4.26 Indian and Northern Affairs Canada, in cooperation with provinces and First Nations agencies, should:

* define what is meant by services that are reasonably comparable,

* define its expectations for culturally appropriate services and standards, and implement this definition and these expectations into the program. (4.17–4.25)

INAC to ensure that its authorities reflect reasonably comparable and culturally appropriate services

01/04/2007

Status: Completed

Update/Rationale as of 31/03/2009:

INAC updated its authorities for the Child and Family Services program in April 2007.  The update included a broader and more culturally appropriate range of placement options, including kinship care (care provided by extended family members), post adoption subsidies (monthly payments to the adoptive parents) and supports (including counselling services and special needs support for children with disabilities) to encourage permanent placement for children.

In addition, INAC will develop a principle based on historical and provincial/FN understanding of what is deemed as culturally appropriate services. 

31/04/2009

Status: In progress

Update/Rationale as of 31/03/2009:

INAC will develop a principle on culturally appropriate services as a specific definition would depend on the interpretation of various First Nations, based upon their specific and unique community circumstances and needs.  Specific culturally appropriate services are included in both the framework documents and the business plans which form the basis of the Enhanced Prevention Focused Approach in the transitioned regions.  INAC will provide the principle in its response to the recommendations of the Public Accounts Committee by July 2009.

INAC to ensure that the principle is reflected in Tripartite Frameworks developed under the Enhanced Prevention Focused Approach.

Ongoing

Status: In progress

Update/Rationale as of 31/03/2009:

The tripartite frameworks in Alberta, Saskatchewan, and Nova Scotia clearly describe expectations on culturally appropriate services as well as reasonable comparability to provincial services.

INAC to ensure that the principle is communicated to Regional Offices, First Nations and Provinces (i.e. updating the FNCFS Program Manual)

30/09/2009

Status: In progress

Update/Rationale as of 31/03/2009:

Once the principle on culturally appropriate services is developed, it will be communicated to Regional Offices, First Nations, and Provinces.

4.32 Indian and Northern Affairs Canada should ensure that it has up-to-date agreements with the provinces and with First Nations agencies in place. As a minimum, these agreements should consistently define who is responsible for providing the child welfare services required under provincial legislation, and what services will be provided. (4.27–4.31)

INAC to ensure that agreements with FNCFS agencies include requirements for Business Plans, or Work Plans as appropriate (whether they are under Enhanced Prevention Focused Approach or still need to transition), that clearly outline roles, responsibility for providing child welfare services required under provincial legislation, and services provided. 

31/03/2010

Status:  In progress

Update/Rationale as of 31/03/2009:

Alberta, Nova Scotia and Saskatchewan, are already party to tripartite accountability frameworks with Provinces and INAC which require Business Plans to access the Enhanced Prevention funding.  In addition to tripartite framework, the FNCFS agency in Nova Scotia has a funding agreement with the province as do the agencies in New Brunswick, Newfoundland, Prince Edward Island, and Yukon who also have agreements with their respective province/territory that outline the respective roles and responsibilities of the parties.  We will work with the remaining provinces to develop similar agreements that specify roles and responsibilities.

Agencies who are not yet delivering the Enhanced Prevention Focused approach have begun developing Work Plans as recommended for fiscal year 2009/10 and will be required to submit Work Plans for fiscal year funding in 2010/11.

INAC to ensure that Work Plan and Business Plan reporting formats are incorporated into the 2008-2009 First Nations National Reporting Guide that is utilized by INAC to guide First Nations recipients on reporting.

31/03/08

Status:  Completed

Update/Rationale as of 31/03/2009:

The National Reporting Guide was updated in March 2008.

4.37 When negotiating agreements with each province, Indian and Northern Affairs Canada should, in consultation with First Nations, seek assurance that provincial legislation is being met. INAC should also analyze the information obtained and follow-up when necessary. (4.33–4.36)

INAC to work with provinces to ensure that Agencies meet provincial legislation. 

Status:  Ongoing

Update/Rationale as of 31/03/2009:

INAC has intervened with Agencies when provinces have indicated areas for improvement.  For example, INAC and the Government of Manitoba are co-funding an audit of a specific Agency in the Province of Manitoba.

In the Atlantic Region, funding has been withdrawn from one First Nation and redirected to the Province as protection staff did not meet provincial standards and therefore the Department’s authorities. Since that time, the Province has provided additional oversight and resources to the First Nation.

INAC to ensure that compliance reviews are conducted on a regular basis, and as needed. 

31/05/09

Status:  In Progress

Update/Rationale as of 31/03/2009:

All FNCFS agencies are required to meet provincial standards.  INAC regions have conducted 27 compliance reviews in fiscal year 2008/09.

INAC to support Tripartite Tables that discuss issues within each province and explore areas for collaboration including the establishment of new enhanced prevention frameworks. 

Ongoing

Status:  In Progress

Update/Rationale as of 31/03/2009:

INAC has been heavily involved in Tripartite tables throughout the transition of the FNCFS program to an Enhanced Prevention Focused Approach.  This is an ongoing exercise.

INAC to coordinate a schedule for annual FNCFS agency self-evaluations to assess agency effectiveness including meeting provincial standards, on a three-year cycle

30/06/07

Status:  Completed

Update/Rationale as of 31/03/2009:

A schedule for annual FNCFS agency self-evaluations to assess agency effectiveness, on a three-year cycle, was developed with regions in 2007-2008 and funding for the first year of evaluations was transferred to regions in 2007-2008. 
Funding for agency evaluations is now included in regional allocations as of 2009-10.  

INAC to ensure that the self-evaluations are conducted and results consolidated into a 3-year final report. 

31/03/2010

Status: In progress

Update/Rationale as of 31/03/2009:

21 evaluations are in progress and reports are expected by end of summer 2009. Based on an analysis of the agency self-evaluations, INAC will initiate discussions with provinces and territories to work on individual agency deficiencies and share best practices beginning in September 2009.  INAC is exploring opportunities with provinces for joint reviews and is working with provinces to address deficiencies that may be identified in provincial program reviews. 

4.42 Indian and Northern Affairs Canada should resolve the fundamental differences with Health Canada related to their respective funding responsibilities for services to First Nations children in care. (4.38–4.41)

INAC to meet on a regular basis with Health Canada officials to clarify responsibilities and funding for First Nations on reserve children in care, and to develop a federal response on Jordan’s Principle.

31/03/2009

Status:  In Progress

Update/Rationale as of 31/03/2009:

INAC and HC have met on numerous occasions over the course of fiscal year 2008/09 and have developed a federal response based on a child-first approach which will address funding issues. 

(Audit Committee Comment: * Letters were sent by Ministers Strahl (INAC) and Clement (Health Canada) in May 2008 outlining the federal response – a “child-first” approach – and inviting provinces to work collaboratively on implementation)

INAC to identify key contacts (focal points) in regional offices of INAC and Health Canada to identify and address emerging issues related to jurisdictional responsibility for services required by a child with multiple disabilities.

31/03/09

Status: In Progress

Update/Rationale as of 31/03/2009:

Regional focal points have been identified by both INAC and Health Canada and meet regularly to discuss areas requiring clarification.  INAC/Health Canada focal point meetings took place in September 2008 and February 2009. These meetings provided for a better understanding of federal responsibilities and an update on activities in other jurisdictions.  Health Canada obtained approval on an approach to address provincially disputed items in March 2009.

INAC to work with Health Canada to develop a Memorandum of Understanding.

31/12/09

Status: In progress

Update/Rationale as of 31/03/2009:

An MOU will be signed by senior management within INAC and Health Canada in May 2009.

INAC and Health Canada to work to resolve funding and eligibility issues regarding the Non-Insured Health Benefits Program (run out of Health Canada).

31/03/09

Status: Completed

Update/Rationale as of 31/03/2009:

Health Canada will be covering eligible expenses under the Non-Insured Health Benefits Program for children in care of FNCFS Agencies.

4.47 Indian and Northern Affairs Canada should examine the human resources requirements for this program and allocate sufficient resources to meet these requirements. (4.44–4.46)

INAC to conduct a Human Resources Requirements Review for the Program

30/06/2008

Status:  Completed

Update/Rationale as of 31/03/2009:

INAC has reviewed its human resource requirements.

INAC to assess feasibility of reallocate resources within the Department on an interim basis, and developing a process for reallocation to reinforce compliance efforts and to provide performance information. 

30/06/2009

Status:  In progress

Update/Rationale as of 31/03/2009:

INAC has reallocated resources within the Department on an interim basis and a process for reallocation to reinforce compliance efforts and to provide performance information is in place.

4.67 Indian and Northern Affairs Canada, in consultation with First Nations and provinces, should ensure that its new funding formula and approach to funding First Nations agencies are directly linked with provincial legislation and standards, reflect the current range of child welfare services, and take into account the varying populations and needs of First Nations communities for which it funds on-reserve child welfare services. (4.48–4.66

INAC to ensure that transition work towards the Enhanced Prevention focussed approach include the requirements as outlined in the OAG recommendations. 

The new costing model is developed after reviewing the respective provincial program, salaries and case loads to determine provincial comparability within the FNCFS program authorities.

31/03/2013

Status:  Ongoing

Update/Rationale as of 31/03/2009:

INAC requires the development of tripartite enhanced prevention frameworks and new costing methodologies in partnership with provinces and First Nations.  The frameworks outline the reasonably comparable and culturally appropriate services that are to be provided over a five year period. 

INAC is providing $98.1 Million over 5 years to implement this new approach in Alberta beginning in 2007/08 and all Agencies opted into the approach before March 31, 2008.  In July 2008, tripartite frameworks were reached between the Government of Canada and the Provinces of Nova Scotia and Saskatchewan and First Nations in those provinces to implement the enhanced prevention-focused approach.  INAC invested an additional $10.2 million over five years in Nova Scotia and $104.8 million over five years in Saskatchewan for First Nation agencies serving on reserve children.  Canada’s Economic Action Plan announced a further $20 million over two years to implement the enhanced prevention-focused approach in additional provinces. 

INAC to ensure that once funding is obtained, Business Plans are developed by Agencies clearly outlining provincial comparability, culturally appropriateness and how the needs of the community will be met.

Ongoing

Status:  Ongoing

Update/Rationale as of 31/03/2009:

In Alberta, five-year Business Plans were developed in all 18 Agencies before the end of March 2008.

In Nova Scotia, a five-year Business Plan was developed before the end of March 2009. 

In Saskatchewan , five-year Business Plans have been developed by 13 out of 18 agencies that were ready to opt-in in 2008-09.  Region will continue to work with the 5 remaining agencies to finalize Business Plans in fiscal year 2009-10.

INAC continues to work with ready and willing partners to transition the First Nations Child and Family Services Program. 

Ongoing

Status:  Ongoing

Update/Rationale as of 31/03/2009:

It is anticipated that most, if not all jurisdictions will have moved to the prevention-focused approach on-reserve by 2012-13.

4.74 Indian and Northern Affairs Canada should determine the full costs of meeting the policy requirements of the First Nations Child and Family Services Program. It should periodically review the program's budget to ensure that it continues to meet program requirements and to minimize the program's financial impact on other departmental programs. (4.68–4.73)

INAC to review its cost estimate for delivering the program on a regular basis both regionally and nationally and to incorporate updates into any business case. 

Quarterly

Status:  Ongoing

Update/Rationale as of 31/03/2009:

INAC has consistently assessed funding requirements as it has transitioned the FNCFS program to the Enhanced Prevention Focused Approach.  Each request for policy and funding authority has included updated business cases.

INAC will continue to review on an annual basis and seek sources of additional resources to minimize the financial impact on other departmental programs.

4.82 Indian and Northern Affairs Canada should carry out the on-site compliance reviews required under the First Nations Child and Family Services Program. It should also ensure that its British Columbia region complies with Treasury Board authority. (4.75–4.81)

INAC to increase its compliance activities beginning in 2008-09 and ongoing.

Ongoing yearly

Status:  Ongoing

Update/Rationale as of 31/03/2009:

INAC regions have conducted 27 compliance reviews in fiscal year 2008/09.

INAC to ensure that prior to entering into the enhanced prevention focused approach FNCFS agencies have undergone recent compliance activity.

31/03/2010

Status:  Ongoing

Update/Rationale as of 31/03/2009:

This practice is in place in Alberta, Saskatchewan, and Nova Scotia; and will be in place in the next provinces to move to the Enhanced Prevention Focused Approach.

INAC to determine best practices on compliance, including ensuring participation by Headquarters officials in regional compliance reviews to better inform the revisions to the directive. 

31/03/2010

Status:  In progress

Update/Rationale as of 31/03/2009:

The FNCFS compliance directive and approach will be linked to the sector-wide approach which is currently in development, in the larger context of risk management and compliance activities led by Audit and Evaluation Sector.  The revised FNCFS compliance directive to be completed by March 2010.

INAC’s British Columbia Region to develop an action plan to better comply with program authorities with an orderly transition that will not undermine FNCFS services for First Nations children.

31/12/09

Status:  In progress

(Audit Committee Comment: * A draft plan is currently being developed)

4.91 Indian and Northern Affairs Canada should define the information it needs to manage the program and account for its results, with a particular emphasis on results and outcomes. In cooperation with First Nations and provinces, INAC should develop performance indicators, define the information required, collect the information, and ensure its quality. (4.83–4.90)

INAC to develop performance indicators for the FNCFS program.

31/03/2008

Status:  Completed

Update/Rationale as of 31/03/2009:

In fiscal year 2007/08, INAC produced a Results-based Management and Accountability Framework that included a Performance Measurement Strategy, which is now being refined.

(Audit Committee Comment: * Performance Measurement Strategies are now required by the
April 1, 2009 Government of Canada Policy on Evaluation and the Transfer Payment Policy of October 2008)

INAC to validate the performance indicators with key stakeholders (Regional Offices, First Nations)

30/09/2009

Status:  In progress

Update/Rationale as of 31/03/2009:

INAC met with the Regional Offices and conducted a validation exercise of the performance indicators in February 2008.  INAC also initiated discussions with provinces/territories in September 2008 to discuss mutually agreed upon indicator development. 
INAC is planning to meet First Nations representatives to validate the indicators and finalize the process.  The expected date of the meeting is in Spring 2009 with a completed and updated Performance Measurement Strategy in place by the end of September 2009

INAC to develop a national FNCFS Information system intended to capture both quantitative and qualitative data that would demonstrate program outcomes.

30/09/2009

Status:  In progress

Update/Rationale as of 31/03/2009:

INAC has begun work on the development of a National FNCFS Information System. The first stage of development requires preparation of the Preliminary Project Approval (PPA) document to identify resource requirements and potential systems. The expected date of completion of the PPA is September 2009.