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.

Appendix D: More Information on the "Remarks" Section

1. Treasury Board Submission Check Lists

Although every Treasury Board submission differs, the following are typical questions the Secretariat analyst may ask be addressed in the "Remarks" section.

1.1 General

  • What is the department/agency trying to accomplish? What are the other expected results? Who are the stakeholders?
  • How does this proposal support the department's strategic objectives per the Management, Results, and Reporting Structure, where it fits within the department's Program Activity Architecture?
  • Cite previous policy approvals (e.g. initiative was approved by Cabinet), including the amount approved and when. Does the proposal visibly support the priorities of government? Was it included in the Throne Speech? Was it announced as part of a budget?
  • Indicate the legal authority (authorities) under which the minister can do what is proposed.
  • Indicate how the program focuses on results and value for money. Has it been the subject of a recent audit or evaluation? What were the results? How are the recommendations being taken into account?
  • Indicate how the program is consistent with federal responsibilities. Could it be carried out by other levels of government or the private sector? Is there scope for public sector/private sector partnerships?
  • Indicate how efficiencies have been considered. Indicate why the project/program is affordable. Is reallocation necessary to fund this program/project?
  • Has a performance management framework been established to ensure a focus on results and establish value for money? Who is accountable for the results?
  • Does the program/project still serve the purpose for which it was created? Has the problem being targeted changed since the initial solution was conceived?
  • How does the initiative fit in with other government programs and priorities? Provide details on any linkages, complementarity, or duplication between the sponsoring organization's proposal and related programs in other federal organizations with similar objectives. Clearly substantiate the requirement for this proposal in light of existing related programs/projects.
  • What are the risks of moving ahead or not moving ahead with the proposal? Provide detail on risks to be managed, risk mitigation measures, any residual risks, financial risks, organizational risks, issue history, administrative risks, and specific project risks (if it is a project under Treasury Board policy).
  • Does the proposal involve the provinces, territories, or the public? Are there implications for federal‑provincial relations?
  • Are there regional implications? How is the funding distributed across Canada?
  • Indicate whether there are outstanding previous conditions. Have they been met? If not, why not?
  • Justify cost estimates comprehensively, including all reasonable life‑cycle costs.
  • Is there a communication plan? Was the communication plan discussed in Cabinet? Are there any issues around the proposed communication plan? Does the initiative meet the communication objectives of the federal organization and the government? Have all communication needs been taken into account, including federal identity and official language requirements?
  • Does the submission involve the delivery of an existing or new service? Does it address the elements of good service management practices (e.g. establishing and communicating service standards to clients, measuring performance and client satisfaction, mapping business processes for accountability management, pursuing collaborative arrangements where appropriate) and service transformation (e.g. using/reusing common solutions, exploring one‑stop access and channel management)?
  • If a website is being built, enhanced, or revamped within the Government of Canada environment, does the site comply with the Common Look and Feel for the Internet standards? The Secretariat has developed the Common Look and Feel Self‑Assessment Guide to assist federal organizations in assessing their compliance.
  • Have the Treasury Board policy instruments on the Secretariat website that are applicable to the submission been identified? Are the requirements of those instruments met? If not, have reasons been provided for any deviations? If exemptions must be sought in relation to an instrument, has an explanation been provided?
  • If the submission relates to 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, has the case for an exemption from a Treasury Board policy, directive, or standard been clearly made?

1.2 Program design, delivery, and implementation

  • What is the program design? How will the program or initiative be delivered? How will it be implemented? What are the plans for electronic program delivery?
  • What are the information and management of information requirements and considerations?
  • What will the management and accountability framework look like? What tools will be used to measure performance (e.g. a comprehensive program evaluation or external review)?
  • If the organization's initiative involves other federal organizations or collaborators outside the federal government, how will activities and outcomes be coordinated? Is a memorandum of understanding among federal organizations required? Is a contract among collaborators required? What is the role of the collaborators in delivering key results?
  • What lessons have been learned from similar national or international initiatives?
  • Will funds be provided through the operating budget or transfer payments?
  • If the operating budget is being used, what will the federal organization's role be? Will more full‑time staff (FTEs) be needed? How much funding will go towards operating costs, and for what (e.g. equipment, travel, consultants)? Are the allocations reasonable?
  • If transfer payments are being used, why was a grant chosen over a contribution, or vice versa? What are the terms and conditions? Who is eligible? Has provision been made for remedial action?
  • Have other means (e.g. alternate service delivery) been considered for carrying out the policy decision? Is the proposal put forth the best one?
  • Are a human resources strategy and a human resources plan in place?

1.3 Regional coordination and horizontal management

  • Are there any horizontal linkages (e.g. climate change or Aboriginal framework) or any previous or forthcoming linkages (e.g. previous Treasury Board or Cabinet expectations, previous evaluation findings, or an expected program evaluation)?
  • Indicate whether the program is a horizontal initiative or a component of a horizontal initiative (i.e. the program involves two or more departments or non‑federal entities that are accountable for the outcomes of the program or other programs under the horizontal initiative). If so, is there a performance management framework that specifically addresses governance, accountability, performance, and financial measurement and reporting to ensure effective management of the initiative?
  • Does the program design provide for regional coordination and horizontal linkages across federal organizations? Is there evidence that regional officials have been consulted or otherwise involved in designing the program?
  • Does the program design incorporate adequate resources to both manage and support collaborative undertakings with other federal organizations, other levels of government, or the private sector?

1.4 Costing

  • Has the Guide to Costing of Outputs in the Government of Canada been consulted for the purpose of preparing cost estimates according to the seven‑step approach and for overall guidance?
  • Are there any central agency and/or legislative/policy requirements that may impact the definition of the purpose and/or determination of the cost base? If so, describe them. Have they been taken into consideration? If not, explain why not.
  • Is there evidence that sufficient consultation took place with any other federal organizations that will be impacted by this TB submission?
  • Is there evidence that sufficient consultation took place internally with the providers of corporate services and any other departmental programs that might be impacted by this TB submission?
  • Has this proposal been considered as part of a previous spending restraint exercise?
  • What is the current level of funding for the program or initiative?
  • On what will the additional funds requested be spent?
  • Has the costing analysis recognized and factored in all costs, including corporate and program support costs, as well as EBP costs and the accommodation premium? Are the costing assumptions reasonable? Do they include all reasonable life‑cycle costs?
  • Are the projected costs reasonable? How do they compare with costs of similar national or international projects?
  • Is there a risk of unfunded costs in the future?
  • What is the link between costs and results? Will the federal government receive value for money?
  • How appropriate is the mix of human resources and operating costs?
  • How appropriate is the mix of program delivery and operating costs?
  • Have maintenance and replacement been factored into capital costs?
  • What is the organization's source of funds?
  • Is there a possibility of reallocating existing funds to the initiative?
  • Is access needed to Treasury Board Vote 5? If so, why?

1.5 Project approval

  • Have there been previous approvals (preliminary project approval or access to pre‑definition funding)? What has changed since the previous approvals?
  • What options were considered? Why has the proposed option been chosen?
  • How will the project be delivered and outcomes measured? What milestones have been established? Are there off ramps? How will success be determined?

1.6 Contract

  • Is the proposed contract a result of a competitive process or sole source? If sole source, provide justification. Is the proposed contract with a former public servant?
  • If what is involved is a contract renewal/extension, what are the details of the original/previous contract approvals and why is the contract being renewed or extended?
  • Which trade agreements, if any, apply: World Trade Organization Agreement on Government Procurement (WTO‑AGP); North American Free Trade Agreement (NAFTA); Agreement on Internal Trade (AIT)?

1.7 Grant, contribution, or grant/contribution program

  • What are the objectives of the program? How has the program been designed? Who are the potential recipients?
  • If there is to be a single recipient, demonstrate how the recipient has the capacity to deliver expected results.

2. Cost recovery

  • The User Fees Act, which came into effect on March 31, 2004, is the standing framework providing the implementation and ongoing management requirements for user fee initiatives. Federal organizations are strongly advised to consult the Act and their respective legal advisors when contemplating new user fee initiatives or changes to existing fees.
  • Federal organizations may consult http://www.tbs-sct.gc.ca/fin/euf-fue/fees-eng.asp for general information on the subject of user fees.

3. Human resources

Submissions requesting significant resources for new salaries must provide strategies that deal with the capacity of the federal organization's human resources (HR) groups to fulfill their responsibilities for recruitment, secondment, employment equity, training, staff relations, pay and benefits, security, classification, staffing, and HR planning. In addition to the 20 per cent employee benefit premium and 13 per cent accommodation premium applied to all new salary dollars, federal organizations should allocate resources for goods and services such as equipment and travel. Inadequate assessment of the latter can have a significant impact on program delivery.

The Canada Public Service Agency may need to be consulted on the impacts of certain HR policies (e.g. employment equity or official languages policy) on proposals.

Submissions that propose to create new delivery mechanisms such as separate employers and special operating agencies, to transfer federal functions to other levels of government, or to wind up programs have more HR management issues. Managing the transition processes involved includes transferring, redeploying, relocating, and terminating staff, and acquiring new technologies. All such activities must be carried out in accordance with the appropriate authorities, such as collective agreements and the Work Force Adjustment Directive.

4. Privacy

The Privacy Act and the Treasury Board's Privacy and Data Protection Policy are based on the principle that federal organizations must protect the personal information they control.

The purpose of the Privacy Impact Assessment Policy process is to ensure that federal organizations consider privacy throughout the design and development phases of all initiatives that involve the collection, use, or disclosure of personal information.

Federal organizations seeking preliminary project approval (PPA) from the Treasury Board pursuant to the Project Management Policy must include the results of the Privacy Impact Assessment (PIA) in the body of the submission or project brief, where applicable. Organizations seeking effective project approval (EPA) from the Board must provide a status report in the body of the submission or project brief summarizing the actions taken or to be taken to avoid or mitigate any privacy risks, in accordance with the Privacy Impact Assessment Policy.

For all other proposals, organizations must provide assurances in their submissions that they have either conducted a preliminary or full PIA and identified and dealt appropriately with all privacy issues or, in exceptional circumstances, that they intend to complete a preliminary or full PIA by a date that is deemed reasonable and acceptable to the Secretariat.

Commitments made by organizations to complete PIAs after submissions have been presented will be monitored by the Chief Information Officer Branch of the Secretariat.

5. Security

The Government Security Policy (GSP) holds deputy heads accountable for protecting personnel and safeguarding information and assets under their control. Security (e.g. physical security measures and IT security software and hardware) can be very costly, especially if dealt with retroactively.

Consequently, federal organizations must address security requirements adequately when preparing submissions. Specifically, for all projects, organizations must provide assurances in their submissions that they have conducted a threat and risk assessment and identified and dealt appropriately with all security issues. When the recommended security requirements exceed the GSP's minimum requirements, a threat and risk assessment must support the funding of these additional measures. For inter‑federal organization activities that require submissions for information technology systems, the sponsoring federal organization is responsible for security, in consultation with the other federal organizations involved.

6. Results‑based management and accountability frameworks (RMAF)

The Treasury Board's Policy on Transfer Payments stipulates that submissions for program approval of terms and conditions of grants for a class of recipients or for contributions should include an RMAF and an RBAF that cover evaluation and audit plans respectively. The preparation of the RMAF provides for appropriate measuring and reporting of results as related to the purpose of providing resources through transfers.

Although RMAFs and RBAFs are required only for transfer payment programs, they should be considered useful management tools for significant policies, programs, and initiatives, whether or not they are produced in compliance with an official government requirement. In deciding whether to develop such frameworks, federal organizations should, in consultation with their Secretariat analyst, consider the general importance of the policy, program, or initiative, as well as its perceived level of risk.

Three key types of stakeholders should be involved in the development and implementation of RMAFs: managers, evaluation specialists, and, in the case of RMAFs involving submissions, Secretariat analysts.

Managers hold primary responsibility for the development and implementation of an RMAF. They are also responsible for ensuring that the content of the framework is accurate and that it reflects the design and operation of the policy, program, or initiative.

Evaluation specialists can provide effective support to managers in the development of an RMAF. Working with managers, evaluators can provide important guidance and technical expertise throughout the development and implementation process.

When RMAFs are developed to meet a Treasury Board commitment, Secretariat analysts can advise the sponsoring organization's managers and evaluators of general requirements in their regard before they are approved by the minister and submitted to the Board. It is therefore helpful to consult with the Secretariat analyst during the preparation of an RMAF.

The frameworks should achieve the following goals related to the results‑based management agenda:

  • to set clear roles and responsibilities for the main participants delivering the initiative through a sound governance structure;
  • to ensure clear and logical design that ties resources to expected results through a results‑based logical model that shows a logical sequence of resources, activities, outputs, and key results for the initiative;
  • to allow managers to track progress, measure results, support subsequent evaluation work, and make ongoing improvements through a sound performance measurement strategy;
  • to set out evaluation work expected to be done during the initiative's life cycle; and
  • to ensure adequate reporting of results.

If successfully developed, the framework should serve as:

  • an understanding between the participants about what they aim to achieve, how they plan to work together, and how they will measure and report on results;
  • a tool for better management, learning, and accountability throughout the life cycle of the initiative; and
  • an early indication that the program or initiative is set up logically with a strong commitment to results and a good chance of succeeding.

It is essential that RMAFs remain responsive to changing needs. As the understanding of the RMAF has evolved over time within the context of the requirements for programs with transfer payments under the Policy on Transfer Payments, so have the needs of managers and federal organizations. A more strategic approach to RMAFs provides managers with increased flexibility to develop frameworks that reflect the unique nature of policies, programs, and initiatives, while maintaining accountability for the achievement of results. While Treasury Board ministers or the Secretariat may stipulate some RMAF requirements, it is the responsibility of the federal organization to determine how these requirements are to be presented within the RMAF.

The appropriate strategic approach to an RMAF should be determined in consultation with the Secretariat. In general, consultations should be initiated early in the submission process, before the federal organization undertakes significant work on a framework.

It should be noted that RMAFs, like evaluations, should be considered public documents. Departments are encouraged to share the content of an RMAF with program managers and appropriate stakeholders to promote a shared understanding of the program objectives as well as performance and evaluation expectations.

A number of tools have been developed to provide guidance and facilitate implementation of the Evaluation Policy. Of special note are the following:

7. Risk‑based audit framework (RBAF) and internal audit plan

The Treasury Board's Policy on Transfer Payments stipulates that submissions for program approval of terms and conditions of grants for a class of recipients or for contributions should include an RBAF and an RMAF that cover audit and evaluation plans respectively. The preparation of the RBAF provides for identification of level‑of‑program monitoring and of sources of risk; assessment of the likelihood and impact of those risks, including the underlying assumptions made; and a discussion of risk mitigation actions (including management controls) taken and planned.

Three key types of stakeholders should be involved in the development and implementation of RBAFs: program managers, internal audit services, and, in the case of RBAFs involving submissions, Secretariat analysts.

Program managers hold primary responsibility for the development and implementation of an RBAF. They are also responsible for ongoing financial and operational monitoring and the audit of recipient compliance with terms and conditions of contribution agreements and the reliability of results data. In addition, they are responsible for ensuring that the content of the RBAF is accurate and that it reflects the design and operation of the policy, program, or initiative.

The role of internal audit services is to employ a risk‑based approach in planning and conducting audits that provide assurance concerning the adequacy of integrated risk management practices, management control frameworks, and information used for decision making and reporting in the achievement of overall program objectives.

The content of the RBAF depends on many factors, such as management requests, legal obligations, pre‑established cycles, policy requirements, and the needs and expectations of the central agencies and other collaborators. To ensure that program and audit resources are used where they are most needed, risk must be the driving force in the development of the RBAF, to provide a coherent and disciplined approach to detecting, assessing, and dealing with risk and an effective way of seeing that program and audit resources are used appropriately.

In the case of transfer programs, internal auditors consider the procedures and controls in place to identify and assess risks, and they may include the program in the annual internal audit plan or revise the plan if the program was created or revised after approval of the plan.

The main role of the internal audit function with regard to transfer programs, as with all programs, is to provide deputy heads and the Comptroller General with added assurance, independent from line management, on risk management, control, and governance processes. For further clarification of the role of internal audit services, consult the Policy on Internal Audit.

Under certain circumstances, internal audit services may look at individual contribution agreements. This generally occurs when program management suspects a problem and the program's internal controls, such as financial and operational monitoring, have failed, or when program officers lack the capacity or expertise to handle an issue.

The audit plan in a submission therefore should focus on how and when audit will determine whether a transfer program is being adequately managed. The plan may also indicate when and how individual contribution agreements will be monitored if it is considered necessary to supplement or assess the effectiveness of program monitoring.

Internal audit of the management of contribution agreements does not relieve program managers of their responsibility to effectively monitor agreements for which they are accountable.

A number of tools have been developed in order to provide guidance and facilitate implementation of the Policy on Internal Audit. Of special note are the following:

8. Communication

A communication plan with budget information may also need to be appended to the submission. A plan with dedicated resources to achieve communication goals and objectives is required where a submission:

  • is not the subject of a previous memorandum to Cabinet that is still in force;
  • involves a significant investment of public funds;
  • proposes a major new policy, program, service, or initiative; or
  • concerns matters in which the public has demonstrated or could express sensitivity and concern.

However, a communication plan is not required in a submission concerning the release of advertising funds from the Treasury Board on the basis of policy direction from the Cabinet or a designated Cabinet committee.

Communication plans in submissions take the same form as communication plans in memoranda to Cabinet (MCs). Thus, federal organizations are asked to follow the same template as for communication plans in MCs.
The plan in the submission must contain all nine sections outlined in the MC template: information on the proposed communication objectives, links to government messages and campaigns, public environment analysis, key messages, target audiences and reactions, regional and provincial issues, parliamentary considerations, communications approach and tactics, and budget.

The federal organization's head of communications must be consulted and must review the communication plan in the submission. The input of a communication specialist helps ensure that appropriate measures and adequate resources are recommended in the plan.

Including communication plans in submissions and ensuring that heads of communications review them are requirements of the Communications Policy of the Government of Canada.

8.1 Federal Identity Program

A federal organization may be asked to assure Treasury Board ministers that its proposal is fully compliant with the requirements of the Federal Identity Program (FIP). These issues are addressed in the "Remarks" section of the submission.

Considerations for Treasury Board ministers include ensuring public recognition of the contributions of the Government of Canada and strengthening federal presence and visibility through the consistent identification of government investments, assets, and activities. The following corporate identity issues should be considered and relevant information provided in submissions as appropriate:

9. Sustainable Development

Where appropriate, consideration should be given to the sustainable development implications of initiatives submitted to the Treasury Board.

Sustainable development (SD) 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 factors in an integrated way to support senior decisions makers.

Where appropriate, the submission should indicate the extent to which the proposal positively or negatively affects SD. As indicated below, a number of federal legislative, policy and program initiatives have established specific requirements to advance and support SD. For more information about SD, see Sustainable Development.

9.1 Sustainable development strategies

Pursuant to the requirements of the Auditor General Act, designated departments are required to table commitments to advance sustainable development in updated departmental sustainable development strategies (SDS) in the House every three years.

Where appropriate, a TB Submission should indicate if the department has an SDS and if the subject matter of the TB Submission supports specific commitments in the departmental SDS. The specific SDS commitments being supported should be identified.

9.2 Strategic environmental assessment

In addition, as part of the federal government's commitment to SD, the Cabinet Directive on the Environmental Assessment of Policy, Plan and Program Proposals requires:

[M]inisters expect a strategic environmental assessment of a policy, plan or program proposal to be conducted when the following two conditions are met:

  • the proposal is submitted to an individual [m]inister or Cabinet for approval; and
  • implementation of the proposal may result in important environmental effects, either positive or negative.

A strategic environmental assessment (SEA) is not required in the following circumstances:

Individual federal organizations are responsible for carrying out this directive.

When an SEA is required, the options and recommendations presented to TB ministers should reflect the following analysis:

There is no single best methodology for conducting an SEA. Federal organizations should use appropriate frameworks and techniques and develop approaches suited to their own needs and circumstances.

The Canadian Environmental Assessment Agency's website contains the Cabinet directive and implementation guidelines.

9.3 Green Procurement

The Policy on Green Procurement is a key tool that has been established to advance the greening of government operations. Set within the context of achieving value for money, this policy. It requires the integration of environmental performance considerations into the procurement process, including planning, acquisition, use, and disposal. In this context, value for money includes the consideration of many factors such as cost, performance, availability, quality, and environmental performance. This requires an understanding of environmental aspects and potential impacts and costs associated with the life‑cycle assessment of goods and services being acquired. The requirements of this policy can be complied within the text of the SEA.

The federal government also supports SD through many initiatives to "green" government operations. For more information refer to the site of the Office of Greening Government Operations.

9.4 Project management considerations (at both the PPA and EPA stages)

Where a procurement strategy is required:

9.5 Contracting considerations

Identify measures taken in the acquisition process, such as the inclusion of environmental contractual clauses and/or standards (e.g. take‑back clause, Energy Star standards, use of certified haulers), to contribute to the achievement of the environmental objectives of the Government of Canada.

Identify whether the proposed contract has resulted in an environmentally preferable good or/and service and associated environmental outcome(s) (e.g. reduction of greenhouse gas emissions; recycled content; product disassembly potential; durability; reusability; reconditioned, remanufactured or bio‑based good or service; energy and water efficiency; resource efficiency).

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