Q’s & A’s For Internal Use Only - Proactive Disclosure of Grants and Contributions Over $25,000

1. Why is the disclosure of grant and contribution awards over $25,000 required?
2. Which government departments and agencies are required to report grant and contribution award information?
3. Are there any restrictions or limitations regarding what information we are to report?
4. What if a grant or contribution has a security classification?
5. Other than information whose disclosure would be prohibited by the Access to Information Act or the Privacy Act, are there any other types or categories of transfer payment information that need to be disclosed?
6. Are Payments in lieu of Taxes to be reported?
7. What type of grant and contributions awards are we required to report?
8. What information is to be reported?
9. What is meant by 'Location'?
10. What is meant by 'Date'?
11. Our department provides grants (or contributions) in the form of goods or services. What 'Value' do we use?
12. What is meant by 'Type'?
13. Can you tell us what kind of information is required when completing the 'Purpose' field?
14. The information elements to be reported include an optional 'Comments' field. What is thisfield for?
15. When are we to start reporting?
16. How often are we required to report?
17. What happens if we miss a posting deadline?
18. What medium will be used to publish the information?
19. How are departments and agencies expected to generate the required information?
20. Are we required to report memoranda of understanding with other levels of government and foreign governments?
21. Are we required to report the payments made as relate to a grant or contribution?
22. What about amounts repaid and credited to the Consolidated Revenue Fund?
23. For multi-year grants and contributions, we normally enter the total value for all years into our financial and information systems. What amount should we report?
24. What if we need to correct data reported in an earlier reporting period?
25. What if we are unable to report a grant and contribution in the period in which it was awarded because we don't have all the information
26. Does the $25,000 threshold include administration expenses where applicable?
27. Do we report grants and contributions that are subsequently redistributed or reallocated by a recipient?
28. Our department's grant and contribution programs are administered on our behalf by another department or agency and who provides awards to recipients. We do so by way of a transfer of funds via interdepartmental settlement. Do we report the grant or contribution or is the other department or agency responsible for posting same?/a>
29. Our Department administers a G&C program on behalf of another Department. Are we responsible for reporting?
30. Our Department provides a contribution to a private sector NGO who, in turn, uses these funds – together with other sources of funds - to provide financial assistance to a large number of Canadians through one or more of its programs. Is the NGO subject to these Proactive Disclosure requirements?
31. Do we report grants and contributions awarded to persons who are not incorporated?
32. Is it expected that the $25,000 threshold will be changed at some point in time?
33. What about systems? Is there any movement towards a Government of Canada systems solution?
34. I heard that we would need to post a Reference Number for each award being posted.
35. We currently disclose G&C information on our Web site. Some of the information we disclose differs in nature and frequency to what is required in this regime. Can we maintain our current approach to satisfy PD requirements?
36. The recipients of our awards include numbered companies. Must we identify the investors behind them or is reference to the numbered company sufficient
37. Our Department doesn't provide grants or contributions. How does this initiative affect our Department if at all?
38. I thought G&C award information was to be assembled and reported by name of Program. Is this still the case?
39. In some instances and in accordance with authorities granted for our programs, our department is able to reallocate existing resources whereby the amount of an original award is subsequently increased later on during the fiscal year. Is the disclosure of the initial award sufficient or must we also disclose the subsequent increase?

1. Why is the disclosure of grant and contribution awards over $25,000 required?
   
   The government continues to carry out new initiatives with a view to promoting greater transparency and accountability across the Government of Canada.
   
   The first initiative was announced on December 12, 2003, when the government released the Guide for Ministers and Ministers of State, and the Guidelines for Ministers' Offices, which stipulate that all travel and hospitality expenses for Ministers, Ministers of State, Parliamentary Secretaries, and their exempt staff would be provided on department and agency web sites. Travel & Hospitality information has been available on Government of Canada websites since March 31, 2004. Since that time, proactive disclosure has been extended to include information related to contracts as well as position reclassifications within government.
   
   The reporting of grant and contribution awards over $25,000 represents the Government of Canada's latest proactive disclosure initiative.
   
   
2. Which government departments and agencies are required to report grant and contribution award information?
   
   Departments and agencies listed on Schedules I, I.1, and II of the Financial Administration Act http://laws.justice.gc.ca/en/F-11/59111.html#rid-59281 are required to report grant and contribution awards.
   
   
3. Are there any restrictions or limitations regarding what information we are to report?
   
   As is the case regarding all Proactive Disclosure initiatives, the provisions of the Access to Information Act and the Privacy Act must be respected.
   
   Accordingly, any information whose disclosure would be prohibited by either one of these 2 Acts is not to be disclosed.
   
   To this end, departments and agencies should first consult with their in-house ATIP Coordinators and/or Legal Services to ensure what information can be disclosed.
   
   
4. What if a grant or contribution has a security classification?
   
   Where disclosure of grant and contribution information would compromise national security, public safety, or government confidences, departments and agencies should consult with their ATIP Coordinators for advice on invoking appropriate exemptions under the Access to Information Act and the Privacy Act.
   
   
5. Other than information whose disclosure would be prohibited by the Access to Information Act or the Privacy Act, are there any other types or categories of transfer payment information that need to be disclosed?
   
   The following transfer payments are not to be reported;
   
   
   1. Transfer payments to Provinces and Territories; and
   2. Statutory transfer payments
      (e.g.: benefits under the Employment Insurance Act).
      
      
6. Are Payments in lieu of Taxes to be reported?
   
   No.
   
   
7. What type of grant and contributions awards are we required to report?
   
   Except for those captured under points 3 through 6 above, all grant and contribution awards greater than $25,000 are to be reported.
   
   
8. What information is to be reported?
   
   The following information elements are to be provided for each grant or contribution award being reported.
   
   
   • Name of Recipient;
   • Location;
   • Date;
   • Value;
   • Type;
   • Purpose; and
   • Comments (if any)
     
     
9. What is meant by 'Location'?
   
   The municipality, Province or Territory, and Country of the Recipient's residence, place of business or company headquarters as applicable.
   
   
10. What is meant by 'Date'?
    
    Typically the date at which the awarding of a grant or contribution has been officially authorized and, by extension, results in a commitment in favour of a recipient.
    
    
11. Our department provides grants (or contributions) in the form of goods or services. What 'Value' do we use?
    
    The fair market value of the good or service, at the time of its award, should be used.
    
    
12. What is meant by 'Type'?
    
    The type of instrument used (i.e.: grant or contribution)
    
    
13. Can you tell us what kind of information is required when completing the 'Purpose' field?
    
    It is expected that departments and agencies will endeavour to post entries that are as descriptive as possible as to the purpose of the grant or contribution being awarded.
    
    
14. The information elements to be reported include an optional 'Comments' field. What is this field for?
    
    It is expected that departments and agencies will only use the 'Comments' field to provide additional contextual information typically as relate to exceptional circumstances. This being said, the 5 following circumstances would require an entry at this information field:
    
    
    1. Notation that recipient reallocates or otherwise redistributes a grant or contribution award to third-party beneficiaries;
    2. Advisory where two or more departments or agencies are involved in the funding of and/or the awarding of a grant or contribution;
    3. Material restatement of a previously-reported grant or contribution (together with appropriate cross-referencing);
    4. Belated reporting of a grant or contribution awarded; and
    5. Awards provided and spanning more than one fiscal year
       
       
15. When are we to start reporting?
    
    The first report is to be posted on department and agency websites by May 31, 2006. This first posting will cover the grants and contributions awarded in the last quarter of fiscal year 2005-2006 (i.e.: January 01, 2006 through March 31, 2006).
    
    
16. How often are we required to report?
    
    Departments and agencies will be required to report on a quarterly basis, corresponding to the government fiscal year quarters. Information must be posted within sixty (60) days following the end of the quarter.
    
    
17. What happens if we miss a posting deadline?
    
    The awards are to be posted and included with the postings for the following quarter together with an appropriate notation to this effect in the 'Comments' field (see 14 d) above).
    
    
18. What medium will be used to publish the information?
    
    Departments and agencies are to report the information on their own websites and to include a hypertext link to the Treasury Board Secretariat website, as was done for Travel & Hospitality.
    
    
19. How are departments and agencies expected to generate the required information?
    
    The information is to be generated from the department's or agency's own internal financial and information systems.
    
    
20. Are we required to report memoranda of understanding with other levels of government and foreign governments?
    
    MOUs are not to be reported.
    
    
21. Are we required to report the payments made as relate to a grant or contribution?
    
    No. Only the amount awarded needs to be reported.
    
    
22. What about amounts repaid and credited to the Consolidated Revenue Fund?
    
    Only the initial award needs to be reported.
    
    
23. For multi-year grants and contributions, we normally enter the total value for all years into our financial and information systems. What amount should we report?
    
    Departments and agencies are required to report grant and contribution information on the basis of the amount awarded. Accordingly, in those cases where an award in a given fiscal year represents an amount applicable over more than one fiscal year, the total amount so awarded needs to be reported. However, in such instances, a notation to this effect should also be posted in the 'Comments' information field as outlined at 14 e) above.
    
    
24. What if we need to correct data reported in an earlier reporting period?
    
    Information posted for one reporting period should be modified in a subsequent posting but only where a correction needs to be made in the information originally reported. Any modified information must be clearly indicated as such in the 'comments' field together with appropriate cross-referencing to the initial posting.
    
    
25. What if we are unable to report a grant and contribution in the period in which it was awarded because we don't have all the information?
    
    A grant and contribution not posted for the reporting period in which it was awarded is to be posted in the subsequent reporting period. As is the case with late postings (see 17 above), a notation to this effect must be provided in the 'Comments' field.
    
    
26. Does the $25,000 threshold include administration expenses where applicable?
    
    Yes, the $25,000 threshold includes all eligible administration expenses incurred by the recipient.
    
    
27. Do we report grants and contributions that are subsequently redistributed or reallocated by a recipient?
    
    Only the amount of the award provided to the initial recipient needs to be reported. However, a notation to the effect that the recipient subsequently redistributes or otherwise reallocates the award should be posted in the 'Comments' information field. (see 14 a) above).
    
    
28. Our department's grant and contribution programs are administered on our behalf by another department or agency and who provides awards to recipients. We do so by way of a transfer of funds via interdepartmental settlement. Do we report the grant or contribution or is the other department or agency responsible for posting same?
    
    The department or agency awarding the grant or contribution to the recipient and typically signing a funding agreement on your behalf is responsible for posting.
    
    This being said, your department's Proactive Disclosure site must include a notation to this effect clearly identifying the administrating department or agency.
    
    
29. Our Department administers a G&C program on behalf of another Department. Are we responsible for reporting?
    
    Yes. And as is the case in question 28, your department's Proactive Disclosure site must clearly identify by way of a notation in the 'Comments' field, each such award so administered on behalf of the other Department.
    
    
30. Our Department provides a contribution to a private sector NGO who, in turn, uses these funds – together with other sources of funds - to provide financial assistance to a large number of Canadians through one or more of its programs. Is the NGO subject to these Proactive Disclosure requirements?
    
    As is the case at point 27 above, departments or agencies are responsible for posting awards provided to their recipients – including NGOs. The financial assistance provided by NGOs falls outside the realm of this particular Proactive Disclosure initiative. This being said, a notation to the effect that the recipient distributes the funds to third parties should be posted at the 'Comments' field. (see 14 a) above).
    
    
31. Do we report grants and contributions awarded to persons who are not incorporated?
    
    Yes, departments and agencies are required to report such grant and contribution awards.
    
    
32. Is it expected that the $25,000 threshold will be changed at some point in time?
    
    Yes. It is expected that the threshold will eventually be changed to $10,000. However, before doing so, TBS officials will continue to consult departments and agencies regarding the capacity of their information systems. Only once they are considered as sufficiently robust to undertake and deliver this information will a decision to this effect be made.
    
    
33. What about systems? Is there any movement towards a Government of Canada systems solution?
    
    TBS officials are currently exploring the feasibility of such an option. This is being done in a collaborative and collegial fashion by way of discussions with key Grant and Contribution departments and agencies.
    
    
34. I heard that we would need to post a Reference Number for each award being posted.
    
    No. The posting of a reference number is not required. However, departments and agencies must have in place such award-specific reference numbers for audit purposes.
    
    
35. We currently disclose G&C information on our Web site. Some of the information we disclose differs in nature and frequency to what is required in this regime. Can we maintain our current approach to satisfy PD requirements?
    
    No. While departments are free to provide any additional or complementary information regarding their G&C programs as they see fit, they must nonetheless adhere to and apply the Proactive Disclosure requirements outlined in this regime.
    
    
36. The recipients of our awards include numbered companies. Must we identify the investors behind them or is reference to the numbered company sufficient
    
    Disclosure of the Recipient is sufficient.
    
    
37. Our Department doesn't provide grants or contributions. How does this initiative affect our Department if at all?
    
    Departments' Proactive Disclosure sites need to address each initiative, now including grant and contribution awards. Departments that do not provide any such awards must nonetheless state as much on their G&C PD site. A brief notation to this effect would be sufficient.
    
    
38. I thought G&C award information was to be assembled and reported by name of Program. Is this still the case?
    
    As a result of consultations with departments and agencies, it has been decided to do away with this requirement. The focus will be on recipients of grant and contribution awards.
    
    
39. In some instances and in accordance with authorities granted for our programs, our department is able to reallocate existing resources whereby the amount of an original award is subsequently increased later on during the fiscal year. Is the disclosure of the initial award sufficient or must we also disclose the subsequent increase?
    
    This may be a requirement at some later date. For the time being only the initial award should be disclosed.