Salary and Training Awards Programs

1. CIHR's process for reaffirming the awards recipients' eligibility annually is generally effective, but could be improved through the collection of better information on the various types of eligibility.

a) There are two primary and universal eligibility requirements: the recipient must be affiliated with an eligible institution and must occupy an appropriate role. There are three roles for Salary and Training Awards: student (masters, doctoral and health professional recipients working towards a degree under the supervision of an independent researcher), fellow (post-doctoral or post-health professional trainee recipients working under an independent researcher) and researcher (independent research recipients employed by the institution). Though institutions adequately report the presence or absence of the recipient, they are less clear on their status as a trainee, fellow or employee. When an individual changes roles (such as a trainee becoming an independent researcher at the institution) the annual assertion received by CIHR may correctly state that the individual is still present at the institution, but not indicate that the individual has changed roles.

Of 181 files reviewed in this regard, role-related eligibility was identified as a problem in only 1 file. However, CIHR does not explicitly request affirmation of role-related eligibility and consequently the extent of non-compliance is not known.

In addition, specific funding opportunities (generally for strategically-funded awards) can have extra requirements for ongoing eligibility. These requirements need to be reviewed on an annual basis as well.

b) Partner-funded awards that are managed by CIHR are accounted for as "encumbered" until specific actions are taken (generally in the form of the deposit of funds by the partner in a CIHR account), at which point their status becomes "outright". The annual eligibility assertion is based on an Electronic Information System (EIS, used for processing grants and awards) report for each institution that only reports on files that have "outright" funds available in the upcoming year. This can result in an incomplete list that does not include awards for which CIHR is responsible but for which funds are not yet considered "outright".

Of 181 files reviewed, there were only 2 instances of this.

Responsibility: Director, Finance

Action: CIHR Finance will meet with ITAMS to discuss including partner-funded awards which are encumbered as part of the reports generated for the annual eligibility assertion process.

If feasible and cost-effective, Finance will work closely with ITAMS to ensure that these new reports are available for use prior to the next annual reaffirmation of eligibility process, scheduled to take place in February 2011.

Timeline: January 31, 2011

2. While compliance with the essential criteria of the Grants and Awards Guide (GAG) and individual funding opportunities (eligibility criteria, reporting, leave requirements and documents for peer review members) is generally well controlled, not all obligations listed in the GAG and funding opportunities are enforced and not all the activities undertaken by CIHR staff are requirements of either the GAG or the individual funding opportunities.

The GAG lists several requirements that are not consistently enforced by CIHR. For example:

• Foreign applicants and Canadians training in foreign countries are required to provide visas, but none of the files reviewed included appropriate documentation;
• The date of birth or adoption for maternity leaves was not always provided;
• Before releasing funds, CIHR does not document the receipt by the institution of partner funds, and ethics, biohazard and other certifications; and
• CIHR does not follow-up on the lack of the applicant's supervisor's approval of non-award earnings.

In other cases, staff practice goes beyond the requirements of the GAG. For example:

• For certain leave requests, CIHR requests confirmation of the return to the training environment or repayment of funds if a recipient terminates early after a leave; and
• The Tri-council (CIHR, Social Sciences and Humanities Research Council, and Natural Sciences and Engineering Research Council) comparison of applications received is conducted yearly in rotation by each member to identify redundant applications, which are then withdrawn. This control process is not formally documented and its related roles and responsibilities are not formally defined.

For some funding opportunities, requirements included in the funding opportunity details page are not reviewed or documented in recipient or competition files. Examples include:

• Specific funding opportunity requirements such as progress or final reports;
• The relevance review for strategic awards, which was not found in several competition or recipient files; and
• Acknowledgement of partners in notification letters.

Responsibility: Director, Research Capacity Development

Action: For cases where it has been identified that requirements in the GAG are not always consistently enforced, a working group will be established to look into each case and determine steps for ensuring the requirements are enforced or the necessary modifications to the GAG are proposed.

For cases where common practice goes beyond the requirements of the GAG, a working group will determine if these practices are required. The results will be appropriately documented (updates to GAG, SOPs, etc.).

For cases where documentation specified in the funding opportunity is missing from the application or competition files, the SOPs will be reviewed to ensure the appropriate steps are detailed.

Timeline: A working group will be established in early July 2010. Work to address the above actions will take place over the summer months (July and August) with proposed solutions coming in September/October 2010.

Of 181 files reviewed during the audit, 40 were partner-funded whole or in part. The partners included CIHR institutes and external organizations that used CIHR's peer review process to fund awards in specific strategic areas. The roles of CIHR and the partners varied widely, from matching funds to 100% partner-funded awards. The documents and application processes used also varied, with some utilizing CIHR's own application forms and infrastructure, and others providing their own forms and processes. This diversity seems to have contributed to non-compliance with CIHR-specific requirements related to public announcement of the awards, effective dates of funding, post-award administration, annual eligibility reviews, provision of a T4 or T4A to a directly-paid recipient, payment of fringe benefits to Salary Awards holders, and collection and distribution of activity reports.

Of 40 partnership awards assessed, there were 11 aspects of the GAG where compliance was in question.

Responsibility: Director, Partnerships and Citizen Engagement

Action: Work with Research Capacity Development (RCD) and Targeted Initiatives (TIB) branches to clarify roles and responsibilities of application and post-award administration of partnered awards and ensure that the collaborative agreements (and funding opportunities where appropriate) clearly reflect responsibilities of each party.

Timeline: December 31, 2010

4. There is no process to finalize the status of research allowances for recipients of direct payments after the expiration of the "Authority to Use Funds" period.

There is a process to finalize the status of the research allowances for recipients paid from common accounts at host institutions through either repayment or an assertion by the institutions that all the funds have been spent. However, for payments made directly to the recipients, there is no process to verify whether there is any unspent balance to be repaid. The Awards Financial Officer affirms in the EIS the full expenditure of the research allowance although he does not receive any information on the status of the allowance from the recipient. Though the value of the individual awards is generally low (ranging from $1,000 to $5,000 per recipient per year), it can be material in aggregate. For example, the total value of research allowances for the 2009-2010 fiscal year was over $800,000 for the Fellowship and Doctoral awards programs.

Of 181 files reviewed, 125 held research allowances, of which 63 had passed the "Authority to Use Funds" date. 18 of these 63 were direct payments to recipients in foreign countries, for whom the status of funds was finalized in the EIS without the benefit of related information.

Responsibility: Director, Finance

Action: The verification of unspent balances for research allowances disbursed directly to recipients poses significant challenges.

Most CIHR grants and awards are administered by host institutions, and in such cases, it is much easier to obtain independent third party evidence to validate whether unspent balances remain. There is currently no cost-effective way to verify unspent balances for direct recipients who are not affiliated with a post-secondary institution in Canada. CIHR Finance considered the value of sending information requests to the individual research allowance recipients regarding unspent balances, but concluded that such self-reported information could not be considered reliable.

CIHR Finance will engage the Research Portfolio in discussions to determine the requirement for a separate research allowance and, if re-affirmed, potential strategies and measures to ensure that the risk of unspent funds not being repaid is appropriately controlled.

Timeline: November 30, 2010

5. CIHR's Records Management process needs improvement for tracking and recovering outstanding files in a timely manner.

Of 181 recipient files reviewed, 1 was missing and could not be found; an equivalent file was substituted to complete a full sample. Of 38 institution files reviewed, 2 financial files for two fiscal years could not be found, affecting 16 recipient files.

The inability to locate files impacts management's ability to conduct follow-up action or review. In addition, a missing file raises privacy and confidentiality issues. The difficulty in locating files has been noted in previous audits.