Background
The Accredited Veterinarian Program authorizes private veterinarians to perform services on behalf of the CFIA. Nationally, almost 2,400 vets are authorized to perform duties related to the Animal Health Disease Control Program and certification of animals for export to the US or Mexico.
Under the authority of the Health of Animals Act and Regulations, the CFIA may grant certain authorities to the accredited veterinarians. The CFIA and the individual veterinarians enter into a three-year Accredited Veterinarian Agreement. These agreements, along with the Accredited Veterinarian Manual, outline the authority of accreditation; the roles and responsibilities; the processes for application to the program; supervision of accredited veterinarians; deviations and resolutions of performance; as well as termination of the agreement.
This program is an example of an "alternative service delivery" arrangement, which has been in place for the agricultural industry, private veterinarians and the Government of Canada for over 100 years.
The objective of the Accredited Veterinarians Program is to assist the CFIA in the delivery of its National Animal Health Program by performing duties related to the Animal Health Disease Control Program and certifying animals for export to the United States or Mexico.
According to the survey results, the percentage of income derived from Accredited Veterinary Program functions is as follows:
| < 10% |
89.3% |
10 - 25% |
8.8% |
| 25 - 50% |
1.4% |
> 50% |
0.4% |
Approach and Methodology
This evaluation was requested by senior Agency management. The issues covered were success, governance, design and delivery. The time frame covered by the evaluation was 2000-2005. Work was carried out from March-June 2006.
Work on the evaluation began immediately following approval of the Terms of Reference for this study were approved by the Sub-Committee on Corporate Planning and Accountability (SCCPA) on March 2, 2006. The work was carried out by an external consultant, TDV Global. The work was supported by an advisory committee with representatives from Programs and Operations
Branches, chaired by AERO. The Accredited Veterinarians Evaluation Report was approved by the successor group to SCCPA, SCARM (Sub Committee on Audit and Risk Management) on September 13, 2006.
Methodologies used included document reviews, file reviews in District and Area Offices, web reviews, site visits to three Area Offices and six District Offices, a survey of accredited veterinarians (20% response rate), as well as internal (26) and external (11) interviews.
Summary of Results
The main results are as follows, presented by evaluation issue.
Success: To what extent is the Accredited Veterinarian Program achieving its objective?
| A. |
To what extent is the Accredited Veterinarian Program successful and effective in assisting the CFIA in the delivery of its National Animal Health Program by performing duties related to the Animal Health Disease Control Program and certifying animals for export to the United States or Mexico?
- Accuracy of export certification very good
- Significant changes to system in 2005 due to BSE-related requirements resulted in temporary increase in inaccuracies.
- Timeliness of export certification very good.
- Disease surveillance benefits currently are indirect but nonetheless significant.
|
| B. |
What are the major internal and external factors contributing to or limiting the success of the program?
Internal Factors:
- Rapport, level and nature of contact between District Veterinarians and Accredited Veterinarians is biggest success factor.
- Accredited Veterinary Manual - frequency and approach to updating has limited success.
- Lack of communication and consultation among Districts, Areas and HQ also limiting success.
- Low CFIA resource levels, staffing of positions and unclear program management accountabilities.
- Inconsistent interpretation of export requirements by District Offices limits success.
External Factors:
- Knowledge/contact Accredited Veterinarians have with producers and herds is a contributing factor for success.
- Breadth of animal export activity - geographically dispersed, large numbers of Accredited Veterinarians is a program challenge.
- Stringent US import requirements (zero tolerance environment related to BSE), inconsistent interpretation of import requirements by USDA border vets and additional requirements by individual States limit success.
|
| C. |
What are some of the perceived limitations to the program?
- Perceived potential for conflict of interest between exporters and accredited veterinarians - observed more at higher levels (e.g. more concern in Areas and HQ than in Districts).
- Limited to US and Mexico and to certain species - US is the key destination and this limitation makes the program manageable.
- Some discussion of potential for expansion of program:
- Survey of Accredited Vets: Willingness to take on additional duties: Yes: 77%; No: 23%.
- Areas of potential expansion: Enhanced disease surveillance, aquatic animals, specific species for additional countries, small animals / pets.
Governance |
| A. |
Are the agreements between the Accredited Veterinarians and the CFIA up to date, and appropriately managed by the CFIA?
- Accredited Veterinarian Agreements are for the most part, up-to-date and appropriately managed.
- Minor issues found:
- Time delays in signing of agreements at Area offices,
- Poor AVIS (Accredited Vet Information System) implementation,
- Lack of a process to manage expired agreements,
- Inconsistent filing and archiving across Areas, and
- Price Waterhouse Coopers (PwC) Compliance Audit Report identified weaknesses in the Management of the Accredited Veterinarian Program policy regarding management of deviations. CFIA management response committed to review and update the policy.
|
| B. |
Are issues of conflict of interest (real or perceived) fully considered in the design and management of this program?
- Conflict of interest has not been found to be a significant issue with the current program design.
- While the potential for conflict of interest is a result of the program design, issue has been considered in:
- Training, Management Manual, Terms and Conditions, CFIA endorsement, Deviation Management.
|
| C. |
Are the program roles and responsibilities, including authorities, clear and well understood by all parties? Do they need revision or modification?
- Roles and responsibilities of the Accredited Veterinarians and the District Veterinarians are clear and well understood.
- Authorities are not clear and need revision:
- District Veterinarians may report to more than one person regarding the Accredited Veterinarian Program.
- Authorities up the chain of command are not clear.
- Roles unclear with respect to the management of the Accredited Veterinarian Program. for:
- Inspection Manager, Regional Veterinary Officer, Area Chief, etc.
- Program accountability has been weak at times.
Design and Delivery:
|
| A. |
Are the procedures in the program..., understood and implemented? Are there mechanisms to provide assurance that procedures are followed?
- Procedures are generally well-documented.
- Lack of clarity with some procedures related to the management and resolution of deviations.
- Implementation inconsistent
- Application process sufficient to meet program needs.
- Supervision of Accredited Veterinarians not fully implemented.
- Issues: consistency of application, lack of standards, awareness, standardized form usage.
- Limited quality assurance occurring at District level; none at Area or National levels.
- Accredited Veterinarians Manual is inadequate in its implementation.
- Processes to manage deviations requires improvement.
- Mechanisms to assure that procedures are followed have not been implemented.
|
| B. |
Are ways to improve program delivery being considered and implemented in support of continuous improvement?
- No systemic implementation of continuous improvement was found although recent program improvement initiatives are positive: Accredited Veterinarian Program Working Group, PwC Compliance Audit, and this evaluation.
- Lack of a mechanism to engage Accredited and District Veterinarians has resulted in insufficient input by both parties into program decisions.
|
| C. |
Risk is managed following incidents, not proactively.
- Risk management processes are inconsistently implemented at Accredited Veterinarian and District levels
- Risk management processes are inconsistently implemented at Accredited
Veterinarian and District levels
- Audit and verification processes designed but not implemented in Areas or Nationally
|
| D. |
What is the economic value of this program to the agricultural industry?
- Accredited Veterinarian Program facilitates timely export of swine, poultry, horses, cattle, ovine, caprine, bison, camelide and cervidae (see table for selected statistics).
- Includes low value animals (for consumption) and high value animals (breeding, racing, show animals).
| Table: Trends in key species exported |
|
|
2003 |
2004 |
2005 |
|
|
# of Animals |
# of Animals |
# of Animals |
# of Certificates |
| Swine |
5,106,457 |
5,755,371 |
5,866,964 |
12,965 |
| Poultry |
26,045,976 |
29,708,323 |
27,057,939 |
1,877 |
| Horses |
54,178 |
43,230 |
39,292 |
24,159 |
| Cattle |
133,000 |
0 |
567,426 |
7,561 |
- At approximately 10% of each Accredited Veterinarian's time (see survey question #3), the program leverages approximately 240 person years at no expense to the public.
- The program generates approximately $2M annually in revenue for CFIA (cost recovery).
|
| E. |
Do the financial arrangements in place have an impact on the efficacy of this program - what are the benefits and limitations of the arrangements? Are there other financial options that would improve the efficacy of the program?
- Current model is efficient, cost-effective, and constitutes an effective cost-recovery model given the current scope of activities.
- While it does introduce the potential for conflict of interest, program design, awareness, professional ethics and consequences of errors and misrepresentation are significant mitigating factors to the risk.
- Alternative options are unlikely to improve efficacy.
Recommendations
The evaluation made the following recommendations.
- The Vice-President Programs, in consultation with Operations, should clarify accountabilities and responsibilities for oversight of the Accredited Veterinarian Program.
- The Accredited Veterinarian Program should improve its procedures for Management of Deviations.
- The Accredited Veterinarian Program should improve the suite of program tools to better equip District and Accredited Veterinarians.
- The Accredited Veterinarian Program should reinforce and monitor its quality assurance procedures (i.e. delivery of supervisory visits, area audits, national audits, and Annual Management Reviews).
- The Vice-Presidents of Programs and Operations should design and implement a continuous improvement system that address the major findings of this evaluation.
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