2014-15 Compliance Report Action Plan

Table of contents

La Fédération des Coopératives du Nouveau-Québec (FCNQ)

Audit Recommendation Recipient Response/Actions Status
1 - The Recipient should ensure the accuracy and completeness of reports prior to these being submitted to AANDC. Therefore, an independent review of reports should be performed by the Assistant Manager - Store Services prior to submission to AANDC. 1 - The Recipient accepts Deloitte's recommendation of having the exactitude and integrity of the reports independently verified by the Assistant OMS Manager before being submitted to INCA for claim processing. Completed

AN Food Distributors (ANFD)

Audit Recommendation Response/Action Status
1 - It's recommended that the Recipient improve its control over the application of the subsidy in order to ensure the accuracy and validity of claimed subsidies. 1 - We will implement the following business changes in order to allow cargo agents more time to process subsidized food shipments to Old Crow:
  1. Restrict the hours that shipments can be accepted at the Whitehorse cargo office to off-peak hours during the day.
  2. Require shippers to pre-sort and segregate all items into level 1 and level 2 boxes before shipments are presented at the cargo counter.
Completed
2 - It's also recommended that the Recipient ensure that an independent review process occurs prior to information being submitted to AANDC, which will increase the quality of the information being provided to AANDC. 2 - A review of the process to prepare a monthly claim will be reviewed with a view to improve the accuracy of claim submission. The monthly claim prepared by the current accounting officer will be reviewed by the new accounting manager once that position is filled. Completed

True North Community Co-Operative (TRUN)

Audit Recommendation for TRUN TRUN Response/Action Status
1 - It is recommended that the Recipient implement a process to ensure that the end consumer receives adequate information on the Nutrition North Canada program. 1. Program visibility: As a Southern Supplier we have met all requirements to ensure our customers receive adequate information on the Nutrition North Canada program. Our future efforts to provide greater information to the end customer include supporting the transition of all program administration to residents of the remote communities we served. Specifically, this means supporting their efforts to become eligible Northern Retailers and phasing out our role as a Southern Supplier. Completed

No longer a registered supplier as of July 2015.
2 - It is also recommended that the Recipient improve its controls over the calculation of the subsidy in order to ensure the accuracy and validity of claimed subsidies. An independent review process prior to submitting information to AANDC would increase the quality of the information being submitted. 2. Processing and reporting controls: As a small non-profit organization we have faced significant challenges segregating duties and receiving adequate documentation from airlines. We have never submitted claims directly to INAC as there is an independent third party review process. Our future efforts to provide greater information to the end customer include supporting the transition of all program administration to residents of the remote communities we served. Specifically, this means supporting their efforts to become eligible Northern Retailers and phasing out our role as a Southern Supplier. Completed

No longer a registered supplier as of July 2015.
3 - It is recommended that the Recipient implement a process to ensure that ineligible parties do not have access to goods shipped by the Recipient under the Nutrition North Canada program. 3. Ineligible clients: As a Southern Supplier we have met all requirements to ensure our customers were not ineligible organizations. Our future efforts to build greater controls include supporting the transition of the program administration to residents of the remote communities we served. Specifically, this means supporting their efforts to become eligible Northern Retailers and phasing out our role as a Southern Supplier. Completed

Rampart Rentals (RAMP)

Audit Recommendation for RAMP RAMP Response/Action Status
1 - It's recommended that the Recipient establish processes and procedures to ensure the subsidy is fully passed on to the end consumer, and that the profit margin is not eroding the subsidy. 1 - The store will continue to improve the processes and procedures in ensuring that subsidy is targeted to the end consumer and this is largely being done as described in point three (3) below. Completed
2 - It's recommended that the Recipient continue its current practice of reflecting the subsidy as a discount to the end consumer to ensure that the subsidy is communicated in a transparent process to the end consumer. The Recipient should ensure that the consumer is aware that the 'discount’ relates to the NNC Program either through signage or a description on the receipt itself. 2 - Program visibility continues to be in place and particularly the 'shelf talkers’ that tell of Nutrition North Canada (NNC) presence are located in areas where the subsidy is mostly targeted (ie: milk and cheese section, eggs, fresh produce). There are several prominent areas in the store where NNC posters could be displayed and we request being forwarded new larger posters that speak of the programs purpose and benefits that upon arrival will be incorporated. Completed
3 - It's recommended that the Recipient improve its controls over the application of the subsidy in order to ensure the accuracy and validity of claimed subsidies. This would include implementing controls to ensure claims are filed on a timely basis and that there is an independent review process occurring prior to information being submitted to AANDC, which will increase the quality of the claims being submitted. 3 - Historically, the practice was the store completed the claim by inputting the eligible subsidy items for the period on the provided spreadsheet and submitted the work to the third party evaluator ie: Crawford. This was done for two reasons; the first being the store manager was most familiar with the store’s item by item purchases, but secondly and more importantly this individual was most prolific at the store level in working with a spreadsheet. To address the recommendation of controls, the ownership is transitioning this role to a person outside of the store who will input the data and the store manager will now oversee the work prior to submitting. Completed
4 - It's recommend that the items which are then resold to ineligible customers not be claimed as part of the subsidy, and noted that upon observing this practice during our on-site fieldwork, the General Manager acknowledged that this practice would not be continued going forward. Further, we recommend that AANDC consider recovering the overpayment of $7,601, as approximated above, relating to the ineligible subsidy claims. Additionally, we recommend that the Recipient retain the detailed sales records for any transactions relating to the Program for the length of time specified in the Recipient’s funding agreement with AANDC in order to substantiate the financial and non-financial reports and facilitate future Program audits. 4 - The audit bore out subsidies being provided to ineligible (ie: mining camps) establishments and the General Manager agreed to stop this practice. The practice was easy to stop as the issue pertained to several customers and one was seen to be the bulk of the affected transactions. The owners agree with the recommendation that NNC recover the funds of $7,601 by short-paying a future claim. The remaining recommendations, such as retaining detailed sales records, are already in place and this practice will continue.

NOTE: Funds identified to be recovered by the Program were deducted from the June 2016 payment issued to the Recipient.
Completed

M&M Yellowknife (Cactus Holdings Ltd.)

Audit Recommendation Response/Action Status
1 - It's recommended that the Recipient inform its clients in writing that they cannot sell and/or ship subsidized items to restricted organizations. 1. We will let customers know we cannot ship to restricted organizations. Completed
2 - It's also recommended that the Recipient ensure that an independent review process occurs prior to information being submitted to AANDC, which will increase the quality of the information provided to AANDC. 2. We will have another set of eyes such as the owner that will independently review information prior to being submitted to AANDC. Completed

North West Company (NWCO)

Audit Recommendation NWCO Response/Action Status
The Recipient was found to be in compliance with the terms and conditions of their agreement with the Department, no recommendations were provided by Deloitte. No Action Plan Required. N/A

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