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                                 COVID-19
                                 PANDEMIC
                                 REPORT 6

                                 Canada Emergency
2021                             Response Benefit
Reports of the Auditor General
of Canada to the
Parliament of Canada
                                 Independent Auditor’s Report
2021
Reports of the Auditor General of Canada
to the Parliament of Canada


Independent Auditor’s Report
COVID-19 Pandemic
REPORT 6
Canada Emergency
Response Benefit
Performance audit reports
This report presents the results of a performance audit conducted by the Office of the Auditor
General of Canada (OAG) under the authority of the Auditor General Act.
A performance audit is an independent, objective, and systematic assessment of how
well government is managing its activities, responsibilities, and resources. Audit topics
are selected on the basis of their significance. While the OAG may comment on policy
implementation in a performance audit, it does not comment on the merits of a policy.
Performance audits are planned, performed, and reported in accordance with professional
auditing standards and OAG policies. They are conducted by qualified auditors who
  • establish audit objectives and criteria for the assessment of performance
  • gather the evidence necessary to assess performance against the criteria
  • report both positive and negative findings
  • conclude against the established audit objectives
  • make recommendations for improvement when there are significant differences
    between criteria and assessed performance
Performance audits contribute to a public service that is ethical and effective
and a government that is accountable to Parliament and Canadians.




This publication is available on our website at www.oag-bvg.gc.ca.
Cette publication est également offerte en français.
© Her Majesty the Queen in Right of Canada, as represented
by the Auditor General of Canada, 2021.
Cat. No. FA1-27/2021-1-6E-PDF
ISBN 978-0-660-37826-8
ISSN 2561-343X




Cover and title page photos: WAYHOME studio/Shutterstock.com
Table of Contents

Introduction                                                                                                                                             1
Background. ...........................................................................................................................................1

Focus of the audit...................................................................................................................................3

Findings, Recommendations, and Responses                                                                                                                 4
Designing an emergency response benefit.............................................................................................4
     The organizations considered and analyzed key areas in the initial design and ongoing
     adjustment of the Canada Emergency Response Benefit. ........................................................................ 5
           Rapid design of the benefit.................................................................................................................... 6
           Benefit expanded and modified over time. .......................................................................................... 8
     Quick delivery of the benefit influenced the approach to controls. ........................................................ 10
           Initial focus on expediting payments.................................................................................................. 11
           Some additional pre-payment controls introduced........................................................................... 12
           Most post-payment verification to begin in the 2021–22 fiscal year............................................... 13

Conclusion                                                                                                                                             16

About the Audit                                                                                                                                        17

List of Recommendations                                                                                                                                22




Canada Emergency Response Benefit                                                                                                          Report 6      |     iii
Introduction

Background

Responding to a
pandemic

                            6.1 On 18 March 2020, as part of its wide-ranging economic
                            response to the coronavirus disease (COVID-19) pandemic, the federal
                                               1




                            government announced 2 new benefits to provide income support for
                            workers. The Emergency Care Benefit would support workers who
                            were unable to work because of COVID-19–related health concerns for
                            themselves or others they care for. It would give benefits to workers,
                            including the self-employed, who did not have access to paid sick leave
                            or Employment Insurance sickness benefits. The Emergency Support
                            Benefit would support workers who were facing unemployment and
                            were not eligible for Employment Insurance. In the week after this
                            announcement, to make it easier and more accessible for applicants,
                            these benefits were replaced with what would become the Canada
                            Emergency Response Benefit.

                            6.2 The purpose of the Canada Emergency Response Benefit was to
                            support workers who lost income as a result of the COVID-19 pandemic.
                            It was intended to
                               • help affected workers meet their financial obligations
                               • allow workers to stay home to help stop further spread of the virus
                               • reduce the disease’s toll on individuals and the health care system

                            Eligibility criteria were defined for the benefit (Exhibit 6.1).




                                Coronavirus disease (COVID-19)—The disease caused by severe acute respiratory
                                syndrome coronavirus 2 (SARS-CoV-2).



Canada Emergency Response Benefit                                                                       Report 6   |   1
    Exhibit 6.1—Eligibility criteria for the Canada Emergency Response Benefit1

         To be eligible for the Canada Emergency Response Benefit, applicants had to meet the following criteria
                                                at the time of applying:

             • reside in Canada
             • be at least 15 years of age
             • earned a minimum of $5,000 before taxes in the 12 months leading up to the application or in 2019 from
               one of the following sources:
                   • employment income
                   • self-employment income
                   • federal and provincial benefit payments related to maternity or parental leave
             • did not quit their jobs voluntarily
             • are affected by the COVID-19 pandemic in one of the following ways:
                   • had work hours reduced because of the pandemic and do not expect to earn more than $1,000
                      before deductions over a period of at least 14 consecutive days during the 4-week period for
                      which they applied for the benefit
                   • stopped working because of the pandemic for at least 14 consecutive days within the 4-week
                      period for which they applied for the benefit
                   • are unable to work because of the pandemic, including because they need to take care of a
                     dependent
                   • received Employment Insurance regular or fishing benefits for at least 1 week since
                     29 December 2019 and had exhausted those benefits

         1
          This exhibit is intended to summarize eligibility information provided to potential applicants by Employment and Social
         Development Canada and the Canada Revenue Agency.

         Source: Employment and Social Development Canada and the Canada Revenue Agency



                                          6.3 Although the Canada Emergency Response Benefit is generally
                                          referred to as 1 benefit, there were 2 benefits with slightly different
                                          eligibility criteria. Applicants could apply for either benefit:
                                             • Applicants eligible for Employment Insurance benefits should apply
                                               for the Employment Insurance Emergency Response Benefit. This
                                               benefit fell under the Employment Insurance Act.
                                             • Applicants not eligible for Employment Insurance benefits should
                                               apply for the non–Employment Insurance Emergency Response
                                               Benefit. This benefit fell under the Canada Emergency Response
                                               Benefit Act.

                                          To make it easier, we will refer to the 2 benefits as the “Canada
                                          Emergency Response Benefit” or the “benefit” unless there is a need to
                                          distinguish between them.

                                          6.4 Initially, the benefit paid $500 per week for 16 weeks to eligible
                                          recipients. The benefit was extended twice. On 26 June 2020, the benefit



2    |        Report 6                                Reports of the Auditor General of Canada to the Parliament of Canada—2021
                            was extended by 8 weeks. This was followed by an additional 4-week
                            extension on 28 August 2020. In total, the benefit provided support
                            for a maximum of 28 weeks. Support under the benefit ended
                            on 3 October 2020. However, individuals could apply retroactively for the
                            benefit up to 2 December 2020.

                            6.5 The most recent figure reported by the government on Canada
                            Emergency Response Benefit payments was about $74 billion as
                            of 4 October 2020.

Roles and
responsibilities

                            6.6 Employment and Social Development Canada’s responsibilities for
                            the Canada Emergency Response Benefit included policy development
                            and program design, administration, and enforcement. The department
                            engaged the Canada Revenue Agency to help administer the benefit.

                            6.7 The Canada Revenue Agency, through a delegation of authority
                            granted by the Minister of Employment, Workforce Development and
                            Disability Inclusion on 3 April 2020, was responsible for administering
                            the non–Employment Insurance Emergency Response Benefit. This
                            means that, for this benefit, the agency’s responsibilities included
                               • accepting applications
                               • verifying and validating the applicant’s eligibility
                               • processing applications and authorizing payments
                               • preventing the processing of non-eligible applications
                               • identifying and collecting erroneous payments

                            6.8 Employment and Social Development Canada had these same
                            responsibilities for the Employment Insurance Emergency Response
                            Benefit.

                            6.9 The Department of Finance Canada is responsible for providing
                            advice and analysis to the Minister of Finance on the economic, fiscal,
                            and social considerations related to proposed policy options.


Focus of the audit
                            6.10 This audit focused on whether Employment and Social
                            Development Canada and the Department of Finance Canada provided
                            analysis to support the initial design and subsequent adjustments to the
                            Canada Emergency Response Benefit.

                            6.11 This audit also focused on whether Employment and Social
                            Development Canada and the Canada Revenue Agency designed
                            mechanisms so that the benefit would support eligible workers who


Canada Emergency Response Benefit                                                          Report 6   |   3
                      suffered a loss of income for reasons related to the COVID-19 pandemic,
                      including limiting abuse of the benefit.

                      6.12 This audit is important because of the significant cost of the
                      benefit and because of its intent to assist workers affected by the
                      pandemic.

                      6.13 The implementation of post-payment verification mechanisms will
                      be the subject of a future audit.

                      6.14 More details about the audit objective, scope, approach, and
                      criteria are in About the Audit at the end of this report (see pages 17–21).



    Findings, Recommendations, and Responses
    Overall message

                      6.15 From the outset of the COVID-19 pandemic, the government set
                      out to quickly get the Canada Emergency Response Benefit to eligible
                      workers. Working within a short time frame, Employment and Social
                      Development Canada and the Department of Finance Canada supported
                      the design of the benefit to deliver support to workers who lost income
                      because of the COVID-19 pandemic.

                      6.16 With its quick rollout and subsequent adjustments in real time, the
                      benefit was put in place to help support affected workers financially and
                      allow them to stay home to avoid overwhelming the country’s health care
                      system. To get the benefit to workers quickly, Employment and Social
                      Development Canada and the Canada Revenue Agency made decisions
                      about the nature of pre-payment controls that would be introduced.
                      The department and the agency made an early decision to focus on
                      post-payment controls to simplify the process and expedite issuing
                      benefit payments. The department and the agency introduced additional
                      controls once the benefit was rolled out. The organizations have planned
                      for post-payment verification work. Most of that work was expected to
                      start in the 2021–22 fiscal year.


    Designing an emergency response benefit

    Context

                      6.17 The Canada Emergency Response Benefit was designed and
                      implemented by Employment and Social Development Canada in a few
                      weeks (Exhibit 6.2).




4    |   Report 6               Reports of the Auditor General of Canada to the Parliament of Canada—2021
Exhibit 6.2—Timeline of key events in 2020 for the Canada Emergency Response Benefit1

       March           11	World Health Organization declares COVID-19 a pandemic
                       15        Canada Emergency Response Benefit period begins
                       18        Temporary measures to support workers announced
                       25        COVID-19 Emergency Response Act comes into effect
                       31        Benefit rate set at $500 per week

       April           6         Online applications opened
                       8         First payments issued
                       15	Expanded eligibility announced to allow benefit recipients to earn up
                           to $1,000 over a 4-week period, and expanded eligibility announced for
                           the Employment Insurance Emergency Response Benefit to include
                           seasonal workers and those whose Employment Insurance benefits
                           had been exhausted2
                       23	Employment Insurance Emergency Response Benefit extended to
                           self‑employed fishers

       June            26        Benefit extended to 24 weeks

       August          28        Benefit extended to 28 weeks

       October         3         Benefit period ends

       December        2         Deadline to submit retroactive applications

       1
         The dates in this exhibit reflect when decisions were made or announced and not necessarily when they came
       into force.
       2
         This refers to Employment Insurance claimants who recently exhausted regular benefits and were unable to
       find work for reasons related to the COVID-19 pandemic.

       Source: Based on information from the COVID-19 Emergency Response Act, interim orders amending the
       Employment Insurance Act, regulations on income support payments, and announcements from the federal
       government and the World Health Organization




The organizations considered and analyzed key areas in the initial design and ongoing
adjustment of the Canada Emergency Response Benefit

What we found

                                6.18 We found that, despite extraordinarily challenging circumstances,
                                an emergency benefit to support workers who lost income as a result
                                of the COVID-19 pandemic was designed quickly. Despite not having
                                the usual time required to perform the analysis for the design of a
                                new benefit, Employment and Social Development Canada and the
                                Department of Finance Canada considered key areas in the design of the
                                Canada Emergency Response Benefit. They also conducted preliminary




Canada Emergency Response Benefit                                                                             Report 6   |   5
                               analyses on the cost of the benefit. In addition, Employment and Social
                               Development Canada conducted analysis in other key areas.

                               6.19 We also found that after the initial design of the benefit was
                               finalized, Employment and Social Development Canada and the
                               Department of Finance Canada performed analysis in key areas. This
                               analysis was used to inform changes to the benefit and respond to the
                               evolving crisis.

                               6.20 The analysis supporting this finding discusses the following topics:
                                 • Rapid design of the benefit
                                 • Benefit expanded and modified over time

    Why this finding matters

                               6.21 This finding matters because of the importance of this benefit and
                               its significant cost. These factors underscore that it needed to be well
                               designed and to be adjusted over time as circumstances changed.

    Context

                               6.22 To deliver this simplified emergency benefit, a new law and
                               changes to an existing law were needed. On 25 March 2020, the
                               COVID-19 Emergency Response Act came into force. This act
                                 • created the Canada Emergency Response Benefit by enacting the
                                   Canada Emergency Response Benefit Act
                                 • provided the authority to the Minister of Employment, Workforce
                                   Development and Disability Inclusion to issue interim orders to
                                   amend the Employment Insurance Act

                               6.23 On 31 March 2020, the Minister issued the Interim Order Amending
                               the Employment Insurance Act to include the Employment Insurance
                               Emergency Response Benefit.

                               6.24 As the Canada Emergency Response Benefit was delivered, it was
                               changed through interim orders amending the Employment Insurance Act
                               and regulatory changes to the Canada Emergency Response Benefit Act.

    Recommendations

                               6.25 We made no recommendations in this area of examination.

    Analysis to support
    this finding

                               Rapid design of the benefit

                               6.26 The unprecedented nature of the global pandemic in
                               mid‑March 2020 meant that developing policy, conducting economic
                               analysis, drafting legislation, preparing communications products, and


6    |   Report 6                        Reports of the Auditor General of Canada to the Parliament of Canada—2021
                            ultimately putting the Canada Emergency Response Benefit in place
                            occurred very quickly. Turnaround time for key steps was often a few
                            hours or overnight. Employment and Social Development Canada
                            and Canada Revenue Agency officials informed us that this stood in
                            stark contrast to the usual policy and program development process,
                            which can take place over many months. Despite this, we found that
                            Employment and Social Development Canada considered many key
                            areas in the benefit’s initial design. The department also conducted
                            analysis in some key areas.

                            6.27 We found that the department considered social, economic, and
                            health and safety information to inform decisions about the benefit’s
                            design. This included key areas such as the benefit’s parameters and
                            structure and its impact on different recipient groups, economic sectors,
                            and the labour supply. The department also considered aspects of the
                            Employment Insurance sickness benefit for health care workers who
                            were affected by the severe acute respiratory syndrome (SARS) virus in
                            2003.

                            6.28 We also found that, when designing the benefit, the department
                            considered what was needed to meet the government objective of
                            getting the benefit to eligible workers as quickly as possible. This
                            included
                               • providing a flat-rate payment, rather than one based on a sliding
                                 income scale
                               • having minimal and clear eligibility criteria (applicants to provide an
                                 attestation but no supporting documentation)
                               • using the Social Insurance Number (SIN) as the primary way to
                                 validate an applicant’s identity
                               • confirming eligibility through post-payment measures

                            6.29 We found that the department also analyzed existing Employment
                            Insurance statistics to determine the average amount paid to claimants
                            and the percentage of claimants receiving the maximum benefit rate.
                            The data showed that in the 2018–19 fiscal year, the average amount
                            paid to claimants was about $470 per week, and approximately 50% of
                            claimants received the maximum benefit of $573 per week. We also
                            found that the department conducted preliminary analysis on the cost of
                            the benefit. Ultimately, the weekly Canada Emergency Response Benefit
                            payment was set at $500 on 31 March 2020.

                            6.30 Similarly, we found that the department analyzed Employment
                            Insurance statistics to identify workers who would be ineligible under
                            the existing Employment Insurance program. This analysis showed that
                            millions of workers would be ineligible. Ineligible workers included, for
                            example, individuals who
                               • were self-employed and did not contribute to Employment Insurance
                               • had to stay home to care for children when schools were closed

Canada Emergency Response Benefit                                                             Report 6   |   7
                   6.31 As part of its responsibility for providing advice and analysis on
                   policy considerations, the Department of Finance Canada performs
                   a challenge function with respect to funding proposals submitted by
                   federal departments and agencies. We found that, despite not having
                   the usual time required to perform its challenge function on the design
                   of the new benefit, the Department of Finance Canada considered key
                   areas in the initial design of the Canada Emergency Response Benefit.
                   The Department of Finance Canada considered some of the same areas
                   as Employment and Social Development Canada. Like Employment and
                   Social Development Canada, it also conducted preliminary analysis on
                   the benefit’s cost. Finally, we found that once the initial design of the
                   benefit was finalized, the Department of Finance Canada compared
                   aspects of the Canada Emergency Response Benefit with similar
                   benefits being delivered by other countries in response to the pandemic.

                   Benefit expanded and modified over time

                   6.32 We found that, although Employment and Social Development
                   Canada was aware that the initial scope of the Canada Emergency
                   Response Benefit excluded some individuals, it went ahead with the
                   launch of the online application system on 6 April 2020. The department
                   did this to issue the benefit as quickly as possible to Canadians who had
                   stopped working because of the COVID-19 pandemic. The benefit did not
                   support those who were not working because of the pandemic, such as
                     • seasonal workers
                     • individuals ready to work but unable to find jobs because of the
                       pandemic
                     • people whose Employment Insurance claims were approaching the
                       maximum benefit period

                   6.33 Similarly, we found that Employment and Social Development
                   Canada was aware that the benefit’s initial design could create a
                   disincentive for some workers to continue working or seek employment.
                   This was because it did not allow for any income to be earned while
                   receiving the benefit.

                   6.34 We found that the department identified that adjusting eligibility
                   criteria to allow workers to continue to earn some income and collect the
                   benefit could create an incentive for some workers to continue working
                   or return to the labour force. It also identified that allowing some income
                   to be earned could help support some of the most financially vulnerable
                   workers, such as employees and self-employed workers whose hours or
                   volume of work, or both, had been significantly reduced because of the
                   COVID-19 pandemic. We found that the department analyzed possible
                   options before it expanded the benefit eligibility on 15 April 2020. This
                   change both included more workers and encouraged people to keep
                   working by allowing workers to earn up to $1,000 a month while receiving
                   the benefit.


8   |   Report 6             Reports of the Auditor General of Canada to the Parliament of Canada—2021
                            6.35 We also found that, to identify possible adjustments, Employment
                            and Social Development Canada monitored and analyzed the benefit
                            after accepting applications and delivering the benefit. In late May 2020,
                            the department analyzed benefit recipient and economic forecasting
                            data. The analysis showed that the number of benefit recipients
                            remained high because of the pandemic, and it estimated that millions
                            of workers would continue to be ineligible for the regular Employment
                            Insurance program and still be in need of financial support. On the
                            basis of this analysis, the department developed options to continue to
                            support workers affected by the pandemic. Ultimately, the Government
                            of Canada extended the benefit twice. It was extended from 16 weeks
                            to 24 weeks on 26 June 2020, and to 28 weeks on 28 August 2020.

                            6.36 We found that, as the benefit was being delivered, the Department
                            of Finance Canada performed analysis to inform the Minister of Finance
                            on proposed changes to the benefit in light of the evolving crisis and
                            economic recovery. For example, the department’s analysis included
                               • the impact on certain sectors and the labour supply, including
                                 current and projected labour market conditions
                               • the ongoing impact on the incentive to return to work
                               • the interaction between the Canada Emergency Response Benefit
                                 and the Canada Emergency Wage Subsidy

                            6.37 We also found that, as the benefit was being delivered,
                            the Department of Finance Canada and Employment and Social
                            Development Canada considered gender-based analysis plus to
                                                                         2




                            assess how Canadian workers were being supported by the benefit. The
                            departments considered recipient data through different demographic
                            profiles, such as age, occupation type, and gender. The Department
                            of Finance Canada also considered the United Nations’ Sustainable
                            Development Goals and how they were related to the emergency nature
                            of the benefit.

                            6.38 We found evidence that, to improve its delivery of the
                            non–Employment Insurance Emergency Response Benefit, the Canada
                            Revenue Agency monitored patterns of incoming applications to
                            identify areas requiring additional pre-payment controls. We found
                            that the Canada Revenue Agency identified and suggested changes




                                Gender-based analysis plus—”An analytical tool to support the development of responsive
                                and inclusive initiatives, including policies, programs, legislation, and services, that are
                                tailored to the different needs and experiences of various groups of people.…The ‘plus’
                                highlights that all dimensions of diversity and their interactions must be considered as
                                part of a rigorous and intersectional [gender-based analysis] plus, including age, disability,
                                indigeneity, economic status, education, ethnicity, geographical location, gender,
                                language, race, sex, and sexual orientation.”

                                Source: Women and Gender Equality Canada



Canada Emergency Response Benefit                                                                              Report 6    |     9
                            to Employment and Social Development Canada on the design of the
                            non–Employment Insurance Emergency Response Benefit.


 Quick delivery of the benefit influenced the approach to controls

 What we found

                            6.39 We found that Employment and Social Development Canada and
                            the Canada Revenue Agency focused on delivering the benefit quickly to
                            help workers who had lost income as a result of the COVID-19 pandemic.
                            Both organizations understood the risks of emphasizing quick delivery
                            instead of their usual approaches to validating eligibility, which includes
                            more controls.

                            6.40 We found that, once the benefit was rolled out, both the
                            department and the agency introduced additional pre-payment controls
                            to stop payments to ineligible applicants in order to limit potential abuse.
                            We found, however, that given the information available to the Canada
                            Revenue Agency, it could have introduced a control related to suspicious
                            applications at the launch of the benefit.

                            6.41 We found that Employment and Social Development Canada and
                            the Canada Revenue Agency planned to start most of the post-payment
                            verification in the 2021–22 fiscal year.

                            6.42 The analysis supporting this finding discusses the following topics:
                              • Initial focus on expediting payments
                              • Some additional pre-payment controls introduced
                              • Most post-payment verification to begin in the 2021–22 fiscal year

 Why this finding matters

                            6.43 This finding matters because a benefit with reduced pre-payment
                            controls requires well-designed post-payment controls to ensure that
                            only eligible applicants received financial support.

 Context

                            6.44 From the outset of the pandemic, the government set out to get the
                            benefit to eligible workers as quickly as possible. The government also
                            emphasized the good faith of applicants.

                            6.45 With the direction to deliver the benefit quickly, Employment and
                            Social Development Canada and the Canada Revenue Agency were
                            responsible for determining the required applicant information. They
                            were also responsible for determining the controls that would be put in
                            place both before a payment was issued (pre-payment controls) and
                            after (post-payment verification).



10   |   Report 6                     Reports of the Auditor General of Canada to the Parliament of Canada—2021
                            6.46 The volume of applications also had to be considered when
                            assessing the feasibility of using existing processes. According
                            to publicly available government data, more than 6 million Canada
                            Emergency Response Benefit and other Employment Insurance
                            applications were received between 15 March and 19 April 2020.

                            6.47 Although Employment and Social Development Canada was
                            responsible for the benefit’s design, the department and the Canada
                            Revenue Agency collaborated to assess the risks and design controls
                            to mitigate them. Each entity leveraged its own existing systems and
                            processes. The department was responsible for designing and putting
                            in place controls for the Employment Insurance Emergency Response
                            Benefit. The agency was responsible for designing and putting in place
                            controls for the non–Employment Insurance Emergency Response
                            Benefit.

                            6.48 According to the International Public Sector Fraud Forum, the
                            ability to implement pre-payment controls is limited in an emergency.
                            Therefore, it is important that post-payment verification work be planned
                            for and carried out to uphold the stewardship of public funds.

Recommendations

                            6.49 Our recommendations in this area of examination appear at
                            paragraphs 6.64 and 6.65.

Analysis to support
this finding

                            Initial focus on expediting payments

                            6.50 We found that, to deliver the benefit quickly, both Employment and
                            Social Development Canada and the Canada Revenue Agency took the
                            approach of relying on applicants’ attestations to assess eligibility for the
                            Canada Emergency Response Benefit. Applicants were to confirm that
                            they did not quit their jobs voluntarily and that they had stopped working
                            because of the COVID-19 pandemic. The use of attestations rather
                            than documentation made the Canada Emergency Response Benefit
                            application process different from that of non‑emergency benefits. For
                            example, applicants were not required to provide a record of employment
                            to confirm details of their employment and the reason for their job loss,
                            or a medical note. According to Employment and Social Development
                            Canada, if the standard pre-payment measures that are used to validate
                            Employment Insurance applicants’ eligibility had been applied for this
                            benefit, it would have taken months to process and issue payments.

                            6.51 According to Employment and Social Development Canada, the use
                            of attestations simplified the process for applicants. Furthermore, not
                            having to provide documentation when applying allowed people to stay
                            home, which followed public health advice.



Canada Emergency Response Benefit                                                            Report 6   |   11
                    6.52 We found that both Employment and Social Development Canada
                    and the Canada Revenue Agency relied on automated pre-payment
                    controls that were possible in their existing information technology
                    systems to validate eligibility quickly. Before issuing benefit payments,
                    both organizations had a control to confirm that the applicant had a
                    valid Social Insurance Number. The department also had a control to
                    confirm that the applicant was not deceased. The agency had a control
                    to confirm that the applicant was not deceased, was at least 15 years of
                    age, and was not in a federal correctional facility.

                    6.53 We found that, by using attestations and limiting the number of
                    pre-payment controls to validate eligibility, Employment and Social
                    Development Canada and the Canada Revenue Agency were aware
                    that some payments would be issued to applicants who were not
                    entitled to the benefit. This included potential cases of intentional
                    misrepresentation. Accepting risks in order to expedite payments
                    to those in need is consistent with best practices promoted by the
                    International Public Sector Fraud Forum and its Principles of Fraud
                    Control in Emergency Management.

                    Some additional pre-payment controls introduced

                    6.54 We found that, to prevent benefit payments from being issued to
                    ineligible applicants, Employment and Social Development Canada and
                    the Canada Revenue Agency introduced some additional pre‑payment
                    controls as the benefit was being delivered to limit potential abuse.
                    Below are examples of pre-payment controls introduced by the
                    department and the agency that were intended to help prevent access to
                    multiple benefits and to identify suspicious applications.

                    6.55 Both the department and the agency understood that there was a
                    risk that an individual could apply for both the Employment Insurance
                    Emergency Response Benefit and the non–Employment Insurance
                    Emergency Response Benefit. We found that Employment and Social
                    Development Canada and the Canada Revenue Agency acted quickly to
                    reduce the risk that workers would receive payments for both benefits.
                    Information on applicants was shared between the department and
                    the agency as of mid-April 2020, about a week after the benefits
                    were launched. A control was introduced by the organizations to stop
                    payments to an applicant when the applicant had already received the
                    other benefit. However, some people applied for and received payments
                    from both benefits before this control was introduced. According to the
                    department and the agency, this represented approximately $500 million
                    in Canada Emergency Response Benefit payments. This represented
                    less than 1% of the total amount in payments made for the benefit. In
                    our view, given the significance of this figure, it will be critical that the
                    organizations conduct rigorous post-payment verification work in this
                    area.




12   |   Report 6              Reports of the Auditor General of Canada to the Parliament of Canada—2021
                            6.56 We also found that when the Canada Revenue Agency launched
                            the Canada Emergency Student Benefit, it designed controls to prevent
                            an applicant from receiving payments from both that benefit and the
                            Canada Emergency Response Benefit for the same period. The Canada
                            Emergency Student Benefit provided financial support to post-secondary
                            students and recent post-secondary and high school graduates who
                            were unable to find work because of the COVID-19 pandemic.

                            6.57 We found that when applicants were blocked by the Canada
                            Revenue Agency because of suspicious information on their applications,
                            they were prompted to call the agency and provide the required
                            documentation in order for their applications to proceed. The agency
                            then reviewed the documentation provided by applicants to determine
                            whether they satisfied the eligibility criteria. According to the agency,
                            as of 20 December 2020, of the approximately 141,000 individuals who
                            contacted the agency about their applications, only 11% were actually
                            eligible for the non–Employment Insurance Emergency Response
                            Benefit.

                            6.58 We found that Employment and Social Development Canada
                            developed risk scenarios to identify and detect high-risk Employment
                            Insurance Emergency Response Benefit applicants. Starting in mid‑May,
                            applications that matched these scenarios were reviewed and, where
                            there were reasonable grounds to believe they were fraudulent,
                            payments were stopped. According to limited information provided by
                            the department, as of 30 November 2020, payments were stopped for
                            more than 30,000 potentially fraudulent applications. This represented
                            approximately $42 million.

                            6.59 We found that, on 11 May 2020, the Canada Revenue Agency
                            introduced an automated control to compare new applicants for
                            the non–Employment Insurance Emergency Response Benefit with
                            information it had already collected from other programs on high-risk
                            indicators, such as suspicious individuals. When applications matched
                            these indicators, the control was designed to block the applications from
                            going forward. Given that this information predated the benefit, we would
                            have expected this control to have been introduced at the launch of the
                            benefit. Agency officials informed us that introducing this control earlier
                            would have meant delaying the launch of the benefit.

                            Most post-payment verification to begin in the 2021–22 fiscal year

                            6.60 With the decision to rely on personal attestations, post‑payment
                            verification became very important. We found that, early on, Employment
                            and Social Development Canada and the Canada Revenue Agency
                            worked together to develop an approach to identifying risks and
                            implementing related controls. This approach identified post-payment
                            verification measures that would be carried out, but it did not identify
                            when this work would be completed or the resources required to do so.
                            Further, it identified that some post-payment verification work for the


Canada Emergency Response Benefit                                                          Report 6   |   13
                    Canada Emergency Response Benefit required income tax data, which
                    would be available in spring 2021.

                    6.61 We found that Employment and Social Development Canada
                    subsequently developed a 4-year post-payment verification plan. The
                    plan was expected to start in the 2021–22 fiscal year. The plan
                      • prioritizes the types of cases that will be examined by the
                        department
                      • identifies the number of cases that will be completed each year
                      • identifies the resources required to complete the reviews and
                        investigations

                    6.62 At the time of our audit, the department was pursuing work related
                    to post-payment verification and collection of ineligible payments under
                    interim orders issued pursuant to the Employment Insurance Act. When
                    these interim orders cease to apply in September 2021, the department
                    will not be able to use its current process for the collection of ineligible
                    payments from recipients.

                    6.63 We found that the Canada Revenue Agency also developed
                    several post-payment verification plans that included verification work
                    until March 2023. However, it was unclear to what extent the plans
                    would address risks directly related to the non–Employment Insurance
                    Emergency Response Benefit. This was because these plans were still in
                    draft form and included several other emergency benefits in addition to
                    the non–Employment Insurance Emergency Response Benefit.

                    6.64 Recommendation. Employment and Social Development Canada
                    and the Canada Revenue Agency should finalize and implement their
                    plans for the Canada Emergency Response Benefit post-payment
                    verification work.

                    The department’s response. Agreed. Throughout the pandemic,
                    Employment and Social Development Canada engaged in robust and
                    proactive planning for post-payment integrity action on Employment
                    Insurance Emergency Response Benefit claims. Following confirmation of
                    funding in the Fall Economic Statement 2020, the department developed
                    a comprehensive 4-year operational plan for post-payment integrity
                    activities and has begun execution of cases of serious fraud.

                    Integrity activities are underway and will continue as per the 4‑year
                    operational plan. The plan will be refined on a regular basis as the
                    department gains experience and knowledge from its investigations and
                    ensures that it remains responsive to the continued pandemic context
                    while maintaining alignment with the Canada Revenue Agency.




14   |   Report 6             Reports of the Auditor General of Canada to the Parliament of Canada—2021
                            The agency’s response. Agreed. The Canada Revenue Agency has
                            been working in partnership with Employment and Social Development
                            Canada to align post-payment compliance activities. The post-payment
                            compliance plan has always been present but remains evergreen because
                            of the shifting economic and public health landscape.

                            The agency’s verification work will be largely supported by data and
                            systems that will become available during the upcoming tax‑filing season.
                            It is important that our risk assessments include 2020 tax data to calibrate
                            our verifications using current data. This will help avoid unnecessary
                            reviews of recipients that may in fact have been eligible to receive benefit
                            payments or may have already completed voluntary repayments, or both.
                            Post‑compliance work will commence in September 2021 and is expected
                            to continue until March 2023.

                            6.65 Recommendation. Employment and Social Development Canada
                            and the Canada Revenue Agency should conduct a formal assessment of
                            the delivery of the Canada Emergency Response Benefit in order to apply
                            the findings to the design and delivery of future government emergency
                            response and recovery benefits.

                            The department’s response. Agreed. The Canada Emergency Response
                            Benefit was implemented to protect Canadians and the economy from the
                            impact of the global COVID-19 pandemic, but the lessons learned could
                            have broader application to future benefit program design and delivery.

                            Employment and Social Development Canada agrees that a formal
                            assessment of the delivery of the Canada Emergency Response Benefit
                            will inform the design and development of future emergency response
                            benefits.

                            The agency’s response. Agreed. The Canada Revenue Agency will
                            conduct a formal assessment of the delivery of the Canada Emergency
                            Response Benefit (from 15 March to 31 December 2020) to identify best
                            practices and lessons learned and to determine whether functionality and
                            processes can be reused in a future crisis.

                            The findings from this exercise will be available by 31 December 2021
                            to assist government in the design and delivery of future government
                            emergency response and recovery programs.




Canada Emergency Response Benefit                                                           Report 6   |   15
 Conclusion
                    6.66 We concluded that, despite not having the usual time required to
                    perform analysis for the design of a new benefit, Employment and Social
                    Development Canada and the Department of Finance Canada considered
                    and conducted analysis in key areas as part of the initial design and
                    subsequent adjustments to the Canada Emergency Response Benefit.

                    6.67 Further, given the crisis presented by the COVID-19 pandemic,
                    Employment and Social Development Canada and the Canada Revenue
                    Agency took the approach of relying on personal attestations and
                    automated pre-payment controls so that the Canada Emergency
                    Response Benefit would be issued quickly to eligible workers who
                    lost income because of the COVID-19 pandemic. Once the benefit
                    was launched, the department and the agency introduced additional
                    pre‑payment controls to limit potential abuse of the benefit. The need for
                    post-payment verification increased given this approach. Employment
                    and Social Development Canada and the Canada Revenue Agency
                    developed plans to conduct post-payment work.




16   |   Report 6             Reports of the Auditor General of Canada to the Parliament of Canada—2021
About the Audit
This independent assurance report was prepared by the Office of the Auditor General of Canada on
the Canada Emergency Response Benefit. Our responsibility was to provide objective information,
advice, and assurance to assist Parliament in its scrutiny of the government’s management
of resources and programs, and to conclude on whether the design of the Canada Emergency
Response Benefit complied in all significant respects with the applicable criteria.

All work in this audit was performed to a reasonable level of assurance in accordance with the
Canadian Standard on Assurance Engagements (CSAE) 3001—Direct Engagements, set out by
the Chartered Professional Accountants of Canada (CPA Canada) in the CPA Canada Handbook—
Assurance.

The Office of the Auditor General of Canada applies the Canadian Standard on Quality Control 1
and, accordingly, maintains a comprehensive system of quality control, including documented
policies and procedures regarding compliance with ethical requirements, professional standards,
and applicable legal and regulatory requirements.

In conducting the audit work, we complied with the independence and other ethical requirements of
the relevant rules of professional conduct applicable to the practice of public accounting in Canada,
which are founded on fundamental principles of integrity, objectivity, professional competence and
due care, confidentiality, and professional behaviour.

In accordance with our regular audit process, we obtained the following from entity management:
  • confirmation of management’s responsibility for the subject under audit
  • acknowledgement of the suitability of the criteria used in the audit
  • confirmation that all known information that has been requested, or that could affect the
    findings or audit conclusion, has been provided
  • confirmation that the audit report is factually accurate


Audit objective

The objective of this audit was to determine whether
  • Employment and Social Development Canada and the Department of Finance Canada provided
    analysis to support the initial design and subsequent adjustments to the Canada Emergency
    Response Benefit
  • Employment and Social Development Canada and the Canada Revenue Agency designed
    mechanisms so that the Canada Emergency Response Benefit would support eligible workers
    who suffered a loss of income for reasons related to COVID-19, including limiting abuse of the
    benefit




Canada Emergency Response Benefit                                                         Report 6   |   17
 Scope and approach

 The audit focused on the design of the Canada Emergency Response Benefit.

 The audit examined the analysis carried out by Employment and Social Development Canada in
 the design of the Canada Emergency Response Benefit, as well as the analysis carried out by the
 Department of Finance Canada to support and contribute to its design. It examined the analysis
 related to the initial design of the Canada Emergency Response Benefit, as well as changes
 considered to the benefit in light of
     • the interaction with other COVID-19 programs, as required
     • the evolution of the broader health crisis and economic situation
     • monitoring activities by Employment and Social Development Canada and the Canada Revenue
       Agency

 The audit also examined the mechanisms designed and put in place by Employment and Social
 Development Canada and the Canada Revenue Agency to provide eligible recipients with the
 amount of money they were entitled to under the Canada Emergency Response Benefit, in
 coordination with other COVID-19 programs. This included
     • controls to assess and validate eligibility
     • controls to manage the Canada Emergency Response Benefit with other COVID-19 programs
     • mechanisms to mitigate identified vulnerabilities, including cases of suspected fraud, or
       changes made to the Canada Emergency Response Benefit, or both

 The audit did not assess the controls mentioned in this report. The implementation of post‑payment
 verification mechanisms will be the subject of a future audit. The audit did not examine the
 collection or recovery work related to the benefit.

 As part of this audit, our work conducted on the United Nations’ Sustainable Development Goals
 was limited to reviewing documentation to determine whether the goals were considered as the
 benefit was being designed and delivered.




18   |   Report 6                        Reports of the Auditor General of Canada to the Parliament of Canada—2021
Criteria

                      Criteria                                             Sources

 We used the following criteria to determine whether
 •  Employment and Social Development Canada and the Department of Finance Canada provided
    analysis to support the initial design and subsequent adjustments to the Canada Emergency
    Response Benefit
 •   Employment and Social Development Canada and the Canada Revenue Agency designed
     mechanisms so that the Canada Emergency Response Benefit would support eligible workers who
     suffered a loss of income for reasons related to COVID-19, including limiting abuse of the benefit

 Employment and Social Development Canada             • Canada Emergency Response Benefit Act
 performs analysis that supports the design of
                                                      • Policy on Financial Management, Treasury Board
 the Canada Emergency Response Benefit and
 that considers efficiency and risk management.       • Management Accountability Framework, Treasury
                                                        Board of Canada Secretariat
                                                      • Correspondence from the Secretary of the
                                                        Treasury Board to Deputy Heads, 19 March 2020
                                                      • Transforming our world: the 2030 Agenda for
                                                        Sustainable Development, United Nations, 2015

 Employment and Social Development Canada             • Policy on Financial Management, Treasury Board
 and the Canada Revenue Agency design and put
                                                      • Management Accountability Framework, Treasury
 in place mechanisms for the Canada Emergency
                                                        Board of Canada Secretariat
 Response Benefit to provide eligible recipients
 with the amount of money they are entitled to, in    • COVID-19 Emergency Response Act
 coordination with other COVID-19 programs, and
                                                      • Canada Emergency Response Benefit Act
 make necessary adjustments in a timely manner.
                                                      • Employment Insurance Act
                                                      • Letter of Authority, Canada Revenue Agency,
                                                        3 April 2020
                                                      • Memorandum of Understanding for the
                                                        Administration of the COVID‑19 Emergency
                                                        Benefits, between the Canada Revenue Agency
                                                        and Economic and Social Development Canada
                                                      • Correspondence from the Secretary of the
                                                        Treasury Board to Deputy Heads, 19 March 2020
                                                      • Transforming our world: the 2030 Agenda for
                                                        Sustainable Development, United Nations, 2015




Canada Emergency Response Benefit                                                              Report 6   |   19
                             Criteria                                                Sources

     We used the following criteria to determine whether
     •  Employment and Social Development Canada and the Department of Finance Canada provided
        analysis to support the initial design and subsequent adjustments to the Canada Emergency
        Response Benefit
     •       Employment and Social Development Canada and the Canada Revenue Agency designed
             mechanisms so that the Canada Emergency Response Benefit would support eligible workers who
             suffered a loss of income for reasons related to COVID-19, including limiting abuse of the benefit

     Employment and Social Development Canada                 • Policy on Financial Management, Treasury Board
     and the Canada Revenue Agency monitor the use
                                                              • Management Accountability Framework, Treasury
     of the Canada Emergency Response Benefit to
                                                                Board of Canada Secretariat
     identify opportunities for ongoing improvement
     to its design and make recommendations to                • Letter of Authority, Canada Revenue Agency,
     inform decision making.                                    3 April 2020
                                                              • Memorandum of Understanding for the
                                                                Administration of the COVID-19 Emergency
                                                                Benefits, between the Canada Revenue Agency
                                                                and Economic and Social Development Canada
                                                              • Correspondence from the Secretary of the
                                                                Treasury Board to Deputy Heads, 19 March 2020
                                                              • Transforming our world: the 2030 Agenda for
                                                                Sustainable Development, United Nations, 2015

     The Department of Finance Canada performs                • Policy on Financial Management, Treasury Board
     analysis that supports the design of the
                                                              • Management Accountability Framework, Treasury
     Canadian Emergency Response Benefit and
                                                                Board of Canada Secretariat
     that considers efficiency, risk management, and
     potential changes to the benefit in light of the         • 2020–21 Departmental Plan, Department of
     evolving crisis and recovery.                              Finance Canada
                                                              • Correspondence from the Secretary of the
                                                                Treasury Board to Deputy Heads, 19 March 2020
                                                              • Minister of Middle Class Prosperity and Associate
                                                                Minister of Finance Mandate Letter, 2019
                                                              • Transforming our world: the 2030 Agenda for
                                                                Sustainable Development, United Nations, 2015




20       |   Report 6                          Reports of the Auditor General of Canada to the Parliament of Canada—2021
Period covered by the audit

The audit covered the period from 1 March 2020 to 10 January 2021. This is the period to which the
audit conclusion applies.


Date of the report

We obtained sufficient and appropriate audit evidence on which to base our conclusion on
11 March 2021, in Ottawa, Canada.


Audit team

Principal: Jo Ann Schwartz
Director: Steven Mariani
Director: Robyn Roy

Donna Ardelean
Cassandra Bishop
Theresa Crossan
Shawn Hamilton
Sean MacLennan




Canada Emergency Response Benefit                                                      Report 6   |   21
 List of Recommendations
 The following table lists the recommendations and responses found in this report. The paragraph
 number preceding the recommendation indicates the location of the recommendation in the report,
 and the numbers in parentheses indicate the location of the related discussion.


                     Recommendation                                              Response

     Designing an emergency response benefit

     6.64 Employment and Social Development                The department’s response. Agreed. Throughout
     Canada and the Canada Revenue Agency should           the pandemic, Employment and Social
     finalize and implement their plans for the Canada     Development Canada engaged in robust and
     Emergency Response Benefit post‑payment               proactive planning for post-payment integrity
     verification work. (6.50–6.63)                        action on Employment Insurance Emergency
                                                           Response Benefit claims. Following confirmation
                                                           of funding in the Fall Economic Statement 2020,
                                                           the department developed a comprehensive
                                                           4‑year operational plan for post-payment integrity
                                                           activities and has begun execution of cases of
                                                           serious fraud.

                                                           Integrity activities are underway and will continue
                                                           as per the 4‑year operational plan. The plan will be
                                                           refined on a regular basis as the department gains
                                                           experience and knowledge from its investigations
                                                           and ensures that it remains responsive to the
                                                           continued pandemic context while maintaining
                                                           alignment with the Canada Revenue Agency.
                                                           The agency’s response. Agreed. The Canada
                                                           Revenue Agency has been working in partnership
                                                           with Employment and Social Development Canada
                                                           to align post-payment compliance activities. The
                                                           post-payment compliance plan has always been
                                                           present but remains evergreen because of the
                                                           shifting economic and public health landscape.

                                                           The agency’s verification work will be largely
                                                           supported by data and systems that will become
                                                           available during the upcoming tax‑filing season.
                                                           It is important that our risk assessments include
                                                           2020 tax data to calibrate our verifications using
                                                           current data. This will help avoid unnecessary
                                                           reviews of recipients that may in fact have been
                                                           eligible to receive benefit payments or may have
                                                           already completed voluntary repayments, or
                                                           both. Post‑compliance work will commence in
                                                           September 2021 and is expected to continue until
                                                           March 2023.




22   |   Report 6                          Reports of the Auditor General of Canada to the Parliament of Canada—2021
                 Recommendation                                          Response

 6.65 Employment and Social Development             The department’s response. Agreed. The Canada
 Canada and the Canada Revenue Agency should        Emergency Response Benefit was implemented
 conduct a formal assessment of the delivery of     to protect Canadians and the economy from the
 the Canada Emergency Response Benefit in order     impact of the global COVID-19 pandemic, but the
 to apply the findings to the design and delivery   lessons learned could have broader application to
 of future government emergency response and        future benefit program design and delivery.
 recovery benefits. (6.26–6.38, 6.50–6.63)
                                                    Employment and Social Development Canada
                                                    agrees that a formal assessment of the delivery
                                                    of the Canada Emergency Response Benefit will
                                                    inform the design and development of future
                                                    emergency response benefits.
                                                    The agency’s response. Agreed. The Canada
                                                    Revenue Agency will conduct a formal assessment
                                                    of the delivery of the Canada Emergency Response
                                                    Benefit (from 15 March to 31 December 2020) to
                                                    identify best practices and lessons learned and
                                                    to determine whether functionality and processes
                                                    can be reused in a future crisis.

                                                    The findings from this exercise will be available
                                                    by 31 December 2021 to assist government in
                                                    the design and delivery of future government
                                                    emergency response and recovery programs.




Canada Emergency Response Benefit                                                            Report 6   |   23


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