Part III: CAP's Concerns and Conclusions about the Management of Grant and Contribution Funding by the Federal Government
Modern government accountability is not just about whether every dollar that has been spent has been fully accounted for. It is about whether that dollar has been used in the most effective way possible to produce the desired results. Aboriginal grants and contributions have been the subject of allegations and complaints, audits, investigations, and in some cases, criminal and civil court proceedings. It remains absolutely necessary to address malfeasance, corruption, and fraud when it exists, but disproportionate focus on these issues diverts time and effort from an important and potentially more challenging national debate. Canada and Aboriginal people can no longer afford a system that supports Aboriginal programs and services, intended to meet desperate need, but delivered without clear objectives or strategies to ensure those services are universally accessible, adequate, appropriate, and administered to maximize resources.
Our analysis, based solely on the limited information contained in the Grant and Contribution disclosure system, cannot consider significant questions that need to be asked and answered about funding for Aboriginal people. This is because the existing reporting of federal grants and contributions provides no information on the following:
How much federal funding is transferred to Provinces and Territories for Aboriginal people (using instruments other than Grants and Contributions) and is it being directed to Aboriginal programs?
Are Provinces and Territories typically spending more or less than they receive in federal transfers related to Aboriginal populations?
Which level of government ultimately bears primary responsibility for Aboriginal program expenditures that are the focus of “jurisdictional” disputes? What mechanisms are needed to begin resolving these disputes in a productive and timely way?
Is it appropriate for governments to provide varying entitlements and inequitable program access to Aboriginal people because of status or residency?
Noting that the Aboriginal population is highly mobile, including frequent movements between federal and provincial jurisdictions, are there federal/provincial agreements in place to ensure program access is not compromised by mobility?
If “reasonable provincial comparability” is the program test for on-reserve program and service delivery standards, what mechanisms are used to ensure that funding is adequate to meet that test? Furthermore, how do federal and provincial governments ensure that provincial program changes, including enhancements, are supported for on-reserve delivery?
Are on-reserve regulatory regimes sufficient to ensure that program quality and service delivery standards are being maintained?
If urban and rural Aboriginal people are expected to access programs that are available to the general population, are there mechanisms in place to ensure that provincial, territorial, and municipal government program design and delivery actually provides adequate, accessible, and appropriate services to their Aboriginal citizens?
For programs and services being delivered by Aboriginal organizations, what economies of scale and strengthening of capacity can be achieved through appropriate delegation and aggregation of service delivery?
For all programs, what is the final distribution of resources between actual program spending and administration costs?
The distribution of Grants and Contributions occurs near the “end” of the federal program funding cycle. Before program funds can be allocated as a Grant or Contribution, there is a great deal of political and bureaucratic effort required to authorize those expenditures. These include Cabinet approvals, the development of Treasury Board program terms and conditions, appropriation of funds by Parliament, Departmental priorization of program resources, and creation of funding formulas, allocation methodologies, and so on.
Financial accountability focuses on recipient financial reporting, including annual audits.
Program accountability has typically been left to the Auditor General, who may only review a program every ten years, and Treasury Board, who renew program authorities for each program every five years. Consistently, the Office of the Auditor General has raised concerns about the lack of clarity around roles and responsibilities for Aboriginal programs. Treasury Board continues to carve out silos for program delivery between departments, resulting in gaps, duplication, and Aboriginal people’s real needs becoming “jurisdictional disputes”. This includes education, housing, municipal services such as water and sewer, and child and family services – significantly, the very programs that are necessary to improve the quality of life and opportunities for Aboriginal people.
The Congress believes that it is time to move the national debate from “financial accountability” to “program accountability”, including clear assignment of roles, responsibility, and accountability for results by federal departments, provincial and territorial governments, Band Councils and Aboriginal organizations. We note that water related deaths in Walkerton and ensuing political crisis forced this exercise for on-reserve water quality. A horizontal “First Nations Water Management Strategy” eventually evolved as a coordinated federal response.13 This exercise needs to be repeated for every program area as a matter of some urgency (economic development, education, social services, housing, and health care). And, it must also include a realistic analysis of “on/off” program availability and accessibility in order to stop the legacy of personal and community tragedies that seem endemic to the lives of Aboriginal people in Canada today.
It is time for everyone to insist on results, in addition to audits. And, it is time to stop funding programs, processes, and organizations that cannot demonstrate results for Aboriginal people so that valuable resources can be directed to programs and services that actually have a positive impact on Aboriginal peoples’ lives and well-being.
Accountability that only asks the question “Where did the money go?” cannot begin to address the real issues and challenges that Aboriginal people and all governments in Canada must confront. Public reporting of Grants and Contributions through the Proactive Disclosure system only nominally begins to address the question of transparency, and raises far more questions – legitimate and important questions -- than it answers.
More work - courageous, forthright, and honest work - needs to be done.
