A Review of the Management and Administration of the Canadian Firearms
Program
Respectfully submitted by: Raymond V. Hession January 31, 2003
1.1 Introduction
This report is not about firearms policy. It is about the management and
administration of the Canadian Firearms Program (CFP). In this latter context,
the Minister of Justice asked me to:
- Review the December 2002 report of the Auditor General and recommend
specific actions to be taken;
- Assess the current systems, procedures and controls within the CFP;
- Recommend improvements to the operational efficiency and
cost-effectiveness of the CFP;
- Make recommendations on the CFP management and performance measurement
structure and practices; and
- Recommend other organizational structures and reporting relationships that
would improve the program's efficiency.
1.2 Approach
With the assistance of HLB Decision Economics Inc. and in cooperation with
KPMG, I undertook to assess the administration and management condition of the
CFP through an intensive process of interviews, documentation reviews and risk
analysis. I examined the governance arrangements, quality management, leadership
model, business complexity, budget management, performance management, policy
direction, technology risk and evolution, user involvement, commitment,
planning, knowledge transfer and vested interest attributes of the CFP.
1.3 Overall Findings
The overall findings of this report, like any report whose recommendations
result in financial forecasts and the risks inherent in such forecasts, need a
baseline so that the reader has a proper context within which to consider the
financial merits of those recommendations. Two such baselines apply here.
The first baseline forecast suggesting that the Canadian Firearms Program
(CFP) would cost taxpayers only about two million dollars in excess of the fee
income it would generate was plainly based on flawed assumptions. The technical
requirements and business processes that were developed to implement the
stipulated functions of Bill C-68 (Firearms Act) proved to be dauntingly
complex.
And, the project struck to manage the development failed to prescribe the
business process and technical architecture of the solution based on which it
would be designed in detail, built, tested and rolled out. Without that full
architectural expression, it was not feasible to do a proper estimate of
development costs. Instead, the architecture evolved and, change-by-change, the
project grew more complex. The development costs escalated. And, because the CFP
was a wholly new venture for the department, there was very limited operational
experience on which to draw as a check on the unintended deleterious effects of
policy requirements on efficient program administration. The procurement method
employed by the government allocated little performance risk to the two
contractors who were asked to detail the design and build the solution. They did
what they were told to do and billed accordingly.
The second baseline, Bill C-10A is intended to streamline program
administration through an Alternative Services Delivery (ASD) contract awarded
in 2002. This contract is focused on the future "steady state"
operations of the CFP. It provides support for the technical infrastructure,
transaction processing and data base management. Combined, the ASD contract and
Bill C-10A are a step in the right direction, forming a good foundation for my
recommendations that follow.
The investments arising out of Bill C-68 to the point of completion of the
"load-up" (the creation of the databases) of firearms registrations
are not recoverable. That is, the estimated $400 million invested to create the
massive electronic files of the license and firearms registry are not
recoverable from future fee income. The registry, however, is the resulting
asset that enables the CFP to operate for years to come.
1.4 Capping Financial Expenditures
Nevertheless, the program administration remains unnecessarily complex and
costly. The recommended changes, assuming prompt action, create significant
taxpayer savings over the medium to long term. KPMG reports that program
expenditures were $200,364,000 in fiscal year 2000-2001 and $136,629,000 in
fiscal year 2001-2002. The Minister of Justice recently stated that the
expenditures for the current fiscal year will be somewhat less than the
$113,500,000 previously expected. The expenditure forecast should be
$111,400,000 and $92,700,000 respectively in fiscal years 2003-2004 and
2004-2005 if the changes proposed here are implemented by the key milestone
dates found in Section 8 below.
Savings in the next fiscal year are restrained by the need to:
- Complete the "load up" of firearms registrations "in
hand" and those arising from the 2003 amnesty;
- Invest in the improvements made possible by Bill C-10A;
- Invest in further program simplification initiated in 2004; and
- Ramp up to "steady state" operations.
In the three fiscal years following 2004-2005, the effect of my
recommendations, successfully implemented, is an expected average annual
productivity gain of 8% in each year, without derogating from the government's
public safety objectives. And, program participants should experience
continuously higher levels of service and associated social benefits.
These forecasted rates of savings should form the basis of a management
discipline that caps real spending to achieve at least that degree of
productivity improvement.
1.4.1 Recommendation 1: Continuous
Improvement and the Program Advisory Council
Reporting to the Minister responsible for the CFP, a Program Advisory
Council, with a Chair appointed by order-in-council, made up of senior
representatives of organizations and stakeholders with a legitimate interest in
the continuous improvement of the administration and operations of the CFP,
should be created forthwith:
- To act as "Chief User" for the CFP;
- To provide regular guidance, in the form of advice on program quality, to
the CFP leadership and the Minister;
- To approve the annual CFP Continuous Improvement Plan; and
- To ensure, to the maximum extent practicable, the CFP "steady
state" operations are managed within the real expenditure cap
established for the CFP beginning in 2003-2004.
1.4.2 Recommendation 2: Quality and
Integration Coordination
The CFP should implement a quality and integration coordination process
that:
- Is managed by a senior officer responsible for quality standards and risk
management;
- Encourages all parties involved in program delivery to continuously
improve program efficiency;
- Produces a 2003 Continuous Improvement Plan by May 2003;
- Produces a Continuous Improvement Plan annually thereafter; and
- Ensures that the CFP business process, organization and technology
components are integrated and consistent with CFP work performance and cost
standards that support the real expenditure cap established for the CFP
beginning 2003-2004.
1.4.3 Recommendation 3: Leadership
To allow the management of the Department of Justice to focus on its core
policy role and to enable the CFP to focus on the efficient execution of its
operational mission, consideration should be given to the CFP, as an entity in
its own right, reporting to a Minister responsible for the CFP. And, a Chief
Executive Officer should be appointed to lead the implementation of the changes
and improvements found in Bill C10-A and as recommended here in anticipation of
"steady state" operations.
1.4.4 Recommendation 4: Controller
(Senior Financial Officer)
The position of Controller (Senior Financial Officer) for the CFP should be
established with a core FTE complement of fourteen. Primarily responsible for
the planning, budgeting, recording, reporting and control of financial
resources, and, as a key step in remedying past fiduciary weaknesses, the
Controller would exercise financial functional control over all program
activities. The implementation of an Activity-Based-Costing capability should
also be a priority for the development of standard costs for transactions
involving repeatable procedures and functions.
1.4.5 Recommendation 5: Freeze on
Technical Infrastructure Development
To bring development costs under control, with the exception of normal
application maintenance, no additional software functions should be added to the
existing technical infrastructure. And, with the exception of the development of
the required interfaces to CCRA, DFAIT and RCMP systems to enable the efficient
management of import, export and enforcement activities respectively, no
additions to the scope of the ASD technical infrastructure should be considered
until the 2003 Continuous Improvement Plan is approved.
1.4.6 Recommendation 6: Internet
Access
As a powerful means of improving service and reducing processing costs,
enable the ability of applicants for licensing and registration to apply via the
Internet and actively promote the use of this means of access.
1.4.7 Recommendation 7: Additional
Legislative Changes
Legislative changes that:
- Further reduce program delivery costs;
- Further improve service delivery;
- Reduce program overhead burden; or
- Eliminate ambiguity or uncertainty in the Firearms Act.
are expected to be recommended in the 2003 Continuous Improvement Plan and
should be considered for approval promptly thereafter. All such changes should
become the subject of an intensive program of communication and training for
front-line officers and administrators to ensure adequate comprehension and to
facilitate the performance of their duties.
1.4.8 Recommendation 8: Alternative
Services Delivery (ASD) Contract Terms
With the early passage of Bill C10-A, negotiate arrangements within the terms
of the existing ASD contract that:
- Enable the transfer of cost and service level risk to the contractor in
exchange for sharing in any cost displacement or productivity gains arising
from approved Continuous Improvement Plan initiatives;
- Enable technical infrastructure solutions to be delivered that satisfy the
requirements of Bill C10-A and the CFP 2003 Continuous Improvement Plan,
based on specified outcomes.
- Enable management responsibility for the processing of applications for
licenses, transfers and firearms registrations by the Central Processing
Site to be transferred to the ASD contractor, based on the achievement of
stipulated service levels and cost thresholds at or below 75% of the CFP
business model planned for "steady state" operations.
1.4.9 Recommendation 9: Integrated
Headquarters and Central Processing
The CFP headquarters, currently located in Edmonton, should be integrated
with the Firearms Registry in one place with a target complement of seventy FTE's,
down from a planned eighty-six. The headquarters requires intensive day-to-day
management of the myriad issues and initiatives facing the CFP. The Central
Processing Site in Miramichi and the Quebec Processing Site should be integrated
in one place to achieve the significant savings and economies of scale
available.
1.4.10 Recommendation 10: Federal
Standards for Firearms Officers
Develop and implement work performance and cost standards for the federal
Chief Firearms Officer and Firearms Officers administering the Firearms Act
consistent with the budgetary objective of a minimum 25% reduction from
2002-2003 operating costs for "steady state" operations, expected to
begin in 2004.
1.4.11 Recommendation 11: Provinces
Maintain Federal Standards
To achieve budgetary objectives for "steady state" operations,
renegotiate existing service agreements with those provincial jurisdictions
currently performing the Chief Firearms Officer and Firearms Officer roles in
their respective provinces to implement and maintain federal work performance
and cost standards for these functions.
1.4.12 Recommendation 12: Federal
"Step In" Provisions
To achieve and maintain budgetary objectives for "steady state"
operations, the Federal Government should be enabled to assume the Chief
Firearms Officer and Firearms Officers roles in those provinces that are unable
or unwilling to implement and maintain the federal work performance and cost
standards.
1.4.13 Recommendation 13: Cost
Limitations
To achieve budgetary objectives for "steady state" operations,
provinces wishing to maintain their Chief Firearms and Firearms Officers roles
at levels that exceed the federal work performance and cost standards should do
so at their incremental cost.
1.4.14 Recommendation 14:
Responsibility for Results
Use a Task Authorization (responsibility for results) management discipline
for significant initiatives and related investment and resource allocation
decisions, applying that discipline now to the following priority work:
- Task Authorization One-User acceptance test and certification of the ASD
contractor's solution;
- Task Authorization Two-Data clean-up and data conversion in preparation
for "going live" with the ASD contractor's certified solution;
- Task Authorization Three-Development of the program to promote the use of
Internet access to the CFP for licensing, transfers and registration
transactions; and
- Task Authorization Four-Development of proposed legislative changes beyond
those found in Bill C-10A that further reduce costs, improve service, reduce
overhead and eliminate ambiguity.
And, in any Task Authorization affecting field services, CFP management must
ensure appropriate leadership or representation of the Chief Firearms Officer
function.
1.4.15 Recommendation 15: National
Weapons Enforcement Support Team (NWEST)
The National Weapons Enforcement Support Team (NWEST) should be transferred
to the RCMP forthwith to be managed there in the interest of the improved
integration of its law enforcement mission.
1.4.16 Recommendation 16: Transition
Planning and Communications
Recommendations 1 through 15 create a significant change dynamic for the CFP
staff, stakeholders and users. A comprehensive transition and communications
plan should be developed and implemented following their approval to ensure
that:
- Affected CFP staff, stakeholders, partners and users are made aware of the
changes;
- The expected timing and operational outcomes of the changes are made
known;
- Individuals affected by the changes are informed of their new work
arrangements, where applicable; and
- Individuals requiring adjustment assistance (job training, relocation,
placement, etc.) are notified of their disposition in a timely way.
These recommendations represent an integrated plan of action intended to
optimize the economy of the administration of the CFP and the services it
provides to its participants and users. Their approval should, with diligent and
expeditious implementation, also improve program relevance and acceptance.
2.1 Background
The Department of Justice is responsible for the Canadian Firearms Program
(CFP). The program is organized as a sub-activity within the department. The
1995 Firearms Act requires that all owners and users of firearms must be
licensed by January 1, 2001 and that all firearms must be registered by January
1, 2003. In 2000, a sample survey conducted by GPC estimated that there are 2.46
million owners and users of 7.9 million firearms in Canada.
In December 2002, the Auditor General of Canada, in a report critical of the
department for its inadequate reporting of CFP costs to Parliament, recommended
that it should annually provide, in its departmental performance report to
Parliament, complete, accurate and up-to-date financial and management
information on:
- The full costs to develop, implement and enforce the CFP;
- All revenues collected and refunds made;
- Forecasts of costs and revenues to the point at which the department
expects the CFP to become fully operational, including details on
outsourcing major components of the Canadian Firearms Registration System
and moving certain headquarters functions to Edmonton; and,
- Complete explanations for changes in costs, revenues, and to the overall
program.
On January 8, 2003, the Minister of Justice reaffirmed, without reservation,
his acceptance of the Auditor General's recommendations. At that time, I was
asked to make recommendations on a streamlined and cost-effective licensing and
registration process.
In my review of the Canadian Firearms Program, I was assisted by HLB Decision
Economics Inc., a firm that specializes in risk analysis. And, in the conduct of
my review, I have benefited from the cooperation of KPMG in those subject-matter
areas of mutual interest. My work included:
- A review of the December 2002 report of the Auditor-General and
recommendations on the specific actions to be taken;
- An assessment of the current systems, procedures and controls within the
CFP;
- Recommendations to improve the operational efficiency and
cost-effectiveness of the CFP;
- Recommendations on the CFP management and performance measurement
structure and practices; and,
- Recommendations on other organizational structures and reporting
relationships that would improve program efficiency.
3.1 Scope Limitations
The above terms of reference do not include the review of any matters that,
directly or indirectly, affect the policies of the Government of Canada
respecting the public safety objectives supported by the 1995 Firearms Act.
The Minister of Justice, in his statement on January 8, 2003, had said,
"The Government of Canada believes in an effective firearms control program
that includes licensing and registration." Speaking on behalf of the
Government on the second reading of Bill C-68, Firearms Act, the Minister of
Justice described its three objectives, as follows:
- (Measures) to deal with the criminal misuse of firearms;
- (Penalties) to punish those who would smuggle illegal firearms;
and,
- (Measures overall) to provide a context in which the legitimate use of
firearms can be carried on in a manner consistent with public safety
The Minister also described the universal registration of firearms as a
fundamental strategy, a fundamental support system to allow Canada to achieve
these objectives.
In my recommendations, I believe that these objectives remain fully
supported.
In the conduct of my review, I undertook the following activities:
- Interviewed the Chief Firearms Officers of Ontario and Prince Edward
Island;
- Consulted the Minister's Users Group;
- Interviewed past and current management and staff associated with the CFP;
- Interviewed officials representing the Department of Justice senior
management and officials of the Privy Council Office and the Treasury Board;
- Interviewed senior officials representing the Solicitor-General's
Department;
- Interviewed officials of the Office of the Auditor-General;
- Interviewed officials of CGI, BDP and EDS;
- Interviewed applicants for a Firearms License or Registration;
- Interviewed members of the RCMP;
- Interviewed the National Chief of the Dene Nation;
- Visited the Firearms Registry (Ottawa) and Miramichi Central Processing
Site;
- Reviewed CFP documents and reports and the December 2002 Report of the
Auditor-General of Canada;
- Reviewed (through demonstration and observation) the end-to-end processing
of applications;
- Reviewed the ASD contract documentation;
- Reviewed my findings and recommendations with KPMG;
- With the assistance of HLB Decision Economics Inc., determined the costs
of the options with adequate service levels for operation of the CFP and
conducted a consensus-based risk analysis of the options.
Early in my review, I organized a "Solutions Team" made up of key
managers from the CFP, the ASD contractor, HLB Decision Economics Inc., KPMG,
PWGSC and legal counsel. This approach got at the issues, got options debated
and solutions formulated in a timely manner. I chaired all meetings of the
"Solutions Team" that sought out the least cost workable solutions to
the observations below.
My review revealed the following observations requiring remedial action.
6.1 Governance
6.1.1 The "Chief User"
The CFP benefits from a large number of advocates, for and against firearms
registration, who formally or informally advise the Minister. This advocacy and
advice has historically focused on the legislation, regulations and policy
prescriptions affecting the program. Missing from the scene is an identifiable
"Chief User" representing, in a formal way, the entity that defines
the service delivery model (SDM) and takes responsibility for formally accepting
the solution brought forward to satisfy that definition. The designation of a
"Chief User" is widely acknowledged, in any business process
development of significant scale such as the CFP, as a prerequisite to
successful implementation. In a multi-stakeholder environment like that of the
firearms program, one would expect the "Chief User" function to take
the form of a panel of persons with a legitimate role or interest in the SDM's
functional, performance and operational characteristics "in use".
6.1.2 Quality
Progress has been made in completing the "load-up" of those data
from the licensing of owners of firearms and firearms registration. One can now
foresee the day when the CFP will enter its "steady state" operations.
During "load-up", the challenges are mainly logistical. That is,
hundreds of thousands of owners were challenged to complete complicated license
and firearms registration forms before stipulated deadline dates yielding,
inevitably, very large volumes of data to be processed in a short time.
Perceptions of administrative chaos can (and did) appear in such circumstances.
Risk management demands have been high. In "steady state", the
operational profile changes significantly. CFP operations are stabilized with
predictable volumes and activities. Regardless of the phase of operations, a
proper governance mechanism is a core success factor to any complex SDM. Such a
mechanism should be focused on quality, that is, continuous improvement and risk
management. Continuous improvement ensures that the CFP stays focused on the
needs and expectations of its users. There is currently no formal governance
mechanism to oversee continuous improvement of the operations of the CFP.
6.2 Leadership, Focus and Execution
The management of the CFP and the Department of Justice are committed to the
success of the CFP. However, the CFP operates as a sub-activity within the
Department of Justice. As such, the intermingling of a highly operational
service delivery function (the CFP) with a policy-rich department whose culture
is expected to be circumspect and prudent can be problematic. The department has
a very demanding policy agenda, involving itself in virtually every legislative,
regulatory and program activity of the government. The CFP has, with its
continuing controversies and extraordinary logistical demands, layered
unprecedented burdens on the department's management. And, correspondingly,
the CFP is continuously contending for the resources and management attention it
has needed to sustain its performance against its legislated milestones. The
aggregate effect of these organizational dynamics includes a cumbersome
leadership model, less intense focus on the mission of the CFP and corresponding
inefficiencies in operational execution. Leadership, focus and execution are
further sub-optimized currently because of the multiple headquarters deployments
(Edmonton and Ottawa) and processing sites (Montreal and Miramichi).
6.3 Complexity
From the start of the business process and technological development of the
CFP, EDS and SHL Systemhouse (subsequently acquired by EDS), responding to
requirements defined by the CFP project management, performed a large number of
changes (1997-319 changes; 1998-310; 1999-474; 2000-415; 2001-260; and,
2002-112) leading to a CFP technical solution that had rapidly evolved from
seemingly straightforward to very complex.
In 2002, following a competitive procurement, an Alternative Services
Delivery (ASD) contract was awarded to Team Centra (a consortium of CGI and
BDP). This outsourcing contract will, upon certification, replace the existing
services. In the interests of cost containment and technology evolution, the
strategic focus of the ASD solution is dependent on Commercial-Off-The-Shelf
(COTS) software replacing the custom-built solution. Current indications are
that the complexities of the CFP continue to put the potential economic
advantages of the COTS solution in jeopardy.
6.4 Budget
6.4.1 Financial Functional Control
The Auditor General has exposed weaknesses in the reporting of program costs.
To some degree, these weaknesses arose, in my opinion, from inadequate financial
functional authority delegated to the CFP Senior Financial Officer (SFO). The
SFO had no functional authority over the reporting and cost justification of
spending by "partners", including "opted-in" provinces,
other federal government departments, etc. Moreover, fees and charges rendered
by these "partners" were not justified based on costed activities.
There are no standard costs for specific activities nor is there in existence
today an Activity-Based-Costing capability within the CFP from which to develop,
monitor and contain such costs. I observed evidence of significant differential
costs for the same transaction types depending on the delivery
"partner".
6.4.2 Performance Management
CFP's core business is the licensing and registration of firearms.
Functionally, the processes and systems that deliver this sort of service are
well established. The best such processes and systems include rigorous
performance management. It is not clear where the process ownership
(accountability) and performance management responsibility lie for the CFP SDM.
In terms of service outcomes, the financial and service level performance
hurdles that define success for the CFP are not clear. In their absence,
continuous improvement plans and strategies are problematic.
6.4.3 ASD Contractual Contingency
The ASD contract referenced in section 6.3 above requires that the contractor's
solution be certified. The ASD contractor has indicated to the government that
the scope of work necessary to achieve certification exceeds his budgeted
provisions because of unanticipated requirements. This additional work,
amounting to as much as $15,000,000, is the subject of current discussions with
the contract authority, Public Works and Government Services Canada. The
contractor is also concerned that he may incur costs primarily related to delays
in the passage of Bill C-10A. The outcome of these discussions was uncertain at
the time of my review and the financial effects were unknown.
6.5 Policy Direction
The policy direction for the CFP is clear and unequivocal. The legislative
(Bill C-10A) and financial authorities needed to improve the SDM are essential
and, if delay penalties are to be avoided, urgent.
6.6 Technology Risk
CFP management has limited internal technical know-how at its disposal. Its
ability, for example, to assess the capacity and performance impacts of volume
surges and growth is limited. Nevertheless, most of the capacity planning and
management impacts will be migrated to the ASD contractor, assuming the
successful certification of its solution. A significant concern requiring
focused attention is the data "clean-up" and data conversion activity
that is an important prerequisite to the implementation of the ASD solution.
6.7 Technology Evolution
Technology evolution is the ability to access new versions or generations of
the underlying technology on which the CFP depends in the expectation of
continuous vendor support. It is an area of some uncertainty. Past evidence of
technology evolution difficulties gave rise to the decision in 2001 to pursue
the ASD contract that relies on COTS. The degree to which COTS software appears
to require customization to satisfy the unique functional requirements of the
CFP is problematic at this time. Unless measures are taken to significantly
simplify the CFP administration, there may be little benefit, in terms of
technology evolution, compared to the current custom solution.
6.8 User Involvement
As pointed out in Section 6.1.1, there was no evidence of a formal
"Chief User" found during my review. Thus, there was no formal
"Chief User" involvement in the approval of the functional design and
process documents for the ASD solution nor does there appear to be such
involvement in the acceptance protocol leading to its certification. This
creates uncertainty insofar as the design and acceptance protocols may not
accurately reflect and satisfy user requirements.
6.9 Commitment
In the course of my review, I met a large and diverse group of officials
representing CFP, Department of Justice, other government departments and
suppliers to the CFP, including a number of people no longer involved with the
program. I also met with a number of Canadians who have made direct use of the
CFP as firearms owners. Without exception, I found concerned and cooperative
people.
CFP management and staff, to their credit, appear to remain committed,
notwithstanding the "crisis mode" in which they have found themselves
in recent months. In light of the current and anticipated flood of registrations
over the months ahead, their diligence and dedication is under continuing
pressure.
Team Centra, for its part, is challenged to meet the acceptance and
certification requirements of its contract. The consortium, although
experiencing additional costs associated with the current delay, appears
committed to fulfill its contract obligations.
6.10 Planning
No critical path plan, integrating the key activities, events and milestones
for both the CFP and Team Centra, existed. Without it, it is not possible to
know with confidence when the "steady state", operations of the CFP
would be achieved. Two key milestones, the passage of Bill C-10A and the
certification of the ASD solution were particularly uncertain.
6.11 Knowledge Transfer
The principal knowledge transfer activities are focused on Team Centra that
is garnering the years of know-how developed by EDS in anticipation of the
eventual transfer of technical operations. The transfer criteria and the plan to
ensure effective transfer were unclear.
6.12 Vested Interests
Uncertainty is the enemy of the CFP. No end-to-end integrated plan to achieve
"steady state" operations, no legislative or financial authority to
enable administrative improvements, an ASD contract still requiring
certification, differential costs and service levels between opting-in and
opting-out provinces, provincial and territorial politicians promoting delay,
etc., are all contributing to the uncertainty. Fuelled by the aggressive actions
of the anti-firearms control lobby whose cause is aided by the uncertainty,
these vested interests are frustrating the alignment of all parties to the
achievement of the expected outcomes.
This section describes the proposed new direction for the administration of
the CFP. That direction is premised on the foreseeable exit from the "load
up" phases of the CFP to the "steady state" phase. " Steady
state" is a prolonged period of normalization of operations. After three
years of determined effort, the licensing and registration activities of the CFP
should become somewhat more predictable, measurable and manageable. In these new
circumstances, the CFP is entering an era of significant continuous improvement
potential.
Thus, the new CFP organization, with its new governance and management
processes, will be transformed into a focused entity in its own right,
with a relatively small permanent staff (see Attachment A) reporting directly to
the Minister responsible for the CFP. It will adopt a results-oriented
management discipline akin to the task authorization process found in section
7.0 of the ASD contract. It will operate in a robust ASD environment, expanded
to enable the contractor to accept most or all of the risk of continuous
improvement initiatives and participate in "gain sharing" from
benefits created. The ASD service provider should perform all transaction
processing and revenue accounting functions where tangible economies so
justify.
The core CFP management and staff will be federal public servants performing
investigatory, adjudication, standards setting, financial control,
communications and integration duties.
The SDM, relying on existing infrastructure where feasible, will call for an
adequate number of points of service required for efficiency and acceptable
service levels. Consistent national work performance standards at standard costs
will be applied to the roles of Chief Firearms Officer and Firearms Officer
whether performed by provincial or by federal officials. Where opting-in
provinces wish to maintain these roles, the accommodation should be dependent on
the maintenance of the approved federal work performance and cost standards.
To maximize cost efficiencies and management effectiveness, the recommended
SDM also assumes a single integrated headquarters and a single location for the
processing of license and registration applications. In the interest of cost
effective services, it also contemplates priority emphasis on a web-enabled
(Internet) client interface as the primary access for:
- Licensing and registration transaction origination and approval, and
- CFP program information.
While a more focused and efficient management and service delivery
organization will result from the new direction recommended here, further
legislative and regulatory changes, beyond those contained in Bill C10-A, will
likely be recommended where they:
- Further reduce program delivery costs
- Further improve service levels
- Reduce overhead burden
- Eliminate remaining ambiguity or uncertainty in the Firearms Act
A concerted effort to determine any such changes is expected to be undertaken
soon after decisions on the recommendations in this report are made.
The CFP plan is focused, integrated and deliberate. It must be managed that
same way.
The key milestone assumptions that drive the financial forecasts cited here
are:
- Passage of Bill C-10A by April 1, 2003.
- Clean up and conversion of licensing and registration data by December 31,
2003.
- Transition to the ASD solution ("go live") by January 1, 2004.
- Approval of the 2003 Continuous Improvement Plan by May 31, 2003.
- Approval of any legislation required for implementation of the 2003
Continuous Improvement Plan by March 31, 2004.
- New federal work performance and cost standards approved for
implementation in opting-in and opting-out jurisdictions by September 30,
2003.
- Integration of CFP headquarters by May 31, 2003.
- Integration of Central Processing Sites by December 31, 2003.
- NWEST transferred to the RCMP by April 1, 2003.
The single most significant of these critical activities are those with
legislative and regulatory process dependencies. These represent most of the
schedule risk to the successful execution of this plan and, hence, its financial
outcomes. It's also possible that the delay in the "load up" of the
firearms registry arising out of the 2003 amnesty could, in turn, delay the data
clean up and conversion. These risks will be better understood following the
execution of the Task Authorization on these same subjects found in
Recommendation Fourteen above.
The proposed CFP organization plan (see Attachment A and associated Schedule)
reflects management concepts (flexible, responsive and performance-driven)
normally associated with results-oriented service delivery organizations
involving ASD-based solutions. It is designed to fulfill the CFP mission, that
is, the CFP licenses owners of firearms, registers firearms and authorizes
the possession, transfer and transportation of firearms in accordance with the
provisions of the Firearms Act and its regulations.
The proposed organization includes a key coordination function that ensures
that CFP business processes, organization and technology components are
integrated and consistent with relevant CFP quality and operational standards.
The coordination function will define CFP quality and operational standards in
the areas of business process design, technology and organization. The
coordination function will advise the CFP Chief Executive Officer on the
implications of management decisions on the overall CFP service delivery model.
The coordination function will also work with the ASD contractor to identify and
resolve quality, risk and integration issues.
The proposed organization does not include the National Weapons Enforcement
Support Team (NWEST), since this important service goes beyond the mission of
the CFP. Law enforcement agencies throughout Canada rely on the specialized
support of the NWEST in pursuing weapons investigations. It provides an
essential service to counter the smuggling and trafficking in illegal weapons.
In the course of its support role, NWEST combines information from the Firearms
Registry, the Canadian Police Information Center, the Police Information
Retrieval System and the Automated Criminal Intelligence Information System.
The operational support and the acquisition and analysis of intelligence
related to the movement of contraband are the responsibility of the police. The
movement of illegal firearms in this regard is no exception. NWEST therefore
should be transferred to the RCMP to be managed there in the interest of
improved integration of its law enforcement mission.
This schedule describes the roles and responsibilities for each key
function in the new CFP organization and, for each new function, indicates,
where applicable, the current function that it replaces.
Governance- The Program Advisory Council
Reporting to the Minister responsible for the CFP, the mandate of the Program
Advisory Council is to act as the "Chief User" and to provide guidance
and advice on program quality to the CFP Chief Executive Officer and the
Minister. It will draw its administrative support from the CFP. The Program
Advisory Council's responsibilities include:
- Approval of the CFP Continuous Improvement Plan.
- To ensure, to the maximum extent practicable, the CFP "steady
state" is managed within the real expenditure cap established for the
CFP beginning in 2003-2004.
- On-going review of the performance of the CFP Continuous Improvement Plan.
- Ensuring that the CFP stays focused on the needs and expectations of its
users.
- Validating that current and future commitments made by the CFP are
achievable.
- Providing the CFP Chief Executive Officer with independent advice at arm's
length from CFP operations and administration.
- Approval of acceptance test criteria, associated test plans, entry / exit
criteria, and validation of each new release of the ASD service
deliverables.
- Review of changes to the Continuous Improvement Plan when:
- Scope is significantly changed, increased or decreased; or
- Projected cost is increased by more than a stipulated amount; or
- More than a stipulated period delays progress on any key initiative.
- Providing periodic reports to the Minister responsible for the CFP on the
outcomes from the above activities.
The Continuous Improvement Plan specifies the measures to be taken to
continuously improve the performance (measured in terms of lower costs, improved
service levels and effectiveness attributes, in some combination) of the SDM. In
general, such improvements result from the rigorous application of a performance
management framework to the licensing and registration processes that make up
the SDM. Performance metrics and standards are determined for each relevant
process that, from time to time, may be altered to achieve improved results.
In addition to these ongoing responsibilities, the Program Advisory Council
may, with the approval of the Minister, call for ad-hoc special reviews in
response to external factors that may materially alter the basic premises or
underlying assumptions of the CFP or the ASD contract.
The Program Advisory Council, chaired by an Order-in-Council appointee, will
have balanced representation of experience and responsibility in areas with
legitimate and material affects on the efficiency and effectiveness of CFP
administration. The Program Advisory Council will act to support the CFP's
success. Subject to the approval of individual appointments by the Minister
responsible for the CFP, its possible composition is:
Chair, Order-in-Council Appointee
Assistant Commissioner, National Police Services
Assistant Deputy Minister, Policy-DOJ
Canadian Association of Chiefs of Police
Senior Representative, CCRA
Senior Representative, Solicitor-General
Chief Firearms Officer Representative
Member-at-large (accounting/auditing profession representative)
Member-at-large (representative gun manufacturer/exporter/importer/retailer)
The Program Advisory Council will meet at least six times per year and, in
addition, at the discretion of the Chair who is expected to provide leadership
to the Council. The CFP Chief Executive Officer and the Executive Lead of the
ASD contractor are expected to attend all Council meetings. The Chair, as an
appointee, may be required to provide up to 60 days of service per year.
A written status report will be prepared by the CFP and distributed to all
Council members monthly. The Council will define its own reporting protocols.
Minutes of Council meetings will be distributed to its members and to the
Minister responsible for the CFP.
CFP Chief Executive Officer (assumes leadership of current Policy
& Consultations and ASD Management)
The CFP Chief Executive Officer, reporting to the Minister responsible for
the CFP, is the most senior CFP executive officer.
The Chief Executive Officer will:
- Manage the day-to-day operations to accomplish the CFP's mission.
- Ensure, to the maximum extent practicable, the CFP "steady
state" operations are managed within the real expenditure cap
established for the CFP beginning in 2003-2004.
- Designate the CFP officer(s) responsible for the performance management of
the licensing and registration processes.
- Execute the CFP management processes as outlined herein, including
recommendation of the CFP Continuous Improvement Plan for approval by the
Program Advisory Council.
- Communicate the CFP goals, operational and organizational philosophies,
policies and progress - within the program and to external stakeholders.
- Manage the ASD contract.
- Represent the CFP to all organizations, and in all activities, carrying
the full authority and responsibility of the program.
- Provide direction and guidance necessary to ensure successful
implementation of the CFP in all functional areas, to facilitate the
establishment of proper interfaces, completion of critical assignments
within accepted quality objectives, on schedule and within the allocated
budgets.
- Delegate specific authorities and assign resources to Task Authorizations.
- Ensure service level agreements (where applicable) for Task Authorizations
are developed and approved.
- Approve all Task Authorizations and change orders for both the CFP and the
ASD contract.
- Review updates to the CFP Continuous Improvement Plan for submission to
the Program Advisory Council for approval, advice or guidance, as
appropriate.
- Provide strategic leadership to the CFP.
- Obtain appropriately skilled staff to fulfill the requirements of the CFP
and any Task Authorizations, as required.
- Manage the performance of all CFP personnel.
- Formally accept ASD deliverables.
- Participate in federal government management structures and processes.
- Liaise with the RCMP, Corrections Canada, The National Parole Board, CCRA,
DOJ, PWGSC, TBS, etc., in the normal course.
- Report to Treasury Board Secretariat, as required.
- Submit an annual report to the Minister responsible for the CFP.
Registrar of Firearms (assumes leadership of Field Services and
oversight of the Central Processing Site)
Reporting to the CFP Chief Executive Officer, the Registrar of Firearms
(Registrar) is responsible to establish and maintain the Canadian Firearms
Registry (CFR). The Registrar will maintain records of:
- Every license, registration certificate and authorization that is issued
or revoked.
- Every application for a license, registration certificate or authorization
that is refused.
- Every transfer of a firearm of which the Registrar is informed under the
Firearms Act.
- Every exportation from or importation into Canada of a firearm of which
the Registrar is informed under the Firearms Act.
- Every loss, finding, theft or destruction of a firearm of which the
Registrar is informed under the Firearms Act.
- Firearms acquired or possessed by the following persons and used by them
in the course of their duties or for the purposes of their employment,
namely:
- Peace officers.
- Persons training to become police officers or peace officers.
- Persons employed by the public service of Canada or by the government of
a province or municipality who are designated as public officers.
- Chief Firearms Officers and Firearms Officers.
- Firearms acquired or possessed by individuals on behalf of a police
force or a department of the Government of Canada or of a province.
The Registrar oversees the provision of services to Chief Firearms Officers
and the operations of the Central Processing Site.
Director, Quality and Integration (QI) Coordination
Reporting to the CFP Chief Executive Officer, the QI Director's
responsibilities include:
- The provision of staff support to the CFP Chief Executive Officer and the
Program Advisory Council.
- Management of all Purchase of Service (Contribution) agreements on behalf
of the CFP.
- Ensuring that CFP clients and stakeholders are identified, qualified and
engaged in the identification and analysis of improvement opportunities for
CFP program delivery.
- Developing and maintaining a CFP Continuous Improvement Plan.
- Establishing CFP and Task Authorization quality metrics and reporting
procedures as part of the Continuous Improvement Plan.
- Coordinating periodic CFP quality management assessment reviews sought by
the Program Advisory Council.
- Implementing appropriate control, verification and reporting procedures to
ensure that the CFP quality standards are being met.
- Conducting periodic surveys to identify opportunities for continuous
improvement and to verify the CFP service level expectations are being met.
- Conducting quality training as required.
- Developing, maintaining and tracking a risk management plan that
identifies CFP risks and the means of their mitigation.
- Developing risk-based investigation techniques and models, in cooperation
with the Registrar, in the interest of cost-effectiveness.
- Establishing CFP operational performance metrics to track CFP performance.
- Establishing and maintaining an effective management process wherein Task
Authorization status reporting.
- Ensuring the CFP's business practices and business processes are
consistent with the achievement of the public policy objectives of the
Firearms Act.
- Coordinating new technical releases of the CFP SDM.
- Ensuring appropriate policy and operational linkages and exchange of
information between the CFP and the related federal government departments
and agencies.
- Developing an overall organizational change strategy, as required.
- Supporting any organizational design requirements for each Task
Authorization.
- Ensuring appropriate linkages and exchange of information between the CFP,
the ASD service provider and the rest of the service delivery organization.
- Ensuring that the technology vision and direction is consistent with the
achievement of CFP service level and cost goals.
- Developing and monitoring the CFP technical standards (availability,
reliability, hours of service, etc.).
- Ensuring appropriate linkages and exchange of information between the CFP
and any technology systems of federal, provincial or municipal departments
or agencies.
Task Managers
Task authorizations may be led by managers from either CFP or the ASD service
provider or both, as appropriate. Task Managers will report directly to the ASD
Executive Lead or the CFP Chief Executive Officer or both, as appropriate. Task
Managers will be assigned responsibility and authority for the successful
leadership, direction, and management of an assigned Task Authorization.
The role of the Task Manager will be to:
- Develop Task Authorizations as authorized by the CFP Chief Executive
Officer.
- Communicate clearly the Task Authorization objectives, scope, policies,
procedures, and status to the Task Authorization team.
- Ensure that the deliverables created by the Task Authorization team
provide quality, add value and contribute to the CFP's success.
- Ensure specific responsibilities are clearly identified and that specific
deliverables are met.
- Provide effective management to ensure successful Task Authorization
completion.
- Use acceptable management practices, adhering to the policies and
procedures instituted by the CFP to plan and accomplish work.
- Provide the CFP Chief Executive Officer with timely status reports and
change order requests, as required.
- Resolve day-to-day issues at the Task Authorization level; work with other
Task Managers to anticipate and solve issues, which involve more than one
initiative.
- Provide actual and projected performance information to the CFP Chief
Executive Officer.
- Ensure that all Task Authorization-related activities are documented to
CFP standards.
- Identify and request the necessary resources to support the Task
Authorization.
- Deliver the Task Authorization on time and within budget estimates and
meet all other responsibilities defined in the Task Authorization.
- Ensure that any service level agreement provisions are maintained.
- Collaborate with the QI Director to ensure an integrated approach to
implementation.
Financial Management-CFP Controller (assumes Corporate Management
leadership)
Reporting to the CFP Chief Executive Officer, the CFP Controller is
responsible for the planning, budgeting, recording, control of CFP financial
resources, HR services, internal audit, security, accommodation, administrative
services, material and records management. Primary responsibilities include:
- Maintaining accounts in accordance with Treasury Board policies and
standards.
- Establishing banking facilities for the receipt of CFP revenues in
accordance with Receiver-General instructions.
- Exercising full financial functional control within the CFP and with all
CFP partners whose services are funded by CFP.
- Formal concurrence in the financial implications of all Task
Authorizations.
- Maintaining an activity-based-costing capability as the basis for
establishing CFP fees and for determining standard costs for CFP and for the
purchase of services from CFP partners.
- Providing regular reporting, including variance analyses where applicable,
on the financial performance of the CFP in the context of the real
expenditure cap established for CFP "steady state" operations
beginning in 2003-2004.
- Establishing and maintaining high standards of reporting to Parliament on
the financial and operational performance of the CFP.
- Maintaining effective liaison with Treasury Board Secretariat including
the satisfaction of its reporting requirements.
- Acting as the principal contact for external auditors.
- Managing all relationships involving the services of PWGSC.
- Managing the services contracting process within CFP.
- Ensuring that resources, budgets and schedules are effectively defined,
measured, controlled and analyzed.
- Establishing standards for time reporting, issues management and status
reporting.
- Human resources and internal audit services (provided through an agreement
with another department or agency).
Communications Manager (replaces Communications And Client Services)
Reporting to the CFP Chief Executive Officer, the responsibilities of the
Communications Manager include:
- Ensuring CFP-wide adherence to communication protocols.
- Acting as the principal spokesperson on CFP operations.
- Developing and gaining approval of the CFP communications strategy.
- Ensuring appropriate sponsorship for communications by obtaining agreement
to communication objectives and success factors.
- Determining the respective roles and responsibilities for CFP
communications.
- Executing communications plans, implementing measures for feedback and
responding to contentious issues.
- Reviewing effectiveness of communication initiatives, revising the
communications plan based on assessments.
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