The 2014 Guidance for the Preparation of TB Submissions includes a revised submission form, the roles and responsibilities of stakeholders, enhanced guidance on costing, tools for submission writers and new service standards for submissions. Departments and agencies have until April 1, 2014, to fully implement the updated guidance.
However, as communicated in the Guideline on Chief Financial Officer Attestation for Cabinet Submissions, a CFO Attestation letter must be annexed to all submissions that have financial implications, effective January 1, 2014.
III: Writing a Treasury Board Submission
8. Preparing to Write a Submission
Key contacts to be consulted are:
- the organization's corporate services with regard to the context, timing, submission process, and any previous TB submission on a similar subject, and for an update on current Board/Secretariat expectations;
- the Secretariat analyst for advice and direction, through the organization's corporate services;
- the organization's submission coordination unit; and
- translation services.
Relevant documentation to be collected includes:
- A Guide to Preparing Treasury Board Submissions;
- previous TB submissions;
- relevant Treasury Board policies and guidelines;
- the Memorandum to Cabinet and record of decision, if applicable;
- the federal organization's planning documents, such as the Program Activity Architecture (PAA), Report on Plans and Priorities, and Departmental Performance Report, if deemed relevant; and
- relevant legislation.
9. Step-by-step Guide to Writing a Submission
The TB submission template is available on the Publiservice website. Appendix F to this guide provides examples of common TB submissions.
The TB submission comprises the following sections.
This section is for the title of the submission and its main purpose, ideally stated in 30 or fewer words. Words in the title should be consistent with the name of the program involved in the organization's approved PAA.
This section provides the Board ministers with information on the source(s) of the authority to bring the submission forward to the Board. This may include relevant legislation, regulations, policy, and previous Board and/or Cabinet approvals.
In the case of an approval under a previous government, references to previous Treasury Board approvals must be by month and year of the approval rather than decision number. Cabinet papers are not shared from one administration to the next.
If legal authority is not clear, the Secretariat may ask the sponsoring organization whether it has obtained an opinion from its legal services as to the source of the authority for the submission.
The purpose of this section is to provide Treasury Board ministers with a clear sense of the exact authorities the sponsoring organization's minister is seeking from the Treasury Board. It is a key section, as it becomes the organization's authority to proceed once the submission is approved (unless amended by the Treasury Board).
Organizations should state each authority being requested, such as:
- adjustments to funding
- accommodation premium
- temporary access to Treasury Board Vote 5
- permanent access to Treasury Board Vote 5
- approval of a new named grant
- approval of terms and conditions for new class grants, new class contributions, or contributions
- approval of an increase to an existing named grant or to class grants
- repayable contributions
- temporary frozen allotments
- release of temporary frozen allotments
- permanent frozen allotments
- special purpose allotments
- transfers between votes (internal or external)
- increases to vote netted revenue
- adjustments to Program Activity Architecture (PAA)
- approval for project authority
- revolving funds–access to unused authorities
- proposals for delegation of authority to issue and amend specific directives or standards associated with a specific Treasury Board approved policy (applies to Secretariat and Canada Public Service Agency submissions only)
There are examples of the content of proposals throughout this guide under the appropriate subject matter headings.
The Secretariat analyst must be consulted when this section is being drafted.
9.4 Cost and source of funds
The purpose of this section is to provide Treasury Board ministers with a clear sense of the funds involved by year and in total, as well as the source of monies funding the proposal. If there are no cost implications, this should be stated under "Cost." Otherwise, the sponsoring organization should identify all costs by category, by year, and in total.
Appendix B of this document provides required costing templates that must be completed for each financial authority being sought in the submission. These tables set out the financial information the sponsoring organization must provide (as applicable) for new policies, programs, and projects (e.g. salaries, employee benefit plan (EBP) costs, accommodation charges).
Appendix C presents accrual information for capital asset acquisition. Project costing must take into account the total cost of the project, as well as the cost of preliminary project approval (PPA) or effective project approval (EPA). Further assistance may be obtained by consulting internal financial experts or the Secretariat analyst.
Appendix F provides the specific wording for the financial authority being sought in the submission.
The number and name of the vote to which funding will be allocated (as it appears in the most recently tabled Estimates) should be stated under "Chargeable to." If more than one vote is involved, a table should show the relevant breakdown.
The "Source of funds" should indicate where the funds to finance the proposal will come from. The source of funds for the proposal should be determined and approved before a submission is prepared and drafted. The Board will not consider submissions with funding implications unless a source of funds is confirmed.
- Indicate total funding for the project(s)/program(s), the time period involved, the name of the vote to which it will be chargeable, and the source of funds, separately indicating the amount of GST or HST included.
- This section should provide detail not only on any funding request, but also on the "total cost" of the project/program. Note that the total cost may exceed the funding requested through the submission (e.g. the organization could be reallocating funding from its reference levels, or there may be previously approved funding).
- Where the fiscal impact for budget and financial statement purposes (i.e. full accrual) is different from the appropriations impact (i.e. modified cash, partial accrual), also provide a multi-year full accrual-based profile table.
9.5 Official languages
The purpose of this section is to provide the ministers with an analysis of any official languages issues raised by the proposal. The Treasury Board, through the Canada Public Service Agency, is responsible for the development and general coordination of the policies and programs related to the implementation of Parts IV, V, and VI of the Official Languages Act (OLA). Canadian Heritage is responsible for Part VII of the OLA.
Federal organizations making submissions to the Treasury Board must analyze the effects of what they are proposing on both organizational bilingualism (Parts IV, V, and VI of the OLA) and the vitality and development of English and French minority communities in Canada and the full recognition and use of both English and French in Canadian society (Part VII).
For greater certainty, a checklist and an impact analysis guide have been developed (see Appendix E), identifying initiatives which require an impact analysis. This analysis should cover measures, taken or foreseen, to ensure that the program or initiative complies with official languages requirements. Any official languages implications of a proposal must be summarized in the submission.
9.6 Audit and evaluation
The purpose of this section is to provide the ministers with a sense of the conclusions of previous audits and evaluations relevant to the proposal, as well as a brief description of future plans in these areas. If there are no previous or future audits or evaluations at play, the organization should simply state "Not applicable."
This section should identify whether departmental, OAG, or central agency audits directly relevant to the subject matter of the submission and the authorities sought from the Board have previously been conducted. If such work has been done, this section should identify the implications for the submission and outline relevant findings, recommendations, and progress against the department's management action plan.
Reference to future audits should be approved by the department's chief audit executive to ensure that such commitments are consistent with the department's annual audit plan, appropriately considered with respect to risk and materiality, and funded. The purpose, timeframe, and source of funding for this work should be indicated.
Risk-based audit frameworks (RBAFs) required under the Policy on Transfer Payments or otherwise requested by the Secretariat should be annexed to the submission and noted in this section.
This subsection should highlight evaluations relevant to the submission, including findings and recommendations that may have an impact on the authorities being requested of the Board.
Information relating to completed evaluations for programs or policies in the submission should include information on performance to date and corrective measures taken. If the federal organization is requesting renewal or modification of a program and no evaluation or review has been conducted, this should be indicated.
Resources for all future evaluation activities should be included separately in costing tables. Sign-off by the organization's head of evaluation is required to confirm that the resources stated are planned at appropriate levels and times and that they are committed to the organization's evaluation function.
All plans for future evaluations and evaluation-related strategies or frameworks (e.g. results-based management accountability frameworks, or RMAFs, in relation to submissions) should also be indicated. It should be noted that RMAFs, like evaluations, should be considered public documents and can be shared with stakeholders.
9.6.3 Chronological approach
A chronological approach may facilitate the development of this section:
- What audits have been done? What were the key findings?
- What evaluations have been done? What were the key findings?
- What are the expected results of the new/amplified program, how will they be measured, and how will they affect those of the rest of the federal organization and the government?
- What evaluations are planned?
- What audits are planned?
For ease of reference, please number all paragraphs in this section. Appendix D to this guide lists typical questions relevant to the "Remarks" section.
The purpose of this section is to provide the ministers with the storyline and rationale to support the proposal. This is where the main content of the submission is entered. In brief:
- It should be set in a non-technical context, clearly and concisely explaining the issues and justifying each request and each authority required.
- It should focus on the implications of/for the program that support the proposal.
- Use of headings such as Purpose, Background, Program Description, Risks, Governance, Accountability, Coordination, Performance Measurement, and Reporting may be useful. The program description should clearly demonstrate the relevancy of the program in relation to the approved PAA.
Sufficient information should be provided to put the proposal in context for the Treasury Board ministers. This could include a summary of policy approvals, previous Treasury Board approval(s), and results of previous audits or evaluations. Of particular note:
- For new or updated initiatives, describe the program objectives and design, explain the rationale for choosing the design, and describe how the organization will use the resources sought to achieve program objectives.
- An explicit description of what results are expected, how they relate to the organization's strategic outcomes and programs, and how the organization will measure performance in terms of those results (perhaps referencing an RMAF) should be presented.
- Provide details on risks that need to be managed, including financial risks, organizational risks, the issues history, administrative risks, and any specific project risks, as well as the measures to mitigate these risks.
- Provide details on any linkages, complementarity, or duplication with other programs in the sponsoring organization or in other federal organizations with similar objectives. Explain why this proposal should go forward in this light.
9.7.1 Risk analysis
All types of Treasury Board submissions need to be analyzed on the basis of the following general risk categories:
- the complexity of implementing the proposals–this could include the nature and number of policies concerned, any previous Board- or Secretariat-related issues, and the nature of the accountabilities at play, such as horizontal linkages;
- the robustness of the organization's structures, accountabilities, and management regimes to successfully deliver the proposal–this could include the organization's previous experience with similar work, the adequacy of its resources, and linkages to its PAA;
- previous or current issues that will be raised by proceeding with the proposal; and
- the financial risk of proceeding with the proposal–this could include the magnitude and impacts of the costs involved.
Moreover, risk analysis is often undertaken for specific projects. The submission should provide details of specific risks that need to be managed, measures proposed to mitigate those risks, and any residual risks (perhaps by reference to an RBAF or by means of a project's specific risk analysis).
9.7.2 Sustainable development
Where appropriate, consideration should be given to the sustainable development implications of initiatives submitted to the Treasury Board.
Sustainable development is defined as development that meets the needs of the present without compromising the ability of future generations to meet their own needs. In practical terms this means considering economic, social and environmental considerations in an integrated way to support senior decision makers. A number of federal legislative, policy and program initiatives have established requirements to advance and support sustainable development. Refer to Appendix D for further direction.
9.7.3 Gender-based analysis
As a reminder, GBA consists of systematically integrating social and economic differences between the sexes into policy, planning and decision making processes so that intended results are equitable for both sexes. This type of policy lens identifies how public policies differentially affect men and women.
Federal organizations are ultimately responsible for developing policies and programs that are compliant with overall government policies, including GBA. They are expected to include these considerations while performing their initial analysis, likely early in the process, at the MC stage for example. This should ensure that GBA concerns, along with other horizontal policy considerations, are integrated into the initial design of a program or initiative. However, when preparing Treasury Board submissions to seek approval of elements of programs, federal organizations should proceed with a last check to ensure their proposal is GBA compliant, and report their findings in the TB Submission.
More information on GBA could be found on the gender-based analysis site prepared by Status of Women Canada. Status of Women's analysts are also available to answer questions.
The goal of this section is to provide the ministers and the Secretariat with a key contact in the organization in relation to the submission. Provide the name, title, email address, and telephone number of the official in the federal organization who can provide more information. For contracting submissions, the names and contact information of two contact persons should be included–one from the procurement/materiel management area, and one from the sponsoring technical/operational area.
The purpose of this section is to provide the ministers with details of some facet of the submission in support of certain aspects of the proposal. A summary of the contents of appendices should be included in the main body of the submission. The "Remarks" section is appropriate for any explanations.
Appendices could contain the following: costing details (see appendices B and C), a communication plan, a human resources management framework, a risk management framework, a privacy impact assessment report, a memorandum of understanding between two or more federal organizations, the terms and conditions of a contribution or class grant program, the eligibility criteria for a grant, proposed regulations that include a regulatory impact assessment statement, and an RMAF or RBAF.
Appendices attached to TB policy submissions should include a copy of any policy instruments submitted for approval, an implementation plan, and a communication strategy.
All appendices should be identified by their respective reference number/letter on the last page of the submission.
Note: An appendix is the designation used for a document supporting a submission. Anything connected with an appendix should be referred to as an annex. This should also be translated, as it forms part of the official Treasury Board submission.
Signing of Treasury Board submissions
The appropriate minister, as defined in section 2 of the Financial Administration Act (FAA), or another minister authorized by order in council to act on behalf of an absent minister, must approve by signing the cases involving the following:
- submissions seeking additional resources or proposing other changes to appropriations approved by Parliament (e.g. transfers between votes) or authorities approved by the Board;
- submissions proposing recommendations by the Board to the Governor in Council, including those involving orders or the making or amending of regulations;
- submissions to the Board acting as Committee of the Privy Council;
- submissions or amendments proposing changes to strategic outcomes and/or program activities in the Program Activity Architecture;
- federal-provincial agreements involving the expenditure of federal funds;
- submissions seeking authority to establish a new organization under the FAA or to alter significantly the mandate or operations of such an existing organization;
- submissions for authority to enter into contracts that involve goods, services, or construction, as specified in the Contracting Policy;
- approvals of real property transactions exceeding transaction authority limits set in the Board's policy for federal organizations;
- authority to make grants or contributions, or approval of terms and conditions for grant and/or contribution programs;
- proposals that the Board reconsider one of its previous decisions;
- submissions on behalf of Crown corporations;
- submissions requesting exemptions from Board policies;
- submissions from a minister requesting a determination of a disagreement between a minister and an accounting officer on the interpretation or application of a Treasury Board policy, directive, or standard;
- submissions requesting approval of new or revised Treasury Board policies;
- human resource policies or programs, either new or amended;
- submissions dealing with collective agreements;
- submissions seeking project approval;
- compensation for excluded groups, including budgets for the offices of ministers and secretaries of state;
- submissions related to EX-4 or EX-5 organization and classification, as required; and
- submissions requiring amendments to TB policies, standards, or directives (applies to Secretariat and Canada Public Service Agency policy submissions only).
10.2 Delegated signing authorities
For submissions not listed above, ministers may delegate their signing authority to a minister of state, deputy minister, or assistant deputy minister.
Ministers should notify the President of the Treasury Board of the name and title of each authorized minister or officer by means of the delegation of signing authority form. All federal organizations are required to provide the Treasury Board Submission Centre with a delegated authority list and a specimen signature card for each authorized person. Completed forms and cards should be sent to the President of the Treasury Board via the TBSC. If these are not received, the TBSC will refuse to process the submission.
Although it is not necessary to inform the Secretariat of the types and levels of submissions each delegated person is authorized to sign, federal organizations should establish internal controls in this regard for TB submissions.
10.3 Signing of joint and omnibus submissions
Co-signatures are required when more than one minister is involved. The item will be removed from the agenda if any of the co-signatures in a joint submission is not received by the deadline. Note that in exceptional circumstances, an alternate formal approval process could be considered, if approved by the Secretary of the Treasury Board.
10.4 Sending a submission to the Treasury Board of Canada Secretariat
The submission and its attachments are to be sent in both English and French.
Once the minister has signed the final submission, the federal organization should deliver the original and 15 copies (double-sided, 3-hole punched) to the Treasury Board Submission Centre, Treasury Board of Canada Secretariat, 8th Floor, East Tower, 140 O'Connor Street, Ottawa, Ontario K1A 0R5.
Each copy must be secured individually by means of a staple, fold-back clip, or other form of binding.
Only the original submission is to be signed. No other signature or initials should appear on the original or any of the copies.
10.5 Late submissions
Submissions received after the deadline will be scheduled for the following Board meeting. Requests to have the Board consider urgent submissions received after the deadline require an original signed letter from the minister to the President of the Treasury Board giving reasons for the request. The letter must be sent via the Treasury Board Submission Centre.
Urgent submissions will be scheduled for consideration by the Board solely at the discretion of the President.
Organizations submitting such a request should advise the Secretariat analyst as soon as possible.
10.6 Withdrawal of a submission
A minister, deputy minister, or assistant deputy minister may request that a proposed submission be withdrawn by sending a letter to that effect to the President of the Treasury Board, via the Treasury Board Submission Centre. The Secretariat will return all copies of the submission to the organization. The original will be retained by the TBSC.
In the event of a joint submission, the minister, deputy minister, or assistant deputy minister of the lead government organization may request, on behalf of all federal organizations involved, that the submission be withdrawn by sending a letter to the President of the Treasury Board, via the TBSC.
10.7 Change of minister
When new ministers are appointed or ministers are reassigned, they must re-sign submissions, or notify the President in writing if they wish the Board to consider submissions signed by the former minister(s). They must also resubmit the delegation of signing authority form confirming or revising signing authorities.
10.8 Change of government
In the event of a change of government, all copies of submissions are returned to their respective federal organizations with instructions on how to resubmit them. The originals are retained by the Treasury Board Submission Centre.
10.9 Cabinet confidence and security designation
Under the Canada Evidence Act, Treasury Board submissions are considered Cabinet confidences.
The submitting organization is responsible for deciding on the security designation or classification of a submission. However, the minimum security level is Protected B. The designation should be indicated on the front of the submission. Further information may be obtained by consulting the Government Security Policy.
10.10 Treasury Board meetings
When Parliament is in session, the Treasury Board usually meets once a week. During the summer, it may meet once or twice. The Secretariat keeps organizations' corporate services and submission coordination services informed of upcoming Board meetings. The Secretariat sets the agenda for the meetings, at which its officials present the submission(s) to the ministers for decision.
10.11 Treasury Board decisions
The Board has four options when considering a submission: approve, do not approve, approve with condition(s), or defer to another meeting.
Secretariat officials record the Board's decision and, within fifteen calendar days, formally advise the deputy minister of the sponsoring organization of that decision. This is done through a formal record of decision with either a turnaround document or a decision letter.
When the Board approves a submission as submitted and without conditions, the Secretariat sends the sponsoring organization copies of the submission stamped "Approved by the Treasury Board. Certified to be a true copy of a Minute of a Meeting of the Treasury Board on [date of meeting]." This is referred to as a turnaround document. The Secretariat sends a decision letter to the organization sponsoring the submission when the Board approves the submission with one or more changes or conditions, or does not approve the submission.
In the case of joint or omnibus submissions, all organizations whose ministers signed the submission receive a turnaround document or decision letter. The decision letter will reflect only those authorities pertaining to the department and not necessarily all the authorities approved by the Treasury Board.
If the Board defers a submission, Secretariat officials contact the organization to advise it of the submission's status or resolve any outstanding issues. The submission may then be rescheduled.
The Secretariat verbally advises organizations with submissions considered at a Treasury Board meeting of the Board's decision as soon as practicable.
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