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Archived - Audit of Memorandum of Understanding Between Agriculture and Agri-food Canada and Canadian Food Inspection Agency:
Growing Forward 2 Assurance Systems Stream Technical Expertise Initiatives

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Table of Contents

1.0 Executive Summary

Background

AAFC and CFIA entered into a Memorandum of Understanding (MOU) which sets out the framework to facilitate the cooperation between AAFC and CFIA for delivery of the Growing Forward 2 (GF2) Assurance Systems Stream Technical Expertise Initiatives. The MOU serves as the basis for the transfer of AAFC funding to CFIA, and sets out the provisions of the participants' cooperation for CFIA, in collaboration with AAFC, to deliver the Technical Expertise Initiatives. The MOU covers the period from April 1, 2013 to March 31, 2018 with a total of $12.5 million in funding over this period. The MOU includes the requirement for CFIA to ensure an audit of compliance with the MOU terms and conditions is conducted for the 2015-16 fiscal year.

Audit Objective and Scope

The objective of the audit was to provide assurance that the Canadian Food Inspection Agency (CFIA) is in compliance with the GF2 Assurance Systems Stream Technical Expertise Initiatives MOU between Agriculture and Agri-food Canada (AAFC) and CFIA. The scope of the audit covered only the 2015-16 fiscal year.

Key Audit Findings

Controls were in place to ensure that amounts reported for non-salary expenditures, employee benefit plans, corporate overhead and accommodations were incurred for the intended purpose of Technical Expertise initiatives and in accordance with Central Agency policies and directives and established Agency practices.

However, the audit was not able to conclude on the reasonableness of reported salary expenditure amounts being spent on Technical Expertise initiatives, as the Agency does not have a time recording system and instead records salaries based on approved planned time estimates.

The audit also found that the MOU was deficient in addressing requirements for CFIA to enable budget transfers between cost categories, and to claim accommodation costs.

Subsequent amendments to the MOU were approved to enable the budget transfers for the Traceability and Biosecurity initiatives, but not the Food Safety Recognition Program (FSRP) initiative. There were variances between budgeted and actual costs for the cost categories for all initiatives in the 2015-16 fiscal year.

Accommodation costs are incurred by CFIA and there is TB guidance as well as precedents permitting their eligibility to be claimed.

Other audit findings included:

Conclusion

Overall, we found that administrative and financial controls supported compliance with Treasury Board and CFIA policies and directives, spending of funds for the intended purpose, and timely and accurate performance reporting. An exception was noted where the audit was unable to conclude on the reasonableness of reported salary expenditure amounts being spent on Technical Expertise initiatives. The audit identified two areas that should be addressed in the existing MOU, as well as future MOUs.

2.0 Background

AAFC and CFIA entered into an MOU which sets out the framework to facilitate the cooperation between AAFC and CFIA for delivery of the GF2 Assurance Systems Stream Technical Expertise Initiatives. The MOU serves as the basis for the transfer of AAFC funding to CFIA, and sets out the provisions of the participants' cooperation for CFIA, in collaboration with AAFC, to deliver the Technical Expertise Initiatives.

GF2 is a five-year (2013-2018) policy framework for Canada's agricultural and agri-food sector with a $3 billion dollar investment by federal, provincial and territorial governments. AAFC administers three broad federal programs under GF2: AgriInnovation, AgriCompetitiveness, and AgriMarketing. The Assurance Systems Stream is a component of the AgriMarketing Program that supports the development of Canadian national assurance systems and standards. The Assurance Systems Stream includes the Technical Expertise Initiatives, which is the focus of this audit. The Technical Expertise Initiatives consist of:

  1. The FSRP Initiative, led by CFIA, which is providing government recognition of on-farm and post-farm food safety systems developed by national (or equivalent) industry organizations. CFIA is continuing to deliver this program and provide scientific and technical advice to support Hazard Analysis Critical Control Points and Hazard Analysis Critical Control Points-based food safety system development.
  2. National Biosecurity Standards Development Initiative, led by CFIA, which focuses on developing nationally consistent plant and animal farm-level biosecurity standards, as well as national service sector biosecurity standards. The national standards are being developed in conjunction with industry, national commodity organizations, provinces, and academia. Once the biosecurity standards are approved by CFIA, they will become the national biosecurity standard for that particular commodity for farm-level or service sector.
  3. Traceability Management Office Regulatory Infrastructure Initiative Office is developing the policy and regulatory infrastructure to put traceability authorities, agreements, protocols, and other elements in place in support of the national livestock traceability system.

The MOU covers the period April 1, 2013 to March 31, 2018 with a total of $12.5 million in funding over this period. Subsequent to the MOU, seven amendments were approved up to the end of the 2015-16 fiscal year, including one approved during the 2015-16 fiscal year. The MOU, with the subsequent amendments, included the following budget:

Total $ for Five Years (2013/14 to 2017/18)
Initiative Salary Employee Benefit Plans Non-Salary Corporate Overhead Total
Food Safety Recognition Program 3,050,055 610,010 970,725 369,210 5,000,000
National Biosecurity Standards Development 1,983,194 396,640 2,352,475 267,691 5,000,000
Traceability Management Office Regulatory Infrastructure 1,282,451 256,489 792,341 168,719 2,500,000
Total 6,315,700 1,263,139 4,115,541 805,620 12,500,000
Total $ for 2015/16 Only
Initiative Salary Employee Benefit Plans Non-Salary Corporate Overhead Total
Food Safety Recognition Program 610,011 122,002 194,145 73,842 1,000,000
National Biosecurity Standards Development 380,819 76,164 490,917 52,100 1,000,000
Traceability Management Office Regulatory Infrastructure 243,111 48,622 174,664 33,603 500,000
Total 1,233,941 246,788 859,726 159,545 2,500,000

The MOU sets out the purpose, AAFC and CFIA commitments, financial arrangements and governance structures for the management and funding of the three components of the Assurance Systems Stream Technical Expertise Initiatives. CFIA's commitment includes carrying out activities as set out in the MOU's Work Plans; providing AAFC with project, progress and performance reports; expending funds transferred by AAFC to CFIA in accordance with the Total Budget by Fiscal Year; and ensuring financial controls over the allocation and usage of funds related to the initiatives are established and implemented in accordance with applicable Government of Canada policies and directives.

The MOU identifies shared responsibility between AAFC and CFIA for overall administration of the MOU and for delivery of each of the three Technical Expertise Initiatives.

It was confirmed by AAFC and CFIA that the scope of this audit would only cover the 2015-16 fiscal year as per Clause 9.1.2 of the MOU. This MOU clause includes the requirement for CFIA to ensure an audit of compliance with the MOU terms and conditions is conducted for the 2015-16 fiscal year in accordance with Generally Accepted Auditing Standards (GAAS).

2.1 Significance

This audit fulfills the obligation provided for in Clause 9.1.2 of the MOU, which includes the requirement for CFIA to ensure an audit of compliance with the MOU terms and conditions is conducted for the 2015-16 fiscal year in accordance with GAAS.

2.2 Objective

The objective of the audit was to provide assurance that CFIA is in compliance with the GF2 Assurance Systems Stream Technical Expertise Initiatives MOU between AAFC and CFIA.

2.3 Scope

The scope of the audit focussed on processes and controls in place to support compliance to the MOU, including:

The scope of this audit did not assess actual performance or delivery against approved work plans, and was limited to assessing performance reporting processes as stated above.

The audit covered the 2015-2016 fiscal year, and was carried out between June, 2016 and August, 2016.

2.4 Approach

The audit was conducted by Spearhead Management Canada Ltd. (SMCL) on behalf of CFIA. The SMCL audit team conducted the audit in accordance with GAAS and CFIA Internal Audit policies, processes and practices. The conduct of the audit included the following approaches:

2.5 Statement of Conformance

This audit was performed in conformance to GAAS and Internal Auditing Standards for the Government of Canada, as supported by the results of the CFIA's internal audit quality assurance and improvement program. Sufficient and appropriate auditing procedures were performed and evidence gathered in accordance with GAAS and the Institute of Internal Auditor's International Standards for the Professional Practice of Internal Auditing and to provide a high level of assurance over the findings and conclusion in this report. The findings and conclusions expressed in this report are based on conditions as they existed at the time of the audit, and apply only to the entity examined.

3.0 Findings and Recommendations

3.1 MOU Management and Administrative Controls

Oversight roles and responsibility for MOU administration, management and delivery were clearly defined in the MOU and were respected.

Clauses 6.1 and 6.2 of the MOU identify shared responsibility between AAFC and CFIA for oversight over administration and management of the MOU and shared responsibility for delivery of each of the three Technical Expertise initiatives.

Within CFIA, responsibility for overall MOU administration and management rests with the Executive Director (ED), Strategic Policy and International Affairs Directorate, Policy and Programs Branch (PPB). CFIA responsibility for the delivery of each initiative is delegated as follows:

We found that CFIA ED oversight roles and responsibilities defined in the MOU for the management, administration and delivery of the initiatives were respected.

Specific individual roles and tasks for AAFC and CFIA related to MOU administration and management were not delineated in the MOU, resulting in shared responsibilities not being consistently carried out between initiatives.

The MOU identified a number of financial and performance related activities with shared responsibility between AAFC and CFIA. More specifically, Clause 6.3 of the MOU states that "the participants" (i.e., both CFIA and AAFC) are responsible for: approving work plans, budgets and performance reports; and, reviewing progress on activities and outputs, cash flow forecasts and expenditures. Clause 8.2 of the MOU includes the requirement for CFIA to report progress and performance information as well as total actual expenditures for each initiative in the annual performance report to AAFC.

We reviewed the MOU and subsequent amendments approved by AAFC and CFIA, and found that they included work plans and total budgets by cost category for each initiative for each fiscal year. Progress and performance information, as well as total actual expenditures, for each initiative were reported to AAFC in the year end performance report for the 2015-16 fiscal year, in accordance with MOU Clause 8.2.

From our interviews and document review, we found that in-year development and monitoring of detailed budgets, commitments and financial / cash flow forecasts for the initiatives were conducted by CFIA, with varying engagement by CFIA with AAFC counterparts. We also found that during the year, initiative progress was generally reviewed by AAFC and CFIA on an informal basis, with the exception of a monthly system recognition report sent to AAFC by the FSRP initiative.

The above practices can be attributed to the lack of clear delineation in the MOU of the individual roles and tasks of each organization in carrying out the financial and performance related activities where there is shared responsibility. The clear delineation of individual roles and tasks would better support relations between AAFC and CFIA and reduce any confusion about individual roles and tasks. As noted in Section 3.3 of this report, the audit did not identify any issues with financial and performance related activities which were being carried out by CFIA, with the exception of costs being transferred between cost categories for one initiative where explicit authority to do so had not been granted.

3.2 Financial Controls

Clause 4.1.5 of the MOU includes the requirement for financial controls over the allocation and usage of funds related to the Technical Expertise Initiatives to comply with applicable Government of Canada policies and directives. Applicable policies and directives include: Financial Administration Act; TB and Agency Contracting Policy; TB and Agency Directives on Travel, Hospitality, Events and Conferences; TB and Agency Directives of Expenditure Initiation and Commitment Control; TB and Agency Directives on Delegations of Financial Authorities; TB Directive on Account Verification; and, Agency Financial Coding Manual.

The following amounts were expended by the Agency in total for the Technical Expertise Initiatives for the 2015-16 fiscal year:
Cost Category Total
Salaries $ 1,478,382
Employee Benefit Plans $ 295,676
Non-salaries $ 475,362
Corporate Overhead $ 152,796
Accommodations $ 192,190Table Note 1
Total Eligible Amount $ 2,594,406
Total Maximum Funded Amount $ 2,500,000

Table Note

Table Note 1

Note that the total calculated amount of $192,190 (13% of salaries) is higher than the amount reported of $97,784 which was the maximum amount that could be claimed to stay within the total funded amount of $2,500,000 for the 2015-16 fiscal year.

Return to table note 1 referrer

Employee Benefit Plans, Corporate Overhead and Accommodations

Amounts claimed and reported for employee benefit plans and corporate overhead were consistent with the costing methodology at the time of MOU development.

Amounts claimed and reported for Employee Benefit Plans and Corporate Overhead represented calculations in accordance with TB or Agency costing guidance, and with practices and calculations used at the time that the MOU and related funding and costing were developed.

We reviewed Agency calculations for the above reported expenditures and related TB and Agency costing guidance and found that the amounts recorded were accurately calculated and were in accordance with guidance.

Amounts claimed and reported for accommodation costs represent legitimate costs incurred by the Agency, but were not explicitly funded or otherwise addressed in the MOU.

Accommodation costs are levied by PWGSC and incurred by the Agency at a rate of 13% of salaries.

The Agency included claims for accommodation costs as part of the total amount of expenditures for the Technical Expertise initiatives reported to AAFC for the 2015-16 fiscal year. Accommodation costs were not specifically funded at the time of entering into the MOU, and the MOU did not explicitly address the claiming of accommodation costs, i.e. it did not preclude claiming accommodation costs.

We reviewed TB costing guidance and found that it specifically provides for the funding and claiming of accommodation costs. We also noted that there are precedents for claiming accommodation costs in previous Agency initiatives, including GF1.

We reviewed Agency calculations for accommodation costs reported and found that the reported amount of $97,784 was lower than the actual amount of accommodation costs incurred ($192,190). The Agency claimed the maximum amount to stay within the total amount funded by the MOU for the 2015-16 fiscal year.

Recommendation 1.0:

The Vice President, Policy and Programs Branch should seek clarification from AAFC on the funding of accommodation costs for all three initiatives and seek amendment to this MOU, if necessary. CFIA should also ensure that the eligibility of claims for accommodation costs is explicitly identified in subsequent MOUs to avoid misinterpretation.

Non-salaries

Financial controls were in place for non-salary expenditures to support compliance with TB and Agency policies and directives.

A sample of 73 non-salary expenditure transactions was selected for testing. This sample comprised all 11 transactions valued over $5,000, and a statistically derived sample of 62 transactions. From our review of documentation supporting the sampled transactions, we found that financial controls were in place and working effectively to ensure MOU-related non-salary expenditures were approved, committed, verified and accurately coded and recorded, and that contracting processes were followed. Consequently, non-salary transactions complied with TB and Agency policies and directives.

We also reviewed account verification processes in place at the Agency's Corporate Management Branch and found that non-salary expenditures were well controlled with independent verifications performed.

Salaries

Salary amounts reported were based on Agency practice of using approved best estimates of planned time, in terms of percentages of employee total time, and not on actual time spent.

For salary expenditures, the Agency does not require actual times to be tracked by employees and recorded to initiatives, including those where funding is "fenced". Instead, salary expenditures are recorded and reported based on "best estimate" percentages of total time that employees are expected or planned to be working on an initiative. Once the estimated percentages are determined and approved for an initiative, they are entered into the SAP Salary Forecasting Tool, from which subsequent actual salary expenditures are derived.

When an employee spends 100% of his/her time on an initiative, there is no issue. However when an employee works on a number of initiatives, including those with fenced funding, there is a risk that the allocation of time to one of these initiatives based on best estimates may be an inaccurate reflection of actual time spent.

Consequently, we are unable to conclude that reported salary expenditure amounts represent a reasonable determination of actual salary expenditures spent directly for the intended purpose of working on the Technical Expertise Initiatives. The salary expenditures amount will also impact the accuracy of employee benefits and accommodation costs as these amounts are calculated as a percentage of salaries.

Salary amounts were accurately recorded in accordance with Agency practice.

As part of Agency salary accounting practice, there is a requirement for planned estimates of percentages of time to be worked on initiatives by employees to be approved. We reviewed a sample of approvals of percentage time estimates for each of the three Technical Expertise Initiatives and found that they were approved by the delegated authority, the percentage time estimates were accurately recorded in the Salary Forecasting Tool of SAP, and that total reported salary expenditures were based on the above recorded percentage time estimates.

3.3 Funding Management Practices and Processes

Work plans and budgets were approved and expenditures were reported in accordance with the MOU.

Clause 6.3 of the MOU identifies the requirement to approve work plans and budgets, and annual performance reports. Clause 8.2.5 of the MOU includes the requirement for CFIA to report total actual expenditures for each initiative in the annual performance report.

We reviewed the MOU and subsequent amendments approved by AAFC and CFIA, and found that they included work plans and total budgets by cost category for each initiative for each fiscal year. We also found that one MOU amendment was approved and executed during the 2015-16 fiscal year prior to the amended activities being undertaken.

Total actual expenditures for each initiative were reported to AAFC in the year end performance report for the 2015-16 fiscal year, in accordance with MOU Clause 8.2.5.

CFIA budgeting, commitment control and financial forecasting were performed in alignment with Agency requirements and practices.

Clause 6.3 of the MOU identifies the requirement to review cash flow forecasts and expenditures for the funded initiatives. Agency requirements for commitments to be set up prior to expenditures being incurred and for commitments to be monitored are provided in the Agency Directive on Expenditure Initiation and Commitment Control. The Corporate Management Branch of the Agency oversees and coordinates Agency processes for budgetary control, including financial forecasting.

From our interviews and document review, we found that budgets, commitments and financial forecasts for the initiative were developed and monitored, and were led by CFIA. We noted good practices for the Biosecurity Initiative where budget and commitment monitoring and financial forecasting were well detailed and documented. We found that the above activities undertaken by CFIA were in alignment with Agency requirements and practices. However as noted in Section 3.1, these activities were led by CFIA, with varying engagement by CFIA with AAFC counterparts.

The ability for CFIA to have discretion to transfer funding between cost categories was not included in the MOU, but was included in subsequent amendments for two of the three initiatives.

The MOU did not include a clause that explicitly addressed the ability for CFIA at its discretion to transfer funding between cost categories, including salaries and non-salary expenditures. For the Biosecurity and Traceability initiatives, amendments to the MOU explicitly provided CFIA with sole discretion to transfer funding between the cost categories. A similar amendment was not done for the FSRP initiative. In light of the existing MOU wording and the absence of an amendment, the ability for CFIA to transfer funding among cost categories for the FSRP initiative is not clear and subject to interpretation.

For the 2015-16 fiscal year, we found that there were variances between budgeted and actual costs by cost category for all initiatives, including FSRP. We understand that cost variances cannot be avoided because all initiatives face challenges with the ability to plan, budget and forecast due to circumstances beyond their control and the dependence on industry. The FSRP initiative is particularly heavily dependent on industry for progress and delivery. The other initiatives have also had to address situations during the 2015-16 fiscal year where industry stakeholders have had difficulty fulfilling travel commitments to attend meetings or conferences already set up.

Recommendation 2.0:

The Vice President, Policy and Programs Branch should seek clarification from AAFC on the eligibility to transfer funds among cost categories for the Food Safety Recognition Program initiative and, seek amendment to this MOU if necessary. CFIA should also ensure the eligibility to transfer funds among cost categories is explicitly identified in subsequent MOUs to avoid misinterpretation.

3.4 Financial and Performance Information Management Processes and Reporting Systems

Clause 8.2 of the MOU provides requirements for the timing of submission by CFIA of draft and final annual performance reports to AAFC and for the contents of the performance reports.

Annual performance reports submitted by CFIA to AAFC for the 2015-16 fiscal year were submitted on a timely basis, were approved by CFIA, were accurate and contained elements in accordance with the MOU.

We reviewed the year end performance reports prepared and submitted for each initiative for the 2015-16 fiscal year and supporting documentation.

We found that the draft and final performance reports for each initiative were delivered to AAFC on a timely basis and contained all required elements in accordance with MOU requirements. We also found that the reports were approved up to the ED level by CFIA.

We further selected a large sample of statements made in the performance report for each initiative, and found that all selected statements made were substantiated with supporting documentation.

Appendices

Appendix A: Audit Criteria

The audit criteria were developed from key controls set out in the Office of the Comptroller General's Audit Criteria related to the Management Accountability Framework: A Tool for Internal Auditors; criteria that are used for similar compliance audits; and, relevant clauses of this MOU.

The audit criteria are organized under the lines of enquiry below:

Line of Enquiry 1: Controls for Management and Administration of the Initiatives

1.1. There is effective oversight over the management and delivery of the three initiatives funded by the MOU.

1.2. Roles and responsibilities for management and administration are established, communicated and understood.

1.3. Lines of communication exist between AAFC and CFIA, and feedback from AAFC incorporated into operational planning and other activities in compliance with the MOU.

Line of Enquiry 2: Financial Controls

2.1 Expenditures related to the MOU are approved in advance by the delegated authority and commitments are recorded at the time of spending decisions.

2.2 The contracting process is followed for non-salary expenditures where applicable.

2.3 Account verification pursuant to Section 34 and 33 of the Financial Administration Act is followed in accordance with established procedures and certified by the delegated authority.

2.4 Expenditures are accurately coded and recorded in accordance with CFIA procedures.

Line of Enquiry 3: Funding Management Practices and Processes

3.1 Work plans and budgets, including material changes, are approved, and amendments to the MOU are executed on a timely basis where appropriate.

3.2 Progress against approved work plans and budgets is monitored, and appropriate corrective actions are taken where required.

Line of Enquiry 4: Financial and Performance Information Management Processes and Reporting Systems

4.1 Financial and performance reports are completed and delivered on a timely basis and are substantiated with supporting documentation.

4.2 Financial and performance reports are reviewed and approved in accordance with established procedures.

Appendix B: Management Response and Action Plan

Date: October 24, 2016

Overall Management Response:

The Vice President, Policy and Programs Branch has reviewed the Audit report on the GF2 MOU and agrees with both recommendations and will immediately begin the process and necessary consultation with the concerned program areas and AAFC partners to action activities outlined in this action plan.

Recommendation 1: The Vice President, Policy and Programs Branch should seek clarification from AAFC on the funding of accommodation costs for all three initiatives and seek amendment to this MOU, if necessary. CFIA should also ensure that the eligibility of claims for accommodation costs is explicitly identified in subsequent MOUs to avoid misinterpretation.
Management Response and Action Plan Implementation or Completion Date Responsible Leads
Management agrees with this recommendation and the following actions will be undertaken:
  • a) Consultation with AAFC to seek clarification on the funding of accommodation costs for all three programs
  • a) February 2017
ED, Animal Health Directorate, PPB
  • b) If necessary, work with AAFC and CFIA program areas to seek amendment to Annex D (Budget) of the GF2 MOU to ensure the CFIA is granted the eligibility to claim accommodation costs. Key milestones include:
    1. Consultation with CFIA Program Areas to amend Annex D of MOU, if necessary.
    2. Consultation with AAFC on proposed amendments
    3. Seek approvals by the relevant Designated Officials identified in clause 6.2 of the MOU (DG, AAFC and EDs, CFIA)
  1. March 2017
  2. April 2017
  3. May 2017
ED, Animal Health Directorate, PPB
  • c) Eligibility of claims for accommodation costs will be explicitly identified in any subsequent MOUs to avoid misinterpretation, whether or not they are specifically funded
  • c) By May 2017, the CFIA's Vice President, Policy and Programs Branch will send a letter of intent to AAFC's Assistant Deputy Minister, Programs Branch indicating that accommodation costs will be explicitly identified in any subsequent MOUs.
ED, Animal Health Directorate, PPB
Recommendation 2: The Vice President, Policy and Programs Branch should seek clarification from AAFC on the eligibility to transfer funds among cost categories for the Food Safety Recognition Program initiative and, seek amendment to this MOU if necessary. CFIA should also ensure the eligibility to transfer funds among cost categories is explicitly identified in subsequent MOUs to avoid misinterpretation.
Management Response and Action Plan Implementation or Completion Date Responsible Leads
Management agrees with this recommendation and the following actions will be undertaken:
  • a) Work with AAFC to seek clarification on the eligibility to transfer funds among cost categories for Food Safety Recognition Program initiatives
  • a) February 2017
ED, Domestic Food Safety Systems and Meat Hygiene Directorate, PPB
  • b) Work with AAFC and CFIA program areas to amend Annex D (Budget) of the GF2 MOU to seek the ability for the CFIA to move funds between cost categories for the Food Safety Recognition Program (much like other GF2 CFIA initiatives – Traceability and Biosecurity). Key milestones include:
    1. Consultation with CFIA Program Areas to amend Annex D of MOU
    2. Consultation with AAFC on proposed amendments
    3. Seek approvals by the relevant Designated Officials identified in clause 6.2 of the MOU (DG, AAFC and EDs, CFIA)
  1. March 2017
  2. April 2017
  3. May 2017
ED, Domestic Food Safety Systems and Meat Hygiene Directorate, PPB
  • c) Explicitly identify in any future MOU arrangements, the ability for the CFIA to move funds between cost categories, in light of expenditure planning and budgeting challenges.
  • c) By April 2017, the CFIA's Vice President, Policy and Programs Branch will send a letter of intent to AAFC's Assistant Deputy Minister, Programs Branch indicating that any future MOU arrangements will explicitly identify the ability for the CFIA to move funds between cost categories, in light of expenditure planning and budgeting challenges.
ED, Domestic Food Safety Systems and Meat Hygiene Directorate, PPB

Approved By (Branch VP):

Date:
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