I will call our meeting to order.
Good morning everyone and welcome to meeting number 20 of the Standing Committee on Public Accounts.
I have a special welcome for MP Shanahan who is joining us today. As was noted, I think we still refer to the table at the end of our reports as the Shanahan table. That is a legacy of her time on this committee. I concur. It's an excellent committee so far. I'm new to this committee. So far it has been a joy being on this committee, certainly with our colleagues and the support that we have. Having been a member for 12 years, I would say that we have a really tremendous public service that serves us in our committees. They do great work,
The committee is meeting in public today to study “Report 4—Oversight of the Government of Canada Advertising” of the 2019 spring reports of the Auditor General of Canada.
As you are all aware, today's meeting is taking place in a hybrid format pursuant to the House order of January 25, 2021. Therefore, members may be attending in person in the room or remotely using the Zoom application. However, I do know that everybody is joining us virtually today. I do want to thank all of our witnesses. You were all online and tested well ahead of time. That is very helpful for our meeting, so thank you.
I have a few reminders for our members. Interpretation services are available for this meeting. You have a choice at the bottom of your screen of “floor”, “English” or “French”. Before speaking, click on the microphone icon to activate your own mike; otherwise, you will owe Matt Green some money. When you are done speaking, please put your mike on mute to minimize any interference.
When speaking please speak slowly and clearly. Unless there are exceptional circumstances, the use of headsets with the boom microphone is mandatory for everyone participating remotely. Should any technical challenges arise, as we've seen even at the beginning of this meeting, please do advise me and note that we may need to suspend for a few minutes to ensure that all members are able to participate fully.
I now would like to welcome our witnesses.
Joining us today from the Office of the Auditor General are Andrew Hayes, deputy auditor general, and Michelle Salvail, principal.
From the Department of Public Works and Government Services, we have Bill Matthews, deputy minister, and Jean-Pierre Blais, assistant deputy minister of the receiver general and pensions branch.
From the Treasury Board Secretariat, we have Peter Wallace, secretary of the Treasury Board of Canada, and Kelly Acton, assistant secretary in strategic communications and ministerial affairs.
I will now turn the floor over to Mr. Hayes for five minutes.
Madam Chair, thank you for this opportunity to discuss our report on the oversight of Government of Canada advertising. This report was tabled in Parliament in May 2019. Joining me today is Michelle Salvail, who was responsible for the audit.
The Government of Canada uses communications to inform the public of its programs and services. A message is considered advertising when the government pays to place it in either traditional media such as newspapers, television, radio or billboards, or digital media such as websites or social media platforms.
In 2016 the Government of Canada introduced in its policy on communications and federal identity a definition of non-partisan communications that includes advertising. The government also put in place the requirement that all advertising campaigns with a budget of more than $500,000 would be subject to an external review for non-partisanship, as assessed against a set of criteria that has been specified.
Our audit focused on whether the Treasury Board of Canada Secretariat and Public Services and Procurement Canada were ensuring that the government's commitment to non-partisan advertising was being met. Overall, in our view, the government's oversight of advertising was not sufficiently robust to ensure that no public funds were spent on partisan advertising.
The Treasury Board of Canada Secretariat did not assess risks beyond cost when it set out the external review process for campaigns with budgets exceeding $500,000. In other words, the threshold was based on just the value of the campaign. The secretariat did not consider other important risk factors, such as the campaign’s audience reach or topic. For example, a campaign can cost little but carry more risk because it focuses on a politically sensitive topic, like medical assistance in dying, while an extensive information campaign on a neutral topic, such as handwashing, will cost much more but be less likely to involve political colouring.
We also found that the secretariat did not monitor the quality of the external reviews conducted by Ad Standards, the not-for-profit organization mandated by the secretariat to conduct the reviews. In reviewing files provided by the secretariat, we found little evidence of the analysis conducted to support the assessment of campaigns against criteria. This gap in monitoring means that the secretariat may have missed opportunities to identify and rectify weaknesses in the oversight process.
Public Services and Procurement Canada, or PSPC, reviews campaigns that fall below the $500,000 threshold to ensure that they comply with policy and legislative requirements, including those for non-partisanship.
We found little evidence that the department conducted consistent and thorough reviews against all non-partisanship criteria. For example, we found no indication that reviewers took steps to confirm that statements and statistics presented in campaigns were factual, even though the government's policy on communications and federal identity sets out that non-partisan communications are to be objective, factual and explanatory.
We made five recommendations to the Treasury Board of Canada Secretariat and one to PSPC. Both organizations agreed with our recommendations and prepared action plans. According to the timelines set out in these plans, all our recommendations should have been addressed at this time.
Although we have not conducted additional audit work since 2019, I do want to note that some changes have been made to the external review process. For example, the threshold for sending a campaign for external review has been lowered to $250,000. The committee may wish to ask the Treasury Board of Canada Secretariat whether its analysis of risk factors other than cost has led to other changes to the process.
Since our audit was completed, the government's website shows that more than 50 additional campaigns underwent a mandatory external review, including those related to the COVID-19 pandemic. We also note that review results posted since our audit identify more instances of non-compliance with criteria such as accuracy, factualness and objectivity. We take these results to be an indication of the positive impact of our work.
Madam Chair, this concludes my opening remarks. We would be pleased to answer any questions the committee may have.
Good morning, Madam Chair and committee members. Thank you for having us here today to discuss Public Services and Procurement Canada's response to the spring 2019 audits of oversight of Government of Canada advertising, which were undertaken by the Auditor General of Canada.
As the chair already mentioned, I am accompanied today by Mr. Jean-Pierre Blais, who is the assistant deputy minister responsible for PSPC's work in this area.
Madam Chair, Public Services and Procurement Canada is committed to ensuring that advertising by Government of Canada departments is non-partisan in nature and to playing our role in that regard. We accepted and followed through on the recommendation that we should provide clear direction and training to our advisers on how to conduct reviews of Government of Canada advertising to ensure non-partisanship.
Today I will provide a brief overview of the role that Public Services and Procurement Canada plays in the oversight of the Government of Canada advertising process as well as how we have taken action to support the goals outlined in the recommendation from the Office of the Auditor General.
Communication with Canadians, which includes advertising, is central to the Government of Canada’s work and contributes directly to the Canadian public’s trust in government. Government advertising can help to convey important information about policies, programs and services, as well as information about Canadians’ rights and responsibilities under the law, and information to help protect their interests and well-being.
PSPC provides advisory services and technical advice with respect to legislation and policy requirements, including the federal identity program, official languages and non-partisanship. In so doing, we review all advertising materials submitted and, where appropriate, provide advice to departments in that regard.
With respect to the non-partisan review process, campaigns with a budget of over $250,000—and I appreciate that it was $500,000, I believe, when this audit was undertaken—must undergo a third party review process which PSPC coordinates. Those with a budget under this threshold may be formally reviewed at the discretion of the advertising department.
Regarding the recommendation directed at PSPC, after a review of PSPC files and documentation, the Office of the Auditor General recommended that the department undertake training on how to conduct reviews, including documenting the rationale for assessments.
I'm pleased to report that's exactly what the department has done.
The Auditor General's report made six recommendations with respect to the non-partisan oversight mechanism, of which one, in paragraph 4.51, was directed at PSPC. The recommendation was that Public Services and Procurement Canada should provide clear guidance and training to its half-dozen advisers on how to conduct their reviews, including documenting the rationale for their assessments of all non-partisanship criteria. Following this recommendation by the Office of the Auditor General, with which we wholeheartedly agree, PSPC immediately undertook to create and update training materials and checklists for all of our advisers. This work was fully completed by December 2019.
As part of this work, PSPC developed a process map for the non-partisan review process to support the advisers in the consistent review and documentation of advertising, which was completed in October 2019. This process map was presented to all advisers to ensure they had a clear understanding of the process and that it could be applied in a consistent manner.
A checklist was also developed that includes steps connected to the non-partisan review criteria. This work was also completed in October 2019.
Finally, the new advertising management information system, which has been procured and is now being configured, will allow for all relevant documentation to be stored in the system itself, including a step uniquely associated with non-partisan reviews.
These enhancements to our processes have been implemented and are fully operational.
Madam Chair, I assure you that PSPC is fully committed to its responsibilities in this area and has implemented our response to the recommendation issued by the Auditor General in this aspect. Our guidance and tools have been fully updated to support the consistent application of legislative and policy requirements related to the non-partisan advertising.
I'll leave it there so we have enough time for questions.
We are really looking forward to your questions.
Thank you, Madam Chair.
Thank you, Madam Chair.
As you indicated, I am joined today by Kelly Acton, who serves as the assistant secretary for strategic communications and ministerial affairs at Treasury Board Secretariat.
After my brief remarks, Ms. Acton and I will look forward to answering any questions from you and the committee.
The subject of today's meeting is, of course, the study of the non-partisan review process for government advertising, one of five reports presented by the Auditor General during the spring of 2019. As we've already indicated, this review process was implemented in 2016.
The Treasury Board Secretariat has addressed all of the recommendations outlined in the 2019 spring report of the Auditor General. I'll simply review those recommendations and then look forward to your questions.
The first recommendation was to consider a risk-based approach to identify campaigns with the higher risk of partisanship. At issue in this recommendation is a determination of what is the best indicator of risk. To date, advertising spend and the total of that spend has been the best indicator.
After an analysis of the review process, it was concluded that a consistent dollar-based target remains the most reliable indicator of risk. That threshold has now been reduced for mandatory review of ad campaigns from $500,000 to $250,000. This reflects the changing nature of the industry and a trend toward somewhat lower dollar amounts in the use of digital media in advertising campaigns. This approach is designed to capture at least 80% of the government's annual advertising budget.
The second recommendation was to ensure that the Ad Standards, the external third party review mechanism, documents the rationale for its assessment of government advertising campaigns against all non-partisan review criteria. In response, the new evaluation form for Ad Standards to assess ad designs and better document their findings has been developed by Treasury Board officials and implemented in this process.
The third recommendation was to assess the appropriateness and application of the two-stage review process to ensure that it is effective and works as intended. The process is set up to ensure that ads are reviewed twice: first, early in the production process and then before actually going to market. This allows any creative work to be reviewed and modified, if necessary, before additional costs or delays are introduced into the process.
Officials found that, depending on the type of media used in the advertising, the period of time between the reviews fluctuated. Based on those findings, it was determined that the process was working as intended and did not in fact need to be changed. Informed by work on this recommendation, guidance was developed to ensure departments plan the timing of their review request to Ad Standards. This guidance was shared with departments and is also posted on Canada.ca.
The Auditor General's fourth recommendation was to improve how officials monitor ad campaign reviews and whether Ad Standards is thoroughly and consistently applying all non-partisan criteria in its reviews. In the fall of 2019, a panel consisting of officials from both Treasury Board Secretariat and Public Services and Procurement Canada began assessing a sample of Ad Standards' reviews each quarter and determined that Ad Standards was applying the criteria consistently. This oversight is, of course, ongoing.
The fifth and final recommendation called for an independent, objective review process to receive, review and respond to public complaints about partisanship in government advertising. In 2020, after looking at options, including the feasibility of implementing an independent review complaint process, a pilot project was established to accept, review and report on public complaints in this area. The public can now submit a complaint online about any Government of Canada advertising that they may feel is partisan. The nature of the complaint and findings of the review would then be posted on Canada.ca.
Treasury Board Secretariat is committed to ensuring that there continues to be an independent and strong oversight of Government of Canada advertising. The audit identified process gaps and not substantive deficiencies in oversight. As noted, these recommendations have been addressed.
Ms. Acton and I are, of course, prepared to answer your questions.
Thank you very much.
Thank you very much, and thank you to all the witnesses for appearing.
My challenge with this overall review is that in first-year law school we all learned about Lord Denning. One of the things he would say is that it was not the biases he was aware of that would scare him; it was the biases that he was not aware of.
When we look through this process, I understand that the tree breaks out into two: it was at $500,000 and now it's $250,000. However, I'm troubled that we're perhaps not getting results.
I just want to first confirm that we have 2020 numbers when it comes to reviewing that. Do we have those numbers now? This report was done for 2019.
Can anyone answer?
Thank you for the question.
In response to our recommendation, the secretariat of the Treasury Board has described the change to the approach that they have put in place. Again, it's based entirely on the cost of the campaigns. From our view, other considerations, such as the subject matter of the advertisement campaign or the timing or audience reach, are important to consider in terms of the risk that partisanship might be present in advertising.
The question you raised about the ability of departments to break campaigns into smaller pieces, for example, could in fact bring those campaigns below the $250,000 threshold. That is exactly why we were recommending a risk-based approach to the external review.
Thank you, Madam Chair.
Thank you to the honourable members and all of our witnesses.
My question is for you, Mr. Hayes. Thank you for being here today. It's always a pleasure to have you. Please say hello to Ms. Hogan for us.
I practically jumped out of my seat at the beginning of your remarks. Specifically, I'm referring to paragraph four, where you said, and I quote, “the government's oversight of advertising was not sufficiently robust to ensure that no public funds were spent on partisan advertising.” I am sure you can easily see where I'm going with this. It brings to mind a dark moment in our recent history involving the Government of Canada and its advertising spending, as you can appreciate.
Given your findings, can you say with certainty that we will never experience another sponsorship scandal?
Thank you for clarifying that, Mr. Hayes. It's rather troubling that we can't be certain public money isn't being used for partisan activities. I also realize that the circumstances today aren't what they were back then, circumstances that led to the Gomery commission. Since the same political party is in power now, I don't mind telling you that I have concerns.
You also noted that the Treasury Board of Canada Secretariat failed to properly examine the external reviews conducted by Ad Standards—failed, in fact, to examine them at all. In your remarks, you pointed to the differences in the outreach of government advertising campaigns.
In the current context, the messaging around handwashing to prevent the spread of COVID-19 would not be considered partisan, of course. I can, however, think of advertising campaigns that might cause confusion, those run by Economic Development Canada, the Business Development Bank of Canada and Destination Canada, for example.
In light of the current political climate, not to mention your audit findings and the millions of dollars spent on government advertising, can you confirm to the committee that you will be keeping a close eye on what happens next and initiating another audit to keep things from getting out of hand?
Madam Chair, I want to be sure I understand what Ms. Salvail just said.
They didn't focus on that aspect, but they didn't identify any issues.
I'd like to know whether the matter received any attention, since reviewing for compliance with the Official Languages Act falls under the department's roles and responsibilities and is subject to the audit, as per paragraph 4.8 of the report.
Do you have any information on that, Ms. Salvail? If you can't provide us with an answer now, would you mind getting back to us in writing?
Thank you, Madam Chair.
Thank you, as well, to the witnesses for being with us today.
My first question is for Ms. Acton. We heard earlier that the number of complaints about partisanship in government advertising is quite low. Ms. Acton said the complaint form was available on the Canada.ca site.
Ms. Acton, I tried looking for the information on how to file a complaint on Canada.ca, but I wasn't able to find it. The site is supposed to answer any question Canadians may have about the Government of Canada. You said the Treasury Board of Canada Secretariat had posted information about how to file a complaint on Twitter, and that's how I found it.
Don't you think it's a problem when a simple process to file a complaint about government advertising isn't readily accessible to Canadians?
Canada.ca is supposed to cover everything government-related. I don't think you're making it easy for Canadians to file complaints about partisan advertising.
Ms. Acton, what matters is having a simpler and more accessible process for Canadians who wish to file a complaint, because right now, that's not the case.
I have another question for you.
We are in the midst of a pandemic, and the government is running all kinds of ad campaigns. Since the Treasury Board of Canada Secretariat still uses a dollar value as the threshold for its reviews, I'm wondering when exactly ad campaigns undergo review.
Does it happen when they are developed, publicized or later?
When do the red flags go up?
Madam Chair, I may be able to answer that.
The process provides for an initial review and a final review. In the initial review, the department submits a fairly comprehensive document on the communication plan. It includes information on the proposed media, the communication strategies and funding amounts. That initial review determines whether the proposed campaign is sent to Ad Standards for review. Then, once any changes have been made, the campaign goes to the committee a second time.
It's important to understand the difference between the overall ad campaign and the individual creative components. For instance, a campaign valued at more than $250,000 may have very short ads on a website, but also a full-length ad on television.
Thank you, Mr. Lawrence. I appreciate your giving up your valuable time.
I want to continue on with the line of questioning of Mr. Berthold regarding public complaints.
Secretary Wallace, you alluded to it in your opening comments. I just want some clarification here.
I'm watching an ad on television about COVID, washing your hands and sanitizing, and in the background there's a green bus bench. Clearly that is a partisan ad right there to see a green bus bench. Of course, that is promoting the Green Party of Canada and Matthew Green. That was clearly something that I would complain about, and I would send it in.
I understand that I would submit that complaint online, but to whom? Is it clearly indicated on the Government of Canada's website where I can go to make this complaint and the process also? You've received my complaint. Who reviews it and who responds? Do you respond to the complainant? I see from the opening comments Mr. Wallace indicated that the review is posted on the site.
Maybe just give us some indication of what exactly goes on with a complaint such as a complaint of a green bus bench.
Thank you very much, Madam Chair.
I would also like to thank the witnesses appearing before us today.
I had a series of questions, but I am really intrigued by those that some of my colleagues have asked.
It's important that the debate be refocused on the issue of Ad Standards, which has been determining standards for advertising in Canada for several decades.
Ms. Acton of the Treasury Board recognized that Ad Standards has been around for a long time. It is a non-partisan, non-profit organization. It determines and administers the process for compliance in online behavioural advertising. It does the same for television and newspaper advertising standards.
My question is for a representative of the Office of the Auditor General.
Mr. Hayes, do you consider Ad Standards to be a legitimate and recognized body that is able to evaluate whether or not our advertisements meet non-partisanship requirements?
Thank you for your question.
I would say yes. We consider the organization to be independent and therefore able to review advertising campaigns objectively.
However, our report raises issues within the organization, including its involvement in the complaints process. We did not conduct an audit in that area, but the complaints process has changed. It has therefore likely been improved.
When I look at the situation, I feel that this group does its reviews objectively.
Thank you, Madam Chair.
My question is for you, Mr. Hayes. In your introduction to the general information section, in point 4.2, you wrote that the 2016–17 fiscal year was the first year that the Government of Canada spent more on digital advertising than television advertising. It was known at the time that the government was spending more for online advertising, but the $500,000 threshold was lowered to $250,000 precisely because online advertising is cheaper.
Would you say that the government was slow to amend the legislation as an external review mechanism?
My next question is for Mr. Wallace.
Since 2016–17, we have known that the government has been spending more on online advertising, but the threshold remained $500,000. You yourself said that the new threshold of $250,000, which has been in effect since April 1, 2020, has helped you capture 80% of the government's annual advertising budget.
Are you saying that, for four years, the mechanism was inadequate because the threshold was too low?
I appreciate the question.
We should recall through all of this that this is a backstop, that there is an obligation on public servants to not undertake partisan advertising and that campaigns should never be partisan in any way. What we have established is not only an existing policy but also a review mechanism to ensure that this policy is implemented.
We need also to have thresholds associated with that simply so there is a responsible use of government money. We maintain a degree of efficiency and effectiveness in terms of the allocation of our resources, and almost every policy does require a threshold of $500,000, as the Auditor General correctly pointed out.
It's hard to believe it was 25 years ago that Allan Cutler first raised alarms about ad scams and bid rigging, and here we are, I think at a very important point in time, with the kind of spending we have in COVID.
Hopefully, through this committee, we can get at any of the shortcomings of this current program with some solid recommendations so that post-COVID, when we look back at this, we will have had a better and more fulsome program.
I want to go back to the deputy AG and talk about paragraph 4.48, where you stated:
We found that the Department provided no guidance to its communications advisors (for example, through manuals or training) on how to conduct reviews, including what criteria to apply and how to apply them, or on the requirement to document their analysis. In our view, this lack of guidance could lead to inconsistencies in how different communications advisors interpret and apply government advertising review criteria.
What is your response to that particular statement, knowing that post-COVID, we're going to have to look back on this? What would be your recommendations in terms of making sure there is a service standard across all departments?
Thank you for the question.
I would note that the deputy minister has responded to the recommendation. While we haven't had an opportunity to audit the situation now, we note that guidance and training have been provided, according to the deputy minister, and that addresses our recommendation.
Perhaps the more important point I'll make is that, likewise, it's important that the documentation of the results of their review be captured on file in order for oversight to be conducted as well.
I very much appreciate this line of questioning. I am sensitive to the issues being raised at this committee.
The external review is designed to make sure that ads are fully consistent with the criteria. When Treasury Board undertook, in response to the auditor's request, a full review, we did look at lowering the threshold. We looked at a variety of other elements as well. The challenge with the other elements, to be quite frank, is that they are inherently subjective. We've already had a conversation at this committee about the nuanced nature of those elements.
It remains my view, although obviously we will listen very carefully to the sense of the committee, that there is, frankly, no free lunch in advertising. The best understanding, the best mechanism we can get for understanding the reach, impact and potential risk of public funds remains firmly embedded in the fiscal amount. It's very clear, very explainable, technically defensible criteria.
If we try to get into other aspects, such as the questions about handwashing or some other elements, frankly, we're introducing a subjective element. That subjective element is probably best implemented by Ad Standards Canada or by the people who are originally proposing the advertising at the department level.
Thank you, Madam Chair, and thank you to our witnesses.
Earlier in today's discussion we had a conversation around the complaint process and how to go about finding it. Mr. Berthold, you raised this, and it piqued my interest in seeing what the process actually was. I did a Google search and found it on the second listing.
Ms. Acton, I want you to know that I have filed a complaint. Of course, it's a test complaint, and I've written that there. It took about two minutes. It speaks, certainly, to the process, that it is pretty straightforward. I was very casual off the street in finding that on Google, and within two minutes I was able to file a complaint. It is pretty straightforward in terms of moving forward.
One of the questions I had going through it.... Of course, this is confidential. You're not asked to give any type of information or parameters around who you are. I can understand that to a certain extent, but have we considered being able to leave some information, such that when a decision is made on the complaint—as you said, it's usually about 10 days that you try to file and make a decision—is there some way for individuals who are doing that to track that through the system if they have busy lives and maybe don't stay connected? Have we considered that?
What we found was that the information available to us when we were reviewing the files was not sufficient to establish that the criteria had been reviewed by Ad Standards or by PSPC when they were conducting the review, so we can't say with any assurance whether or not there were problems.
In terms of the complaint process, while there haven't been many complaints—or none until, I guess, yours—for a number of years, I would say that in itself could be a good thing or a bad thing. I worry as a manager when I see zero complaints, because I wonder whether or not that means the process is working fine, or whether it means that people don't know about the process, or there are maybe problems with the process.
We highlighted one about independence and objectivity in our report, and I know that's been addressed according to the information from the secretary and the deputy minister.
Mr. Hayes, at one point during the line of questioning earlier, you talked about.... I do have some concerns about more elements being externally reviewed.
As has been mentioned, there were three out of 1,800 that, as I understand it, would have gone to Ad Standards Canada to be reviewed, but I think it's fair to note too that our public servants who are working on this take an oath to be non-partisan as well.
Do you actually see concerns? Outside the processes you handled, surely our public servants who are working on this, so long as they're following the standard—and I think our departments have talked about the mechanism they've had to tighten this up—are well placed to handle some of this discretion as well. Would you not agree?
Thank you, Madam Chair.
I will come back to Mr. Wallace and the question I asked earlier.
Let me summarize it for you, Mr. Wallace.
In 2016, we already knew that the federal government was spending much more on digital advertising than on television advertising. Then, in 2018, the gap widened even further, with the federal government spending five times more on advertising on digital platforms than it did on television or newspaper ads.
However, the Auditor General did a report on Government of Canada advertising. The Treasury Board Secretariat had already proposed a new threshold, which you specified between June and December 2019. Finally, on April 1, 2020, you decided to lower the threshold from $500,000 to $250,000 because it's cheaper to advertise online and the $500,000 threshold was no longer realistic.
You say that cost remains the most reliable indicator of risk and that the new approach will cover about 80% of the government's annual advertising budget.
Since we know that the government has been spending more online for four years and the threshold has never been lowered, does it mean that the external review mechanism was basically inadequate for all those years?
There are a couple of different things. We do very much appreciate the review from the Auditor General, pointing us to the need to re-evaluate thresholds and make sure those thresholds are appropriate. It is not necessarily that digital advertising is cheaper. Digital advertising provides a reach but it is actually priced. There is a market, and it is my personal view that there's no free lunch in advertising or anything else.
The market clears and the market is adjusting, so expenditures, whether digital or traditional, remain expenditures on advertising. They are a reliable mechanism in understanding the core criteria associated with audience reach, which is essentially what it costs to purchase eyeballs or ears, or the ability to project content. That's consistent across digital and non-digital media, this ability of markets to equilibriate and determine the appropriate pricing of other elements.
However, in some respects, digital may require and may promote the use of smaller bundles of advertising in a more agile way. Because of that, it does make sense to lower the threshold, and our review determined that lowering it to $250,000 is required to make sure that we continue to capture 80% of all advertising directly and have it go through an external review process.
Madam Chair, I can set the record straight.
According to the report, from 2015 to 2016, the amount invested decreased from $42 million to $36 million. From 2016 to 2017, it increased from $36 million to $39 million, and from 2017 to 2018, it went up from $39 million to $58 million. However, from 2018 to 2019, according to the latest public report, it went down from $58 million to $50 million.
So it varies from year to year. It should also be recognized that, in election years, no advertising is done for five to six months.
I'd like to pick up on it. Mr. Blanchette-Joncas has some great lines of questioning.
I'm also stuck on the threshold.
As you know, Madam Chair, I'm on OGGO and procurement. We used to be on that committee together. One of the ways in which we found the public service skirted these thresholds was that rather than have $300,000 as a contract, it would be broken up 10 times into $30,000 or something like that.
Just to be clear, when we talk about the thresholds, is this per company for the entire year? It would make sense if it's only on the actual contract at hand. For instance, could one company have four contracts for $249,000?
It might be something to consider. I'd also recommend doing a survey, as I believe that would actually let you guys know whether anyone's reviewing it. Is it zero complaints? If, for example, there were no complaints about discrimination in the workplace, I would be worried. I'd be very concerned. Why aren't people reporting that? I wouldn't just say, “You know what? Maybe there's no discrimination.”
I think we need to look at that seriously.
I'm hoping that you can dissuade me of some concerns I have. Let's just say that the government decides to push its tentacles into the public service, as has happened in SNC-Lavalin, or might have happened in the WE Charity scandal. Then they say, “You know what? This Philip Lawrence guy keeps asking our officials all these annoying questions. We want to get rid of him.”
There's a flooding issue that's around my riding, and Bay of Quinte has a Liberal member. They say they're going to pump in 25 thousand dollars' worth of media to say how much they're doing to protect against flooding in that particular riding, but they're not going to put that money in.... I'm wondering if there's anything external to stop that $25,000 social media control, because I'm not hearing any. I want to believe there is, but I'm not hearing any.
Thank you very much, Madam Chair.
It is a real pleasure to have the opportunity to be part of this committee. I welcome the chance also to thank our public servants here today from the Auditor General's office, PSPC and the Treasury Board for the work that they do. The integrity that they bring to the table, I think, is unparalleled when we look at what happens elsewhere.
Indeed, it reminds me very much of some of these conversations and discussions that we had when I was on the public accounts and government operations committee three or four years ago: that the intent of the legislation and the policy was that, regardless of the government in power, the public servants would be empowered to make those determinations of what constitutes partisan advertising and would be able to act accordingly.
On that note, I would like to ask what the criteria are. Maybe give me a couple of examples of what constitutes partisan advertising.
Perhaps I can help on that side.
If there was an advertising campaign, under the federal policy the department would develop a rather elaborate communications plan. If it's subject to review, we would also receive that, and there would be two review processes.
Maybe I can add—and Deputy Matthews mentioned it a moment ago in his opening remarks—that we're positioning a new AdMIS program. It's going to come online on the first of April. It's a cloud-based solution that will allow much better documentation of the various steps. Going forward, quite apart from the new criteria that we outlined that we put in following the Auditor General's report, we will have a system that actually is able to track even better the ad-clearing process.
I actually want to note for the benefit of other committee members that something that we were seized with a few years ago was the matter around data capture. That was something where there were great deficiencies. It's very hard to measure and review what you don't have data concerning.
Also, I want to commend the departments on their completion of the action reports. That was another issue that we were seized with. The Auditor General's reports would be produced at much cost and with much attention, but then were not necessarily followed up on. Now I see the action reports that are communicated to this committee, which are very useful. We can see the progress that is made or not made and can react accordingly.
Madam Chair, do I have any time left?
Thank you very much, Ms. Shanahan and Mr. Blais.
Witnesses, I would like to thank you for attending our meeting today and for the testimony you have provided. We do appreciate it.
I will invite you to take your leave. Thank you.
Colleagues, I have just a very quick reminder that there is no committee meeting on Thursday, but you should have received an invitation for the Auditor General's virtual lock-up, which is happening between 12 p.m. and 1 p.m., eastern standard time. The log-on information will be sent to you later this week.
Is the committee in agreement to adjourn the meeting?
I see thumbs up. Great. Thank you.
The meeting is adjourned.