Summary of Consultation Comments

Draft Cost Recovery Policy & Framework : Consultation Document

Introduction

The Canadian Food Inspection Agency's (the Agency) operating environment is evolving and becoming increasingly complex. A number of factors contribute to this growing complexity, including: increasing trade volumes with goods sourced from a greater diversity of markets, changing consumer demands driven by demographic and social trends, higher international standards, and new business and production practices. These changes affect the Agency's ability to keep pace with rising costs, changes in technology, new programming, shifts in demand for services, and evolving government policies.

One step the Agency is taking to respond to these changes is to update its service standards and user fees. Setting clear and transparent service standards with appropriate fees that are in line with the cost of providing these services will support the Agency's ability to respond to these changes.

The Agency undertook a 30-day consultation on a draft Cost Recovery Policy and Framework. Service recipients; provincial, territorial, and international governments; international regulatory organizations; CFIA staff; and Canadians were invited to comment. The purpose of the consultation was to inform stakeholders of the Agency's intention to modernize service standards and user fees, and to initiate dialogue on cost recovery.

This report consolidates and summarizes the policy-related comments received from respondents during the consultation in order to provide stakeholders with an overview of the comments received.

About the Consultation

The consultation involved posting the draft document on the CFIA external website and requesting comments from stakeholders.

Table 1: Respondent Profile¹

Categories of Participants	Distribution
Beef	10%
Food Processing	10%
Grains	20%
Horticulture	20%
Seafood	10%
Special Crops	10%
Other	40%

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¹ Some respondent groups fall into more than one category, as a result the number of participants appears to exceed 100%.

What We've Heard

Overview of Key Messages

Respondents were generally supportive of the draft Cost Recovery Policy and Framework. Clearer and stronger linkages between the draft policy and framework and the Agency's mandate were recommended by stakeholders. Respondents also suggested that elements of the framework be clarified. The CFIA responses to these suggestions are set out below.

The majority of the comments received pertained to implementation issues, such as the need for business impact assessments, the importance of examining the service standards for services being reviewed, and the degree of transparency around the costing components that will support user fees. These comments will inform the implementation portion of the process and will be revisited during consultations on user fee proposals.

Guiding Principles

Comments on the guiding principles related to the level of obligation imposed on the Agency. Some respondents suggested strengthening the principles by using stronger language in order to limit the flexibility of interpretation and resulting variability in application of the principles.

CFIA Response: The guiding principles are intended to represent best practices to guide the development of user fee proposals. It is the Agency's intention to follow these principles for all user fee proposals that are developed. These principles are also consistent with the Treasury Board Policy on Service Standards for External Fees and reflect the tenets of the User Fees Act.

Services Appropriate for Cost Recovery

Some respondents expressed concern that the scope of services considered appropriate for cost recovery is too broad. Concerns were also raised that charging fees for food safety activities would deter participation in food safety programs.

CFIA Response: The guiding principles are intended to represent best practices to guide the development of user fee proposals.  It is the Agency’s intention to follow these principles for all user fee proposals that are developed.  These principles are also consistent with the Treasury Board Policy on Service Standards for External Fees and reflect the tenets of the User Fees Act.

Public vs. Private Benefit

A number of comments were related to the determination of public versus private benefit. Generally, additional information and clarity was requested around how direct benefit will be determined. Specific comments included the suggestion to make the 'private benefit' step in the process a yes/no decision point (refer to paragraph 16 of the draft document).

CFIA Response: The flow chart now contains additional descriptors for each item and clearly sets out that although services may be suitable for cost recovery, if service recipients do not receive direct benefit, then no further steps are required.

Jurisdictional Comparison

The User Fees Act requires a jurisdictional comparison for all user fee proposals. Respondents highlighted the importance of considering not only international jurisdictions for comparison, but also inter-provincial comparisons, where appropriate. In addition, respondents suggested that for each comparison, an appropriate weighting be placed on the findings.

CFIA Response: The User Fee Act prescribes that comparisons be made with other jurisdictions with which a comparison is relevant. As suggested by respondents, the CFIA will endeavour to consider the services offered provincially, where such a comparison is relevant, for completeness.

Third Party Providers

In some cases, the private sector may provide the same services as the Agency or may be used by the Agency to deliver services. Respondents suggested that the policy document address how outsourcing to private enterprise will be encouraged and approved.

CFIA Response: This issue does not pertain directly to the policy on setting user fees. The role of third party providers is considered during the program design stage as decisions are being taken on how to deliver a service. User fees are considered once a the program design stage is complete.

How We Are Responding

Respondents' comments on the draft Cost Recovery Policy and Framework have been considered and are reflected in the final policy and framework document where appropriate. The final document is available on the Agency's website and will be shared with service recipients and others through normal business channels.

We would like to thank everyone who contributed their time to the consultation process and shared their views.