee on Public Accounts Chapter 5, Surveillance of Infectious Diseases – Public Health Agency of Canada of the May 2008 Report of the Auditor General of Canada

Introduction:

Auditor General of Canada (AG) reports from both 1999 and 2002 identified a series of issues and recommendations in regards to Canada’s health surveillance and disease control programs. At the time of these reports, Health Canada was the primary federal organization responsible for responding to and following up on these recommendations.

As a result of these reports, and others issued following the SARS outbreak in 2003 (e.g. the Naylor Report), the federal government created the Public Health Agency of Canada (PHAC) in 2004. PHAC acquired its own enabling legislation, the Public Health Agency of Canada Act, in December 2006. PHAC plays a key role in the protection and promotion of public health in Canada. Its primary goals are to strengthen Canada’s capacity to protect and improve the health of Canadians and to help reduce pressures on the healthcare system.

To do this, PHAC is working to build an effective public health system that: enables Canadians to achieve better health and well-being in their daily lives by promoting good health; helps to prevent and control chronic diseases and injury; and, protects Canadians from infectious diseases and other threats to their health. A key responsibility of PHAC is to coordinate efforts to identify and respond to public health threats, and to act as a hub for Canada’s public health surveillance and disease control programs. The work that PHAC performs is critically important since timely health actions can prevent and contain disease outbreaks, reduce the economic costs of infectious and chronic diseases, reduce disabilities, and save the lives of Canadians.

In December 2007, PHAC established the position of the Senior Surveillance Advisor who reports directly to the Chief Public Health Officer (CPHO). Formal governance mechanisms for all surveillance activities have been established and are led by the Senior Surveillance Advisor. PHAC has also adopted a strategy to improve and strengthen its surveillance activities.

In May 2008, the AG submitted to Parliament a report which addressed a variety of issues that affect the daily lives of many Canadians, from infectious disease surveillance to the safety of air travel.

Chapter 5 of this report focused on the surveillance of infectious diseases and on how well PHAC tracks threats posed by infectious diseases. The AG concluded that PHAC has surveillance systems in place to detect and monitor existing and emerging infectious diseases in Canada, but fundamental weaknesses noted in the 1999 and 2002 reports remain (e.g. an incomplete legislative review, and an inconsistent quality of national infectious disease surveillance information). The report did acknowledge that there are competing demands associated with launching a new organization and that collaboration with partners is necessary to achieve results. As well, the AG reported that while important steps have been taken to respond to past recommendations, PHAC has not made satisfactory progress on those related to strategic direction, data quality, results measurement, and information sharing.

The CPHO of Canada appeared before the House of Commons Standing Committee on Public Accounts (PAC) on March 10, 2009, to respond to PAC concerns about the AG’s recommendations in Chapter 5 of the May 2008 report. At that time, a summary action plan for the implementation of PHAC’s Surveillance Strategic Plan was tabled. Following the session, PHAC also provided PAC with: a list of Memoranda of Understanding (regarding information sharing during a public health emergency, provision of mutual aid during an emergency, and roles and responsibilities in pandemic preparedness); a guideline for information-sharing agreements (ISAs); and, a model agreement on information sharing related to public health.

PAC completed its study of the AG’s Chapter 5 in May 2009. The resulting report recognizes that PHAC is a new organization facing substantial challenges, and while it will take time for the organization to grow into its role, much has been accomplished to-date. PAC indicated that it believes that fundamental changes are needed to PHAC’s surveillance systems, and that further delay in the implementation of the AG’s recommendations puts the lives of Canadians at risk.

To reinforce its concerns, PAC recommended that a series of status updates, analyses and reporting practices, including timelines and an annual update to PAC, be undertaken by PHAC to demonstrate on-going commitment to the implementation of the AG recommendations.

On June 26, 2009, the CPHO received PAC’s report on Chapter 5 of the May 2008 AG report (with five recommendations). A response letter was sent from the CPHO to PAC acknowledging receipt of the report and the requirement to table a response before September 24, 2009.

While the report from PAC acknowledges that work is on-going to address the AG recommendations, several areas of concern led PAC to supplement the AG findings with the following five recommendations:

That PHAC provide an interim status report to the Public Accounts Committee on its progress in implementing the Office of the Auditor General’s recommendations by 30 September 2009, and that additional status reports be submitted to the Committee annually until the recommendations are fully implemented;
That Health Canada and PHAC provide the Public Accounts Committee by 30 September 2009 with a clear timeline for a legislative review that would determine whether additional statutory authorities are necessary;
That PHAC provide the Public Accounts Committee by 30 September 2009 with a proposed timeline for negotiating information sharing agreements with the provinces and territories, and report progress in making these agreements in its annual status report to the Committee;
That PHAC provide the Public Accounts Committee with its assessment of core surveillance and response capacity requirements by 30 September 2009, along with a timeline detailing how it intends to meet the World Health Organization (WHO) Regulations by the mandatory deadline of 2012; and,
That PHAC include in its departmental performance reports an outline of the challenges and risks it faces as an organization; and that PHAC provide a balanced appraisal of the results it has achieved in improving its surveillance activities.

Government of Canada Response:

Recommendation 1:

That PHAC provide an interim status report to the Public Accounts Committee on its progress in implementing the Office of the Auditor General’s recommendations by 30 September 2009, and that additional status reports be submitted to the Committee annually until the recommendations are fully implemented.

Response:

PHAC has included, as part of Annex A to this Government Response, an interim status report and will continue to submit status reports to PAC on an annual basis, each February, until the AG recommendations are fully implemented.

Recommendation 2:

That Health Canada and PHAC provide the Public Accounts Committee by 30 September 2009 with a clear timeline for a legislative review that would determine whether additional statutory authorities are necessary.

Response:

A legislative review related to the surveillance of infectious disease was completed prior to the 2008 AG report. Careful consideration is being given to the need for additional legislation that would modernize and augment the Minister’s ability to collect, use and disclose information for surveillance and research purposes. Public health information regulations are being developed pursuant to the authority in s. 15(1) of the Public Health Agency of Canada Act. These regulations will clarify the Minister’s authority to collect, analyse, interpret, publish and distribute information, including personal information and confidential business information, relating to public health. The regulations will also identify measures that the Minister may take to protect personal information. Internal consultations on the first draft of these regulations are in progress. This will be followed by appropriate external consultations with the provinces and territories and the Office of the Privacy Commissioner. Publication in the Canada Gazette (Part 1) could occur as early as Fall 2009.

Recommendation 3:

That PHAC provide the Public Accounts Committee by 30 September 2009 with a proposed timeline for negotiating information sharing agreements with the provinces and territories, and report progress in making these agreements in its annual status report to the Committee.

Response:

A Federal/Provincial/Territorial Memorandum of Understanding on the Sharing of Information During a Public Health Emergency was agreed to in principle by all FPT Health Ministers on September 5, 2008. The Memorandum of Undertanding (MOU) establishes a framework for the sharing of information between and among jurisdictions in a public health emergency.

As a follow-up to the MOU, PHAC is also working with each province and territory to develop information-sharing agreements (ISAs). To assist with this task, a FPT Task Group co-led by PHAC, has developed Guidelines for Public Health Government-to-Government Information Sharing Agreements and a Model Agreement on Information Sharing relating to Public Health between the Government of Canada and Provincial/Territorial Governments. An ISA for all nationally notifiable infectious diseases has been signed with the Province of Ontario.

An ISA on influenza is currently under development; this work is being expedited through the H1N1 Task Force and is expected to be approved by Fall 2009 and signed by FPT Ministers of Health by Summer 2010. Following the successful implementation of this prototype agreement, it is expected that ISAs for all infectious diseases will be negotiated. Current plans are for additional agreements with provinces and territories to be signed by Summer 2011. The development and implementation of these broader ISAs is to be integrated into the action plan flowing from Canada’s commitment to the International Health Regulations (IHRs). Updates regarding progress on these ISAs will be provided as part of the annual status reports submitted to PAC.

Recommendation 4:

That PHAC provide the Public Accounts Committee with its assessment of core surveillance and response capacity requirements by 30 September 2009, along with a timeline detailing how it intends to meet the WHO Regulations by the mandatory deadline of 2012.

Response:

The IHRs (2005) came into force on June 15, 2007. Annex 1A of the regulations contains a series of core capacity requirements for surveillance and response at the local, provincial/territorial and federal levels. State parties were required to assess, by June 15, 2009, the ability of national structures and resources to meet these minimum core capacities. State parties are required to ensure that these core capacities are present and functioning throughout their territories by June 15, 2012.

Coordinated through the IHR Secretariat in PHAC, capacity assessments for surveillance and response were conducted by provinces and territories and across the federal government between December 2008 and April 2009. The assessments were reviewed at an FPT National IHR Roundtable held in Ottawa in June 2009. Participants included IHR Champions from each of the provinces and territories, as well as those from implicated federal departments and agencies, and it was concluded that Canada has already complied with these requirements ahead of the 2012 deadline.

A Pan-Canadian IHR Assessment Report, which will include results of the FPT assessment of core capacity for surveillance and response, will be published in early 2010. The Secretariat will develop a continuous monitoring program for IHR implementation in collaboration with other government departments and provincial/territorial authorities. This will enable Canada to conduct ongoing evaluations of its ability to detect, assess, notify and respond to public health events.

Recommendation 5:

That PHAC include in its departmental performance reports an outline of the challenges and risks it faces as an organization; and that PHAC provide a balanced appraisal of the results it has achieved in improving its surveillance activities.

Response:

Work is underway to include, within PHAC’s current Departmental Performance Report (DPR), an enhanced discussion of key public health and some organizational/management challenges and risks. Within the constraints of the new concise DPR requirements, a balanced appraisal of results achieved in improving its surveillance activities will be included in future DPRs. As PHAC matures as an organization, Surveillance Evaluation, Risk Management Frameworks and other tools are in place, and PHAC’s capacity to report on performance results will be enhanced.

Public Health Agency of Canada

Interim Status Report on Progress in Implementing May 2008 Auditor General Recommendations - Chapter 5: Infectious Disease Surveillance

August 14, 2009

First half of the calendar year = H1; Second half of the calendar year = H2

Timelines and deliverables have been updated since March 10, 2009 to reflect current situation and priorities; unless otherwise stated, all initiatives that are ‘in progress’ are on schedule

Para.	AG Recommendations	PHAC’s Official Response to the AG	Deliverables	Timelines	Status	Outcome / Progress to-date
5.22	To ensure effective management of risks posed by existing and emerging infectious diseases, PHAC should use public health threat assessments to set objectives and priorities for its national surveillance activities.	PHAC is assessing, on a daily basis, public health risks to Canadians posed by existing and emerging infectious diseases which are recorded in its Daily Intelligence Report. PHAC has written its Surveillance Strategic Plan, initiated its implementation process, and is committed to completing its implementation over the next three years. This will include a formalized decision process using health threat risk assessments to address priorities and objectives. PHAC’s Integrated Risk Assessment Framework will be in place by December 2009.	1) Implement enhanced governance infrastructure and process components of PHAC’s Surveillance Strategic Plan.	H1 / 2008	Achieved	* Senior Surveillance Advisor to the CPHO has been appointed and reports to PHAC's Executive Committee. * PHAC Surveillance Management Committee approved the Surveillance Integration Team (SIT) Terms of Reference and a five-year work plan (2008-2012). * Surveillance Integration Team meetings take place regularly with monthly reports to Surveillance Management Committee on progress.
5.22			2) Implement the work plan based on objectives and priorities defined in PHAC’s Surveillance Strategic Plan	H2 / 2008	Achieved	* A Surveillance Coordination Unit has been established to support the Agency's surveillance governance structure and initiatives towards addressing OAG recommendations and the PHAC Surveillance Strategic Plan (i.e. implementing SIT work plan). * Process for managing surveillance issues and product development has been developed and implemented. * Work groups for delivering on the Surveillance Integration Team work plan are in place.
			3) Develop a corporate Integrated Risk Management Framework	H2 / 2009	In progress	* Comprehensive risk management framework to apply across PHAC drafted for executive consideration. * An implementation plan and toolkit is under development.

5.28	To help clarify its roles and responsibilities, ensure that it receives relevant and timely surveillance information, and ensure that it has adequate legislative and regulatory authorities for the collection, use and disclosure of public health information, the Agency should, with Health Canada, complete the legislative review and, if necessary, should seek the additional authorities for the Agency to carry out surveillance.	The Agency and Health Canada (HC) will continue to work together on legislative and regulatory authorities for collection, use and disclosure of public health research and surveillance information	1) Legislative Review		Achieved		* Department of Health Act (DHA), Public Health Agency of Canada Act (PHA), Privacy Act (PA) and Quarantine Act were reviewed
			2) Update authorities (draft new legislation / regulations) as required	H2 / 2009 – H1 / 2010	In progress		* First draft of the Public Health Information Regulations has been produced and is currently being reviewed by the Department of Justice. Consultations with Health Portfolio, Dept of Justice, Provinces/Territories (Public Health Network Council), Surveillance Information Expert Group and the Office of the Privacy Commissioner. Publication in Gazette I could occur as early as fall 2009.
5.33	To improve their ability to anticipate and control zoonotic diseases, the Public Health Agency of Canada and the Canadian Food Inspection Agency should jointly assess the possible risks to human and animal health, clarify how the responsibilities will be divided, and act on joint surveillance objectives and priorities.	To further ensure collaboration and coordination, including clarification of roles and responsibilities for issues surrounding zoonotic diseases and the potential impacts on human and animal health, PHAC, Canadian Food Inspection Agency (CFIA), and HC are currently finalizing a Memorandum of Understanding. In addition, PHAC addresses issues related to diseases transmitted via food and water through the Foodborne and Waterborne Issue Group, a federal-provincial-territorial committee of the Public Health Network. Also, a newly established Issue Group of the Communicable Disease Expert Group has been created to deal with issues related to animal-to-human infections that are not typically transmitted through food and water. This federal-provincial-territorial committee, as well as forums such as the annual National West Nile Virus and Other Non-Enteric Zoonotic Diseases meetings, provides PHAC with a platform for discussion with stakeholders and CFIA. CFIA and PHAC will implement a risk assessment by spring 2009 and enhancements will be made to the surveillance zoonotic alert module.	1) A Memorandum of Understanding (MOU) between PHAC, CFIA and Health Canada, and a Letter of Agreement (LOA) with CFIA on zoonotic and human health	H1 / 2008		Achieved		* PHAC, CFIA, and HC signed an MOU in April 2008. The MOU helps to ensure collaboration and coordination, and clarify roles and responsibilities for issues surrounding zoonotic diseases and the potential impacts on human and animal health. * A LOA between PHAC and CFIA was signed in May 2008. The MOU helps to ensure collaboration and coordination, and clarify roles and responsibilities for issues surrounding zoonotic diseases and the potential impacts on human and animal health.

2) In collaboration with CFIA, develop and implement the work plan as defined in the LOA, including operational standards and procedures for information sharing about domestic animal diseases of possible risk to human health;

H2/2010

In progress

* A workshop was held between PHAC and CFIA in December 2008 to initiate the development of a work plan for an integrated approach to zoonotic disease risk analysis, surveillance, and alerting mechanisms.

* Two working groups were formed as a result of the workshop – one with a focus on surveillance and information sharing and the other with a focus on health risk assessments. Work plans are being developed but have been delayed due to H1N1 response.

3) In collaboration with Provinces and Territories and other partners, strengthen the ongoing joint risk assessments for animal infections of potential risk to human health, addressing the surveillance needs linking animal, human and environmental health;

H2/2010

In progress

* The working group on surveillance and information sharing will oversee animal-public health alert modules, information sharing, and management of the alert modules between the two Agencies.

* Throughout the H1N1 outbreak (April 2009 to present), links were further established and strengthened between all parties. Various levels of government and academia are collaborating to conduct assessments of risk. Work on a risk assessment mechanism is being developed between CFIA and PHAC, but has been delayed due to H1N1 response

4) Finalize and pilot-test the prototype zoonotic alert module; revise and evaluate the alert module

H2/2010

In progress

* A public health related prototype zoonotic alert module has been developed by the Canadian Network for Public Health Intelligence (CNPHI) and is expected to be functional by end of the 2009/10 fiscal year. CNPHI fills a need in Canada’s national public health infrastructure to gather and share strategic public health information and intelligence.

* The Zoonotics Division, in collaboration with CNPHI, will coordinate a pilot test of the alert module. Partners will need to be informed of its existence and help provide information for the alert module.

5.39	The Public Health Agency of Canada should establish data-sharing agreements to ensure that it receives timely, complete, and accurate surveillance information from all provinces and territories. In collaboration with its partners, the Agency should set timelines for putting these agreements in place.	The Agency recognizes the importance of sharing data in a timely, complete, and accurate fashion. Over the last 3 years, the Agency has worked with Provinces and Territories to put in place data sharing agreements. It also participated in a number of provincial and territorial fora to address issues of surveillance information, such as the Public Health Network, and the Committee of Chief Medical Officers of Health. Furthermore, the Agency is in the process of developing a Privacy Framework for the management of privacy issues, such as record information sharing and managed information sharing agreements, with an expected completion date of March 2009. During the 2008–09 fiscal year the Agency will continue its partnership work with provinces and territories on information sharing and complete the portion of data-sharing agreements that is under its jurisdiction, while engaging provincial and territorial partners to complete their respective portions.	1) Set timelines, sign and manage data-sharing agreements dealing with national surveillance priorities	H2/2011	In progress	* Memorandum of Understanding on Information Sharing During a Public Health Emergency has been approved in principle by the F/P/T Ministers of Health in September 2008 and signed by a majority of jurisdictions. Guidelines and an information-sharing agreement prototype have been developed and approved by the Public Health Network. Data-sharing agreement with Ontario (for all nationally notifiable diseases) has been signed. * Information Sharing Agreements for all infectious diseases to be put in place by Summer 2011.
			2) Support and develop an agreement under the Public Health Network for data sharing on new emerging influenza virus.	H2/2010	In progress	* First draft of an Information Sharing Agreement on the Use, Disclosure and Retention of Information and Biological Substances Relating to Influenza is being expedited through a PHAC-supported task group within the Public Health Network. Planning to have approval in principle by end of September 2009 and final signatures by Summer 2010.
			3) Build on the Agency Privacy Framework for management of privacy issues.	H2/2009	In progress	* A Data Privacy Work Group is in place. * The Agency's Privacy Management Framework will be completed by November 2009.
5.43	The Public Health Agency of Canada should work with its partners to implement agreed-on standards for the data it receives from provinces and territories. Steps should include finalizing agreements with all provinces and territories on the data to be provided for each infectious disease.	The standards for notifiable diseases were agreed to and signed by Ontario as of September 2007. The Agency will continue working toward finalizing more of these data-sharing agreements with provinces and territories. Additionally, the revised case definitions for notifiable diseases will be finalized and published by December 2009.	1) Publish the revised case definitions for notifiable diseases and distribute them to Provinces and Territories	H2/2008 to H1/2009	Achieved	* The revised case definition document has been completed and approved by the Communicable Disease Control Expert Group of the pan-Canadian Public Health Network and a prepublication copy was provided to all P/Ts.

5.46

To ensure adequate data quality to support public health actions, the Public Health Agency of Canada should put in place the necessary procedures for assessing and documenting its data quality, and should work with its partners to address deficiencies.

The Agency has been working and will continue its work to formalize the data quality checks that it has already undertaken. A data quality process has been piloted within the Agency, and is expected to be completed by March 2009. As outlined in its Surveillance Strategic Plan, the Agency will continue to strengthen its existing activities to formalize procedures internally, and work with partners to address any deficiencies that become apparent.

1) Implement a data quality framework for each surveillance program

H2/2009

In progress

* A Data Quality Framework has been created and will be implemented in fall 2009

5.50

The Public Health Agency of Canada should periodically evaluate its surveillance systems to ensure that they are working as intended, and it should report the results publicly.

During the 2008–09 fiscal year, the Agency will finalize and implement the existing Evaluation Framework for Surveillance Systems throughout the organization. This Framework will be used to perform regular evaluations of surveillance systems.

1) Implement the Agency’s Evaluation Framework for Surveillance systems

and include end-user needs as an element of all evaluations.

H2/2009

In progress

* The development of a conceptual model for integrated surveillance evaluation and an associated process for undertaking such evaluations has been completed.

* Surveillance system evaluation tools have been developed and are being pilot tested in 2009-2010

* Plans are being prepared for each program area to undertake regular evaluations of their respective surveillance systems and report the results over a 5-year cycle (consistent with the new TB Policy – Evaluation – 2009).

5.51

To regularly measure the performance of its surveillance systems, the Public Health Agency of Canada should establish indicators with targets and report the results against those targets.

In conjunction with current work being done on revising and detailing its Strategic Outcome and Program Activities, the Agency will work to establish required indicators and subsequent reporting in the 2009/10 fiscal year.

1) Establish Agency Surveillance Strategy indicators and report on the performance of its surveillance programs on a regular basis.

As of H1/2009 and

ongoing

In progress

* Key indicators and inclusion/exclusion criteria for surveillance programs and associated systems have been established.

* Criteria are being implemented in performance reporting of surveillance systems and indicators are established on an ongoing basis as part the evaluation of surveillance programs

5.54

To ensure that its surveillance systems for HIV, the West Nile virus, and the influenza virus are best meeting the needs of the users, the Public Health Agency of Canada should systematically assess and document the user needs.

The Agency will implement a user needs assessment program for surveillance systems by December 2008

1) Expand on the Agency’s user needs assessment program to include a broader scope of diseases of public health risk significance

H1/2009

Achieved

* PHAC has conducted and will continue to conduct user needs assessments for its HIV/AIDS and influenza surveillance reports.

* PHAC produces a West Nile Virus National Surveillance Report and consults with its stakeholders on the user needs.

5.88

To meet its obligations under the IHRs, the Public Health Agency of Canada should ensure that its internal systems for managing information about significant public health events are comprehensive and well-documented.

In the 2008–09 and 2009–10 fiscal years, the Agency will formalize comprehensive and well-documented internal systems for managing information during a significant public health event. This will be accomplished through strengthening existing daily briefings of executive management and responsible officers of data systems, laboratories, and relevant surveillance systems.

1) Strengthen and formalize a comprehensive and well-documented internal system that meets International Health Regulations requirements.

H1/2009

Achieved

* Canada has met the June 15, 2009 core capacity requirements for surveillance and response, as described under Annex 1A of the Information Health Regulations, as concluded by F/P/T capacity assessments conducted between December 2008 and April 2009. A Pan-Canadian IHR Assessment Report will be published in 2010.

5.89

To ensure that it can meet its obligations under the International Health Regulations, the Public Health Agency of Canada should work with its partners to establish an action plan with clear and realistic deadlines for implementing the memorandum of understanding on the sharing of information during a public health emergency.

PHAC continues to work on a plan to meets its obligations under the IHRs. This includes finalizing the MOU on ISAs during a public health emergency developed by the Public Health Network’s Surveillance and Information Expert Group, and, during the 2008–09 fiscal year, supporting and participating in the collaborative action plan for its implementation.

Also, as required by the WHO, PHAC will work with partners to develop a comprehensive action plan by December 2009 that will outline how Canada intends to meet its obligations under the Regulations.

PHAC believes Canada’s public health systems are in a much better position than in 2003 to deal with an infectious disease threat of national importance. For example, the agreements that have been concluded between the Agency and its partners since 2004 and the experience of events that have occurred since SARS demonstrate the ability of the Agency and its partners nationally and internationally to address public health threats effectively.

1) Finalize and implement a comprehensive IHR action plan in collaboration with P/T and international partners

H2/2009

Achieved

* An action plan is not required as Canada has met the June 15, 2009 core capacity requirements for surveillance and response, as described under Annex 1A of the Information Health Regulations, as concluded by F/P/T capacity assessments conducted between December 2008 and April 2009. A Pan-Canadian IHR Assessment Report will be published in 2010.

5.91

To comply with Treasury Board Secretariat requirements and aid negotiations with the provinces and territories, the Public Health Agency of Canada should take steps to complete a privacy impact assessment that covers the information-sharing requirements outlined in the memorandum of understanding on the sharing of information during a public health emergency.

In the coming year, the Agency plans to develop and perform privacy impact assessments in compliance with Treasury Board Secretariat policies. The Agency is committed to protecting the privacy of Canadians, and will continue to work with provinces and territories to assess and manage the privacy implications of all types of information shared in the context of public health.

1) Establish an F/P/T working group to address privacy issues.

H2/2009

Achieved

* Data Privacy Work Group was created in September 2008 reporting to the Surveillance Integration Team.

* An F/P/T work group on Information Sharing Agreements has been established and will act as the liaison to the Data Privacy Work Group to address next steps as it develops and deploys a comprehensive data privacy framework

2) Undertake Privacy Impact Assessments on the Agency’s current information holdings which contain personal information as per the Treasury Board Directives

H2/2008 to H2/2012

In progress

* As information sharing agreements are developed the Agency will ensure compliance with the Federal Privacy Act for all personal information exchanged with the P/Ts.