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Specific COVID-19 Benefits — Report 10, Reports of the Auditor General of Canada (2022)

Summary

Report 10 of the 2022 Reports of the Auditor General of Canada to the Parliament of Canada audits Specific COVID-19 Benefits, as required by An Act to provide further support in response to COVID-19, which received royal assent on 17 December 2021. The audit covers the Canada Worker Lockdown Benefit, Canada Recovery Benefit, Canada Recovery Sickness Benefit, Canada Recovery Caregiving Benefit, Canada Emergency Response Benefit and Canada Emergency Wage Subsidy. The report says the programs quickly offered financial relief, but the limited pre-payment controls resulted in $4.6 billion of overpayments to ineligible recipients of benefits for individuals, and at least $27.4 billion of payments to individuals and employers should be investigated further. It says approximately $2.3 billion had been recuperated and shows total payments of $210,727 million.

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Full text

                                 COVID-19
                                 PANDEMIC
                                 REPORT 10

                                 Specific COVID-19 Benefits
2022
Reports of the Auditor General
of Canada to the
Parliament of Canada
                                 Independent Auditor’s Report
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.
© His Majesty the King in Right of Canada, as represented by the Auditor General of Canada, 2022.
Icons for United Nations’ Sustainable Development Goals are used with permission.
The content of this publication has not been approved by the United Nations and does not reflect the views of the United
Nations or its officials.
https://www.un.org/sustainabledevelopment/
Cat. No. FA1-27/2022-1-10E-PDF
ISBN 978-0-660-46281-3
ISSN 2561-343X




Cover photo: Banana Oil/Shutterstock.com and Andrey_Popov/Shutterstock.com
Table of Contents

Part 1—Key Findings                                                                                                                                   1
Introduction                                                                                                                                           1
Background. ...........................................................................................................................................1

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

Findings and Recommendations                                                                                                                           4
Outcomes and effectiveness. .................................................................................................................5
     COVID‑19 programs supported Canada’s economic recovery. ................................................................. 7
     COVID‑19 benefits went to people and employers in the economic sectors
     most impacted by the pandemic................................................................................................................ 11
     Employment and Social Development Canada adjusted benefit programs
     to try to address disincentives to work...................................................................................................... 16

Program delivery and controls..............................................................................................................18
     The trade‑off between expediency and confirming eligibility resulted
     in payments to ineligible recipients. .......................................................................................................... 19

Post‑payment verification and collection..............................................................................................25
     Employment and Social Development Canada and the Canada Revenue Agency
     were planning to do few post‑payment verifications. .............................................................................. 25
     The Canada Revenue Agency performed limited collection activities on COVID‑19 programs............ 30

Conclusion                                                                                                                                            33


Reports of the Auditor General of Canada                                                                                           Report 10      |    iii
to the Parliament of Canada—2022
Part 2—Additional Information and Findings on Specific COVID-19
Programs                                                                  35
A—Canada Emergency Response Benefit                                           35

B—Canada Recovery Benefit                                                     45

C—Canada Recovery Caregiving Benefit                                          52

D—Canada Recovery Sickness Benefit                                            59

E—Canada Worker Lockdown Benefit                                              66

F—Canada Emergency Wage Subsidy                                               74

About the Audit                                                               82

Recommendations and Responses                                                 86




Reports of the Auditor General of Canada                      Report 10   |    iv
to the Parliament of Canada—2022
                                                                                   Specific COVID-19 Benefits



Part 1—Key Findings

Introduction

Background

Responding to the
COVID‑19 pandemic

                               10.1     In March 2020, Canada faced the global coronavirus disease
                               (COVID‑19) pandemic. To protect Canada’s population and help prevent
                               the spread of the disease, all levels of government asked Canadians
                               to isolate and many employers in Canada to close their doors to
                               face‑to‑face services or to adopt a work‑from‑home model when
                               possible. These prevention efforts resulted in business closures and
                               slowdowns, which led to reduced working hours or unemployment for
                               many Canadians.

                               10.2     To minimize the impacts of the COVID‑19 pandemic on
                               the health of Canada’s population, businesses, and economy, the
                               Government of Canada announced emergency income support
                               programs for Canadian residents and employers in Canada. The federal
                               public service was mandated to develop, implement, and deliver the
                               new COVID‑19 benefit programs, which were unprecedented in size and
                               urgency. Federal organizations responded by relying on their existing
                               systems and processes, which were repurposed to deliver the new
                               COVID‑19 benefit programs. Within weeks, many programs were up and
                               running. Historically, programs of this size would have taken months, if
                               not years, to roll out.

                               10.3     Like all Canadians and Canadian businesses, the federal public
                               service delivering the COVID‑19 benefit programs had to overcome
                               its own pandemic challenges. For example, federal workplaces had to
                               adjust operations to have hundreds of thousands of employees switch
                               quickly to working from home while continuing to deliver all other
                               programs and services that are part of regular government operations.

                               10.4     The original programs were expected to last only a few
                               months. However, additional waves of the pandemic occurred, and
                               the government extended existing programs and introduced new
                               support programs. This, in turn, necessitated flexibility and changes
                               to program plans, as benefit payments were made well into 2022. For
                               benefits to individuals, recipients could receive only 1 COVID‑19 benefit
                               per period, while employers had access to multiple emergency relief
                               programs simultaneously.



Reports of the Auditor General of Canada                                                     Report 10   |   1
to the Parliament of Canada—2022
                                                                                   Specific COVID-19 Benefits


                               10.5      To simplify and accelerate the application process for
                               COVID‑19 benefits, both Employment and Social Development Canada
                               and the Canada Revenue Agency—the federal organizations delivering
                               the programs—relied on applicants’ attestations of eligibility. This
                               allowed the government to meet 1 of its goals to quickly get financial
                               support into the hands of those affected by the pandemic. In so doing,
                               the government accepted the risk that some recipients might not be
                               eligible for benefits received. Some pre‑payment controls were built into
                               program designs to confirm eligibility. However, the department and
                               agency made an early decision to put more effort into reviewing eligibility
                               after payments were issued and recovering overpayments or payments
                               to ineligible recipients.

Previous audit work and
a new act

                               10.6     The Office of the Auditor General of Canada has conducted
                               numerous performance audits related to COVID‑19, including 2 audit
                               reports in spring 2021 on specific benefit programs: Report 6—Canada
                               Emergency Response Benefit and Report 7—Canada Emergency
                               Wage Subsidy.

                               10.7      On 17 December 2021, An Act to provide further support in
                               response to COVID‑19, also known as Bill C‑2, received royal assent.
                               This act served to extend or create specific benefits and programs
                               related to COVID‑19. The act also required that the Office of the
                               Auditor General of Canada complete a performance audit of specific
                               COVID‑19 benefits during the first year after Bill C‑2 came into force, so
                               no later than 17 December 2022, and submit a report to the Speaker of
                               the House.

                               10.8   As required by the act, we audited the following
                               COVID‑19 benefit programs for individuals:
                                  • Canada Worker Lockdown Benefit
                                  • Canada Recovery Benefit
                                  • Canada Recovery Sickness Benefit
                                  • Canada Recovery Caregiving Benefit
                                  • Canada Emergency Response Benefit, including the Employment
                                    Insurance Emergency Response Benefit

                               10.9   We also audited, as required by the act, the following
                               COVID‑19 program for employers:
                                  • Canada Emergency Wage Subsidy

                               10.10  Additional information and some of our findings on each
                               program are provided in Part 2 of this report.




Reports of the Auditor General of Canada                                                     Report 10   |   2
to the Parliament of Canada—2022
                                                                                   Specific COVID-19 Benefits


Roles and
responsibilities

                               10.11   Employment and Social Development Canada. The department
                               is responsible for
                                  • policy development and program design of the COVID‑19 benefits
                                    for individuals
                                  • administration of the Employment Insurance Emergency Response
                                    Benefit, including accepting applications, verifying and validating
                                    the eligibility of applicants, authorizing payments, and preventing
                                    non‑compliance

                               10.12       The Canada Revenue Agency. The agency is responsible for
                                  • administration, on behalf of Employment and Social Development
                                    Canada, of the other COVID‑19 benefit programs for individuals and
                                    the Canada Emergency Wage Subsidy, which included accepting
                                    applications, verifying and validating the eligibility of applicants,
                                    authorizing payments, and preventing non‑compliance
                                  • collection of overpayments and payments made to ineligible
                                    recipients for all benefit programs for individuals and employers


Focus of the audit
                               10.13  This audit focused on whether Employment and Social
                               Development Canada and the Canada Revenue Agency
                                  • ensured that COVID‑19 benefit payments were accurate and paid to
                                    eligible applicants
                                  • undertook timely procedures to recover overpayments and
                                    payments made to ineligible recipients

                               The audit also focused on whether the department and the agency
                                  • managed the COVID‑19 programs efficiently
                                  • measured their administrative effectiveness

                               Finally, the audit examined whether the programs achieved their
                               objectives and provided value‑for‑money outcomes.

                               10.14     More details about the audit objective, scope, approach, and
                               criteria are in About the Audit at the end of this report.




Reports of the Auditor General of Canada                                                     Report 10   |   3
to the Parliament of Canada—2022
                                                                                       Specific COVID-19 Benefits



Findings and Recommendations
Overall message

                               10.15     With its response to the COVID‑19 pandemic, the Government of
                               Canada set an objective of helping Canadians as quickly as possible. The
                               COVID‑19 emergency programs that we audited achieved that objective.
                               They quickly offered financial relief to individuals and employers, prevented
                               a rise in poverty, mitigated income inequalities, and helped the economy to
                               recover from the effects of the pandemic.

                               10.16    To expedite issuing payments, the Canada Revenue Agency
                               and Employment and Social Development Canada relied on personal
                               attestations. They decided early on to focus less on confirming the eligibility
                               of applicants up front and more on reviewing eligibility after payments
                               were issued and recovering overpayments or payments made to ineligible
                               recipients. The risk that some recipients might not be eligible for benefits
                               they received made verifying eligibility after payment all the more important.

                               10.17     We found that the department and agency’s approach to limit
                               pre-payment controls, as well as the lack of timely data at the time of
                               application, resulted in a significant amount of payments made to recipients
                               who were ineligible or whose eligibility needs to be verified. We found
                               $4.6 billion of overpayments made to ineligible recipients of benefits for
                               individuals. In addition, we estimated that at least $27.4 billion of payments
                               to individuals and employers should be investigated further. A more
                               definitive estimate of payments made to ineligible recipients and amounts
                               to be recovered by the government will be determined only after the agency
                               and the department have completed their post-payment verifications.

                               10.18     The department and agency did not develop rigorous and
                               comprehensive plans to verify the eligibility of recipients. We found that their
                               post‑payment verification plans did not include verifying payments made
                               to all identified recipients at risk of being ineligible for all COVID‑19 benefit
                               programs. Given the limited pre‑payment controls and the early decision
                               to focus on post‑payment verifications, we expected the department and
                               the agency to perform extensive post‑payment verifications to identify
                               payments made to ineligible recipients.

                               10.19     There have also been delays in conducting post‑payment
                               verifications and the collection of amounts owing has just started.
                               The department and agency are at risk of not completing all planned
                               post‑payment verifications within the applicable timelines. This means they
                               may be unable to identify and recover amounts owing. According to the
                               information provided by the department and agency, they have recuperated
                               approximately $2.3 billion.




Reports of the Auditor General of Canada                                                         Report 10   |   4
to the Parliament of Canada—2022
                                                                                                  Specific COVID-19 Benefits


Outcomes and effectiveness
Context

                                    10.20 The Government of Canada’s COVID‑19 benefit programs were
                                    put in place to support Canadians and Canadian businesses throughout
                                    the pandemic. Exhibit 10.1 shows when the benefits included in this
                                    audit were available to individuals and employers in Canada, including all
                                    extension periods.

Exhibit 10.1—Periods of availability of COVID-19 benefit programs

                       March 2020   September 2020    October 2020                      October 2021                   May 2022


  Canada Emergency
      Wage Subsidy


  Canada Emergency
  Response Benefit*


   Canada Recovery
   Sickness Benefit

   Canada Recovery
  Caregiving Benefit


   Canada Recovery
           Benefit

     Canada Worker
   Lockdown Benefit


* Includes the Employment Insurance Emergency Response Benefit


                                    10.21 Exhibit 10.2 shows the total benefit payments made to recipients
                                    for each COVID‑19 subsidy and program.

Exhibit 10.2—Payments to recipients for COVID‑19 benefit programs

                       COVID‑19 benefit program                          Total payments at program end (in millions)

 Canada Emergency Wage Subsidy                                                                                     $100,738
 Canada Emergency Response Benefit and Employment                                                                   $74,815
 Insurance Emergency Response Benefit
 Canada Recovery Benefit                                                                                            $28,390
 Canada Recovery Caregiving Benefit                                                                                  $4,370
 Canada Recovery Sickness Benefit                                                                                     $1,500
 Canada Worker Lockdown Benefit                                                                                         $914
 Total                                                                                                             $210,727
Note: Programs ended on different dates, and applications could be submitted for a specific time period once a benefit program
ended. This exhibit reflects all payments made for the Canada Emergency Wage Subsidy up to May 2022 and for each benefit
program for individuals up to July 2022.
Source: The Canada Revenue Agency and Employment and Social Development Canada


Reports of the Auditor General of Canada                                                                      Report 10   |   5
to the Parliament of Canada—2022
                                                                                                                   Specific COVID-19 Benefits


                                        10.22 Exhibit 10.3 provides a simplified overview of the application
                                        process for the COVID‑19 subsidy and benefit programs.

Exhibit 10.3—Simplified COVID-19 benefit application process for individuals and employers

                                                                 Application received




                                                                 Automated system
                                                                pre-payment controls




                          Application automatically           Application identified for           Application rejected as
                                  approved                         manual review                          ineligible




                                                                Application rejected:
                                   Accepted
                                                                  End of process*




                               Payment issued




    No post-payment verification                Post-payment verification




                                Result—adjustment required                  Result—no adjustment



                                    Notification sent to
                                recipient of amount owing*



                                    Collection measures
                                       (if necessary)



                                     Payment recovered




                                       End of process


* If applicant disagrees with decision, a recourse process exists.




Reports of the Auditor General of Canada                                                                                     Report 10   |   6
to the Parliament of Canada—2022
                                                                                  Specific COVID-19 Benefits


COVID‑19 programs supported Canada’s economic recovery

What we found

                               10.23 We found that the COVID‑19 programs achieved their objective
                               to help Canada avoid a more severe contraction of the economy and the
                               social consequences of, for example, a significant increase in poverty.
                               This financial support allowed the economy to rebound and return to its
                               pre‑pandemic level.

                               10.24 The analysis supporting this finding discusses the
                               following topics:
                                  • Economic rebound
                                  • Mitigation of poverty and income inequality

Why this finding matters

                               10.25 This finding matters because it is important that the government
                               demonstrates that the COVID‑19 benefit programs supported Canadians
                               and employers in need.

Context

                               10.26 The objective of the COVID‑19 benefit programs for individuals
                               was to directly support individuals who lost income as a result of the
                               COVID‑19 pandemic. For example, the programs were intended to help
                               affected workers meet their financial obligations while reducing the
                               disease’s toll on individuals and the health care system.

                               10.27 Along with the benefit programs for individuals, the government
                               introduced COVID‑19 support for employers, including the Canada
                               Emergency Wage Subsidy. This program’s objective was to
                                  • help employers retain their employees during the pandemic
                                  • ensure that workers were able to count on a source of income
                                    despite some sectors of the economy being shut down
                                  • encourage employers to rehire workers who were laid off as a result
                                    of the pandemic
                                  • help position employers to resume normal operations more easily
                                    when economic activity fully resumed




Reports of the Auditor General of Canada                                                    Report 10   |   7
to the Parliament of Canada—2022
                                                                                                          Specific COVID-19 Benefits


Analysis to support
this finding

                                      Economic rebound

                                      10.28 Statistics Canada reported that between February and
                                      April 2020, Canada’s gross domestic product1 decreased, after adjusting
                                      for inflation, by $350 billion—a 17% reduction in economic activity. But
                                      by November 2021, 20 months after the beginning of the pandemic,
                                      economic activity was back to its pre‑pandemic level (Exhibit 10.4). In
                                      terms of magnitude, the reduction of gross domestic product caused by
                                      the pandemic was thus not comparable to the most recent economic
                                      recession of 2008–09.

Exhibit 10.4—After a 17% reduction in 2020, economic activity bounced back to its pre-COVID-19
level by November 2021
Gross domestic product
in billions of 2012 dollars
                                                                                              Start of the COVID-19          November
                                                                                             pandemic, March 2020                2021
 $2,100

 $2,000

 $1,900

 $1,800

 $1,700
                                                                                                                      April 2020
 $1,600

 $1,500

     $0
        Jan      Jan      Jan      Jan      Jan      Jan    Jan    Jan     Jan     Jan     Jan      Jan       Jan          Jan      Jan Jun
       2008     2009     2010     2011     2012     2013   2014   2015    2016    2017    2018     2019      2020         2021     2022 2022
Source: Statistics Canada data, released August 31, 2022


                                      10.29 With health measures put in place to limit the spread of the
                                      virus that causes COVID‑19, many Canadians transitioned to working
                                      from home. Others were unable to work. This explained a reduction
                                      in the number of hours worked and highlighted the importance of
                                      these programs supporting workers who lost income. Hours worked
                                      diminished by 28% between February and April 2020 (Exhibit 10.5)
                                      but returned to their pre‑COVID‑19 level by May 2021. The most
                                      significant impacts were concentrated in the service sector, such as
                                      accommodation and food services, where non‑essential business
                                      activities were closed and where physical distancing and alternative work
                                      arrangements were more difficult or impossible.



                                          1     Gross domestic product—The total value of goods and services produced in a year.
                                          Also commonly referred to as GDP, it is 1 of the indicators traditionally used to measure
                                          the size of the economy.



Reports of the Auditor General of Canada                                                                                   Report 10    |   8
to the Parliament of Canada—2022
                                                                                                                   Specific COVID-19 Benefits


Exhibit 10.5—After a major decrease between February and April 2020, the number of hours
worked went back to pre-COVID-19 level as of May 2021, with some service industries still affected

  Evolution of hours worked using
  January 2020 = 100 as the baseline

   110

   100

    90

    80

    70

    60

    50

    40

    30

     0
          Jan      Mar      May       Jul        Sept   Nov     Jan    Mar     May     Jul     Sept     Nov      Jan     Mar      May      Jul
         2020      2020     2020     2020        2020   2020   2021    2021    2021   2021     2021     2021    2022     2022     2022    2022



                Total employed, all industries          Accommodation and food services        Other services (except public administration)


Note: We used Statistics Canada data and established an index number (January 2020 = 100, which is a statistical technique for measuring
changes in the magnitude of a group of related variables) to measure the change from a point in time. “Other services” include activities not
classified to any other sector, such as personal care services, funeral services, and car repair and maintenance. For a complete definition, see
Statistics Canada.
Source: Statistics Canada


                                            Mitigation of poverty and income inequality

                                            10.30 Statistics Canada data revealed that without benefit programs,
                                            the poverty rate in Canada would have reached 11.6% in 2020, more
                                            than 5 percentage points higher than the observed 6.4% rate. This data
                                            showed that the COVID‑19 benefits had a notable impact on preventing a
                                            spike in the poverty rate in 2020.

                                            10.31 Statistics Canada data also showed that workers with relatively
                                            lower income were among those who received the most benefit
                                            payments, which compensated their loss of income. For families with the
                                            lowest level of income, their combined income from employment, private
                                            pensions, and investments—known as market income—decreased
                                            on average by $700 (or 18%) between 2019 and 2020. However, when
                                            we combined this income with government transfers (cash benefits
                                            such as child benefits, tax credits, as well as emergency response and
                                            recovery benefits for 2020)—known as after‑tax income—we saw an
                                            annual income increase of $2,900 (or 16%) in the same period. Although
                                            individuals from all income groups observed a growth of this income, the
                                            increase was substantial for lower‑income families (Exhibit 10.6).




Reports of the Auditor General of Canada                                                                                         Report 10         |   9
to the Parliament of Canada—2022
                                                                                                           Specific COVID-19 Benefits


                               Exhibit 10.6—Annual after-tax income increased among the
                               lowest‑income earners between 2019 and 2020 due to government
                               payments for COVID-19 benefits
                                Percentage change
                                in average annual income,                                        Market income           After-tax income
                                between 2019 and 2020

                                 20%


                                            16%
                                 15%




                                 10%
                                                              8%
                                                                               7%
                                                                                               5%                                5%
                                  5%

                                                                                                                2%

                                  0%
                                                                                                                0%
                                                                                              –2%                                –2%
                                                                              –3%
                                 –5%




                                –10%
                                                            –10%


                                –15%



                                           –18%
                                –20%
                                            Lowest          Second            Third          Fourth            Fifth              All
                                           quintile*        quintile         quintile        quintile         quintile         income

                                                                                    Income group
                               Note: An income quintile is a measure that divides the population into 5 income groups (from lowest
                               income to highest income) so that approximately 20% of the population is in each group. Market income
                               is employment income and private pensions plus income from investments and other market sources.
                               After-tax income is the total of market income and government payments, less income tax. For 2020,
                               government transfers included emergency response and recovery benefits.
                               The exhibit above illustrates that people in the lowest quintile were those who had the highest decrease in
                               their market income. It also illustrates that COVID-19 benefits represented a higher proportion of the total
                               after-tax income for the people in the lowest quintile.
                               Source: Statistics Canada




Reports of the Auditor General of Canada                                                                                 Report 10     |    10
to the Parliament of Canada—2022
                                                                                              Specific COVID-19 Benefits


                                 10.32 According to Statistics Canada, from 2019 to 2020, the median
                                 income2 of combined employment, pensions, and investments for
                                 Canadians declined by $1,600. However, the median government
                                 transfers doubled from $8,200 to $16,400. This was due mainly to
                                 COVID‑19 income support programs. Overall, these increases in
                                 government transfers to households exceeded losses in wages and
Goal 1: End poverty in all its
forms everywhere
                                 salaries and self‑employment income. This income compensation
Source: United Nations           through the COVID‑19 programs helped to financially support the
                                 population.

                                 10.33 These findings are aligned with the government’s targets
                                 regarding 2 United Nations’ sustainable development goals—Goal 1,
                                 No Poverty, and Goal 10, Reduced Inequalities. Thus, we found that the
                                 COVID‑19 benefits under audit for individuals contributed to reducing
                                 poverty and inequalities in Canada in 2020.
Goal 10: Reduce inequality
within and among countries
Source: United Nations



COVID‑19 benefits went to people and employers in the economic sectors most
impacted by the pandemic

What we found

                                 10.34 We found that individuals from the groups most impacted
                                 by the pandemic were able to benefit from the programs. Women,
                                 visible minorities, Indigenous groups, and youth aged 15–24 accessed
                                 programs at slightly higher rates than other groups did. In addition, we
                                 found that benefit payments supporting individuals were made in a
                                 timely manner, particularly during periods of public health restrictions.

                                 10.35 Regarding the Canada Emergency Wage Subsidy, we found that
                                 it supported employers in sectors that suffered the biggest employment
                                 declines. However, it was difficult to assess the impact of the program
                                 and how effectively the program met its objectives because of the
                                 limited information employers were required to provide upon application.
                                 For example, the program did not require employers to submit any
                                 information on rehiring.

                                 10.36 The analysis supporting this finding discusses the
                                 following topics:
                                   • Benefits paid to the most-impacted Canadians
                                   • Unclear impact on business resilience
                                   • Missing data for assessment of Canada Emergency Wage
                                     Subsidy effectiveness


                                    2    Median income—The amount that divides the income distribution into
                                    2 equal groups.



Reports of the Auditor General of Canada                                                                Report 10   |   11
to the Parliament of Canada—2022
                                                                                  Specific COVID-19 Benefits


Why this finding matters

                               10.37 This finding matters because it is important that the government
                               demonstrates that the COVID‑19 benefit programs—which cost
                               Canadians about $211 billion—supported Canadians and employers that
                               were in need.

Analysis to support
this finding

                               Benefits paid to the most-impacted Canadians

                               10.38 We found that COVID‑19 programs for individuals provided
                               income support to a large number of people who lost their jobs or had
                               their working hours significantly reduced because of the pandemic.
                               Based on available data from Statistics Canada, mostly on the Canada
                               Emergency Response Benefit, we calculated the following:
                                  • 41.7% of recipients were household major income earners
                                    (3.46 million people)
                                  • almost 25% of recipients were sole income earners in their
                                    household (1.9 million people)
                                  • 69% of women working in the accommodation and food sector
                                    received the Canada Emergency Response Benefit (while women
                                    represented 56% of the people employed)

                               10.39 We also found, based on Statistics Canada information, that a
                               higher proportion of workers who were visible minorities or Indigenous
                               received the benefits compared to those who were not members of a
                               group designated as a visible minority or Indigenous (Exhibit 10.7).

                               10.40 In the case of the Canada Emergency Response Benefit, we
                               also noted that workers in groups designated as a visible minority or
                               Indigenous received benefits for slightly more weeks than those who
                               were not. For instance,
                                  • people who identify as a visible minority received the benefit
                                    for 18.5 weeks on average (compared to 16.2 weeks for people who
                                    did not identify as visible minorities)
                                  • Indigenous people received the benefit for 17.4 weeks on average
                                    (compared to 16.8 weeks for non‑Indigenous workers)




Reports of the Auditor General of Canada                                                   Report 10   |   12
to the Parliament of Canada—2022
                                                                                                    Specific COVID-19 Benefits


                               Exhibit 10.7—A higher proportion of people in visible minority and
                               Indigenous groups received benefits than in groups not designated
                               as such
                                  Percentage of recipients
                                  in each identified group
                                  45
                                                 40.9%                         40.5%
                                  40

                                  35
                                                                                                            29.9%
                                  30

                                  25

                                  20

                                  15

                                  10

                                   5

                                   0
                                            Persons in groups                Indigenous                    Persons not
                                              designated as                    people                    designated as a
                                             visible minorities                                        visible minority and
                                                                                                          not Indigenous
                               Note: Federal COVID-19 benefits include the Canada Emergency Response Benefit, the Canada Emergency
                               Student Benefit, the Canada Recovery Benefit, the Canada Recovery Caregiving Benefit, the Canada
                               Recovery Sickness Benefit, and a 1-time payment made to Canadians with disabilities.
                               Source: Statistics Canada


                               10.41 We found that Canadians received benefits in a timely manner,
                               notably during lockdown periods. The number of recipients of the
                               benefits was aligned with the severity of public health restrictions
                               in response to COVID‑19, as measured by the stringency index3
                               (Exhibit 10.8). For the Canada Emergency Response Benefit and the
                               Canada Recovery Benefit, the more severe the health restrictions, the
                               higher the number of recipients. However, as illustrated in the case of
                               the Canada Recovery Benefit, we noted that, starting in June 2021, the
                               number of recipients diminished less quickly with the lifting of restrictive
                               public health measures, showing that individuals did not return to work.




                                   3     Stringency index—A measure of the severity of policies governments put in place to
                                   protect people against the transmission of COVID‑19 (for example, school and workplace
                                   closures, stay‑at‑home requirements, and restrictions on travel) tracked over time
                                   throughout the country. A higher index score indicates a higher level of COVID‑19–related
                                   restrictions on individuals and employers. Values shown for the stringency index are
                                   averages of the daily scores for the 2‑week periods for the programs.



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Exhibit 10.8—The trend in the number of people receiving benefits aligned with the level of severity
of COVID-19–related restrictions

                                                              Number of recipients                 Stringency index


                               Canada Emergency Response Benefit and Employment Insurance
                                      Emergency Response Benefit—Stringency index

     Number of                                                                                                                                    Stringency
     recipients                                                                                                                                        index
     16,000,000                                                                                                                                             80
     14,000,000                                                                                                                                             70
     12,000,000
                                                                                                                                                            60
     10,000,000
                                                                                                                                                            50
      8,000,000
                                                                                                                                                            40
      6,000,000
                                                                                                                                                            30
      4,000,000
      2,000,000                                                                                                                                             20

               0                                                                                                                                            0
                    15 March              15 April                15 May              15 June              15 July             15 August         15 September
                      2020                 2020                    2020                2020                 2020                 2020                2020



                                                 Canada Recovery Benefit—Stringency index

     Number of                                                                                                                                    Stringency
     recipients                                                                                                                                        index
      1,400,000                                                                                                                                             80

      1,200,000                                                                                                                                             70

      1,000,000                                                                                                                                             60

        800,000                                                                                                                                             50

        600,000                                                                                                                                             40

        400,000                                                                                                                                             30

        200,000                                                                                                                                             20

               0                                                                                                                                            0
                   27 Sept     27 Oct   27 Nov       27 Dec     27 Jan     27 Feb   27 Mar      27 Apr   27 May      27 Jun   27 Jul   27 Aug    27 Sept

                                   2020                                                                   2021


Note: The stringency index measures the severity of policies governments put in place to protect people against the transmission of COVID-19. A
higher index score indicates a higher level of COVID-19–related restrictions on individuals and employers. Values shown for the stringency index
are averages of the daily scores for the 2-week periods for the programs.
Source: Stringency index—Bank of Canada; number of recipients based on data provided by the Canada Revenue Agency and Employment and
Social Development Canada


                                           10.42 With regard to COVID‑19 support for employers, we also found
                                           that the Canada Emergency Wage Subsidy went to sectors in need.
                                           Employers and sectors that suffered the biggest employment decline
                                           from the introduction of the lockdowns used the Canada Emergency
                                           Wage Subsidy the most. About 36% of all active employer businesses




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                               received the subsidy. According to Statistics Canada, the top 3 industries
                               that received the subsidy as at June 2021 were
                                  • accommodation and food services (66% of businesses in
                                    this industry)
                                  • arts, entertainment, and recreation (56% of businesses in
                                    this industry)
                                  • manufacturing (55% of businesses in this industry)

                               Unclear impact on business resilience

                               10.43 According to Statistics Canada data released in June 2022, the
                               number of active businesses went back to the pre‑pandemic level in
                               October 2021. However, the influence of the Canada Emergency Wage
                               Subsidy in this resilience is unclear because the businesses that existed
                               pre‑pandemic were different from the businesses that existed as of
                               October 2021.

                               10.44 Statistics Canada also reported that there were fewer business
                               closures for those businesses that received the Canada Emergency
                               Wage Subsidy. Among the businesses that received the subsidy, 10.3%
                               of them closed by February 2022 compared to 32.8% of businesses that
                               did not receive the subsidy. However, these closure patterns could not
                               be interpreted as reflecting the impact of the Canada Emergency Wage
                               Subsidy because pre‑existing and other emergency support government
                               programs were running at the same time to support businesses through
                               the pandemic. Therefore, we could not conclude on the impact of the
                               subsidy on business resilience.

                               Missing data for assessment of Canada Emergency Wage
                               Subsidy effectiveness

                               10.45 We found that the Canada Revenue Agency did not have the data
                               needed to measure the effectiveness of the Canada Emergency Wage
                               Subsidy. For example, the application form did not require employees’
                               social insurance numbers. These employees were supposed to be the
                               ultimate beneficiaries of this program through their employers. Without
                               data, we could not accurately determine
                                  • the exact number of employees who benefited from this program
                                  • whether employees remained working for the same employers,
                                    changed to another employer, or moved to work in another sector
                                  • the exact number of employees who were rehired (as the program
                                    aimed to encourage employers to rehire workers who were laid off
                                    as a result of the pandemic)




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                               10.46 Sound management of public funds requires that data collection
                               and analysis be a key aspect of program administration. In our view,
                               this missing data highlights a broader issue of missed opportunities
                               to assess the effectiveness of programs, in this case the Canada
                               Emergency Wage Subsidy.

                               10.47 Recommendation. In the administration of future programs,
                               the Canada Revenue Agency should engage with its partners, such
                               as Statistics Canada and relevant departments, to ensure it collects
                               pertinent data from applicants to better monitor and measure the
                               effectiveness and outcomes of programs.

                               The agency’s response. Agreed.

                               See Recommendations and Responses at the end of this report for
                               detailed responses.


Employment and Social Development Canada adjusted benefit programs to try to
address disincentives to work

What we found

                               10.48 We found that the government was aware from the onset of
                               the pandemic that the introduction of COVID‑19 benefits to individuals
                               would create a disincentive to work for some recipients. Employment
                               and Social Development Canada announced changes to the Canada
                               Emergency Response Benefit program to counter the disincentive.

                               10.49 We also found that some lower‑income recipients of the benefits
                               replaced their previous annual earning by more than 100% using the
                               Canada Emergency Response Benefit and by 119% by staying on the
                               Canada Recovery Benefit for all periods. The government assessed
                               the impact and took steps to mitigate these issues. These included
                               introducing incentives to get more people working, especially when the
                               economy was reopening.

                               10.50 The analysis supporting this finding discusses the
                               following topic:
                                  • Benefits’ disincentive to work

Why this finding matters

                               10.51 This finding matters because, at a time when businesses
                               needed employees, some employees had more income by receiving the
                               COVID‑19 benefits than they would have had by rejoining the workforce.




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Analysis to support
this finding

                               Benefits’ disincentive to work

                               10.52 We found that Employment and Social Development Canada
                               did an analysis in June 2020 on the impact of the Canada Emergency
                               Response Benefit on the labour market and made changes to the
                               program. Early on in the pandemic, employers in some sectors
                               were having difficulty finding workers, which was confirmed in the
                               department’s analysis that the Canada Emergency Response Benefit had
                               created a disincentive to work. This benefit was developed to encourage
                               people to stay at home while public health restrictions were in place. The
                               program as initially administered did not allow recipients to have other
                               earnings while receiving benefits. In mid‑April 2020, the department and
                               agency began administering the program so as to allow workers to earn
                               a maximum of $1,000 while still being eligible to receive benefits if they
                               met other program eligibility criteria.

                               10.53 We looked at the department’s analysis of challenges to the
                               labour market created by the benefits programs. The department’s
                               analysis showed the following:
                                  • Individuals in the lower income brackets—earning less than $500 per
                                    week—represented the largest number of applicants to the Canada
                                    Emergency Response Benefit.
                                  • The amount of benefit they received could impact their return
                                    to work since they could receive an equal or greater income
                                    without working.

                               10.54 The department’s analysis also determined that people whose
                               pre‑pandemic weekly earnings were $500 or less represented 44% of
                               individuals that lost their employment between February and April 2020.
                               However, between April and May 2020, only 11% of people earning
                               $500 or less returned to work. In our view, the department’s analysis
                               showed that the Canada Emergency Response Benefit created a
                               disincentive to go back to work, especially for more than one third of
                               applicants who earned less than $500 per week. For them, the Canada
                               Emergency Response Benefit represented more than 100% of income
                               replacement. This may explain why approximately 2 million people
                               stayed on the benefits for all 7 periods for a total of 28 weeks.

                               10.55 The Canada Emergency Response Benefit ended in
                               October 2020. The Canada Recovery Benefit succeeded that program
                               for Canadians without Employment Insurance insurable hours. It had
                               the same benefit amount as the Canada Emergency Response Benefit
                               but did not necessarily limit earnings to $1,000. The Canada Recovery
                               Benefit could be collected for a maximum of 54 weeks. For applications
                               for a benefit period beginning before 18 July 2021, the maximum benefit
                               was $500 per week for the first 42 weeks. After this, and as a means to


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                               encourage people to return to work, the benefit amount was reduced to
                               $300 per week. These changes applied to new claimants for a benefit
                               period beginning on or after 18 July 2021.

                               10.56 As with the Canada Emergency Response Benefit, we found
                               that the lowest-income recipients of the Canada Recovery Benefit could
                               earn more from receiving the benefit than from working. Low-income
                               earners (with gross earnings of $20,000 or less per year) who received
                               the recovery benefit for all periods (54 weeks) effectively replaced their
                               annual income by 119%.

                               10.57 In our opinion, the ability for low‑income individuals to earn
                               more on the Canada Recovery Benefit represented a disincentive to work,
                               which impacted some labour markets at a crucial time when the need for
                               employees was trending upwards.


Program delivery and controls

Context

                               10.58 The urgency of responding to the impacts of the pandemic
                               meant that government programs that would normally have taken
                               months or years to design and implement had to be operational within
                               weeks. Although the original programs were expected to last only a
                               few months, additional waves of the pandemic led to the government
                               extending existing support programs and introducing new ones.

                               10.59 In our spring 2021 audits, Report 6—Canada Emergency
                               Response Benefit and Report 7—Canada Emergency Wage Subsidy, we
                               found that the design of COVID‑19 benefit programs relied on applicants
                               attesting to eligibility and on some automated and manual pre‑payment
                               controls. This decision allowed for quicker processing times, which, in
                               combination with the short turnaround time, also limited confirmation
                               of eligibility.

                               10.60 The Canada Revenue Agency and Employment and Social
                               Development Canada decided to put emphasis on verifying recipients’
                               eligibility after payment to compensate for the initial limited rigour at
                               the pre‑payment stage. This approach is consistent with best practices
                               promoted by the International Public Sector Fraud Forum and its
                               principles for fraud control in emergency management.




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The trade‑off between expediency and confirming eligibility resulted in payments to
ineligible recipients

What we found

                               10.61 We found that Employment and Social Development Canada and
                               the Canada Revenue Agency’s approach to limit pre‑payment controls
                               and rely on applicants’ attestations to expedite payments meant that a
                               significant amount of payments were made to ineligible recipients or
                               to recipients with high risk indicators of ineligibility for the programs.
                               We found that the government made $4.6 billion of overpayments
                               to ineligible recipients. We also estimated that at least $27.4 billion
                               was paid to recipients that should be investigated further through
                               post‑payment verification4 to confirm eligibility.

                               10.62 The analysis supporting this finding discusses the
                               following topics:
                                  • Limited pre‑payment controls
                                  • Limited performance standards and measures
                                  • No real‑time business revenue data
                                  • No real‑time payroll data
Why this finding matters

                               10.63 This finding matters because the benefit programs to individuals
                               and employers were significant emergency measures that, in order to
                               issue payments within days of receiving an application, relied upon the
                               good faith of Canadians and Canadian employers.
Analysis to support
this finding

                               Limited pre‑payment controls

                               10.64 Despite the fact that the Canada Revenue Agency and
                               Employment and Social Development Canada added some pre‑payment
                               controls over time, there were still eligibility criteria for each program
                               for which no pre‑payment controls were implemented. We found that
                               $4.6 billion was overpaid to ineligible recipients. We also estimated that
                               at least $27.4 billion was paid to recipients that have an indicator of
                               ineligibility and should be investigated further.

                               10.65 In estimating this amount, we used information available up to
                               March 2022. Much of that information was not available to the agency
                               and department when the payments were issued because it either was
                               not requested on the applications or was not readily available through
                               income tax return information. For example, the $5,000 income criterion

                                   4    Post‑payment verification—Confirmation of eligibility and accuracy after the benefit
                                   has been paid.



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                               could be calculated using earnings from the 12 months prior to the
                               application date. This information was not available to the agency
                               and department unless they contacted the applicants, which would
                               have hindered payment expediency. In addition, during the pandemic,
                               the 2019 income tax return deadline was extended to June 2020, which
                               further delayed the availability of some of the information. Therefore, in
                               most instances, the available data we used in our assessment could not
                               alone confirm ineligibility. In most cases, only post‑payment verifications
                               can establish ineligible amounts, as recipients will need to be contacted
                               to provide additional information.

                               10.66 See Exhibit 10.9 for a summary of amounts paid to ineligible
                               recipients and recipients that should be investigated further. The exhibit
                               shows payments before individuals and employers repaid an estimated
                               $2.3 billon, as reported by the agency and the department.

                               10.67 We found that the agency added several pre‑payment controls
                               over the course of the COVID‑19 benefit programs for individuals.
                               For example, in July 2020, once most income tax information was
                               available, the agency implemented a check to verify that applicants
                               met the eligibility criterion of a minimum income threshold of $5,000.
                               If the criterion was not met, applicants were prevented from receiving
                               benefits until they provided more information to prove eligibility. While
                               the agency estimated that this pre‑payment control prevented billions in
                               benefit payments to ineligible recipients, we found that this control was
                               ineffective for the following reasons:
                                  • The agency did not request additional information from every
                                    identified applicant at risk of being ineligible as soon as they were
                                    identified, but did so over many months.
                                  • The agency was limited to using the tax information available at the
                                    time, which alone could not confirm eligibility.

                               10.68 The agency stopped payments and requested additional
                               information from over 544,000 applicants. Based on our analysis
                               using 2019 to 2021 income tax information, we found an
                               additional 366,000 recipients that were not identified by the agency
                               and who did not appear to meet the income threshold of $5,000. These
                               should now be investigated further to confirm eligibility.

                               10.69 Regarding the Canada Emergency Wage Subsidy, we found
                               that the agency made few additions or improvements to pre‑payment
                               controls to address risks of ineligible payments. This was to maintain
                               the speed of processing applications. For example, prior to payment, the
                               agency did no automated validation of the revenue decline submitted by
                               applicants, which was an eligibility criterion. At a minimum, the agency
                               could have compared the submitted revenue decline against historical
                               goods and services tax/harmonized sales tax (GST/HST) data (even
                               if only on a sample basis). Also, instructions given to pre‑payment




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                                  reviewers were limited and relied on a reviewers’ discretion in accepting
                                  or denying a claim. Multiple opportunities to improve pre‑payment
                                  controls were available but not taken when
                                     • the program was extended multiple times
                                     • business intelligence tools were used in December 2020 to identify
                                       risks and select recipients for post‑payment audits
                                     • our 2021 audit of the Canada Emergency Wage Subsidy
                                       recommended that available information should be better used to
                                       improve controls

Exhibit 10.9—Benefit and subsidy amounts paid to ineligible recipients or recipients that should be
investigated further

                                                                                                                  Total
    Benefit program and amounts paid to ineligible
                                                               Program requirement not met or at                payment
        recipients or recipients that should be
                                                                     risk of not being met1                     amount
                 investigated further
                                                                                                              (in billions)
    Overpayments to ineligible recipients                                                                               $4.6

    Individual benefit programs
    • $3.1 billion paid to 1.8 million recipients              • Recipients received an
                                                                 advance lump‑sum overpayment
                                                                 for EI‑ERB2
    • $1.5 billion paid to 711,000 recipients                  • Recipients received more
                                                                 than 1 benefit per period
    Payments that should be investigated further                                                                     $27.44

    Individual benefit programs
    • $8.3 billion paid to 627,000 recipients                  • Recipients earned
                                                                 less than $5,000
    • $3.8 billion paid to 1.4 million recipients              • Recipients earned more
                                                                 than $1,000 during a 4‑week
                                                                 CERB period3
    Canada Emergency Wage Subsidy
    • $15.5 billion paid to recipients that should be          • Recipients showed insufficient
      investigated further                                       revenue decline based on
                                                                 GST/HST filing data
    Total                                                                                                               $32
1
  See Part 2 of this report for more information on assumptions made for each program to determine these amounts as well as
information about additional payments to recipients that should be investigated further that are excluded from this exhibit.
2
 For the Employment Insurance Emergency Response Benefit (EI-ERB) program, the lump‑sum payments issued to recipients
were not related to program requirements, and Employment and Social Development Canada knew it would need to recover
these overpayments.
3
 . Program requirements are based on eligibility information as administered by Employment and Social Development Canada
and the Canada Revenue Agency at the time of program delivery. CERB is the Canada Emergency Response Benefit
4
 Some payments have been identified as ineligible in more than 1 program requirement. Therefore, we adjusted our finding of
$27.4 billion so that duplicates were excluded.




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                               10.70 In addition to the $4.6 billion in overpayments and $27.4 billion
                               of payments that should be investigated further identified in Exhibit 10.9,
                               we found other limitations to pre-payment controls that suggest more
                               payments and recipients should be further investigated. In our opinion,
                               the $27.4 billion is the minimum amount that should be investigated.
                               Notably, the following examples were not included in the $27.4 billion
                               either because we could not quantify the amount or because the
                               information had not been validated to confirm its reliability:
                                  • For the Canada Emergency Response Benefit program, we
                                    identified 190,254 recipients who received $1.6 billion in payments
                                    for which Employment and Social Development Canada has
                                    information indicating recipients quit their employment. This
                                    information needs to be verified, as quitting may have made them
                                    ineligible for benefits. (See additional information on the Canada
                                    Emergency Response Benefit program in Part 2 of this report.)
                                  • For the Canada Emergency Wage Subsidy, as noted in our
                                    spring 2021 Report 7—Canada Emergency Wage Subsidy, a lack of
                                    detailed employee information (for example, not requiring social
                                    insurance numbers on application forms) prevented the Canada
                                    Revenue Agency from using a control that would have identified
                                    instances of businesses inaccurately reporting information about
                                    employees (number and remuneration) in their claim and employees
                                    who were also claiming individual benefits.

                               10.71 Our recommendation for this area of examination is in
                               paragraph 10.101.

                               Limited performance standards and measures

                               10.72 We found that Employment and Social Development Canada
                               established performance standards by focusing solely on the speed
                               of payment. For all programs for individuals audited, we found that
                               payments were timely, usually within 4 days of the application being
                               received. We also found that the Canada Revenue Agency provided input
                               to the department regarding improving the administrative efficiency
                               of the programs. However, the department’s following performance
                               indicators were, in our view, simply volume metrics:
                                  • total number of unique applicants for the stated benefit
                                  • total number of approved applications for the stated benefit
                                  • total gross dollar value of the stated benefit

                               10.73 We found that the department did not develop other
                               performance indicators to measure results related to the administrative
                               efficiency, effectiveness, and outcomes of the programs.




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                               No real‑time business revenue data

                               10.74 We found that the Canada Revenue Agency did not have
                               timely and sufficient data in its systems to reliably assess the Canada
                               Emergency Wage Subsidy eligibility criteria at the time of application.
                               In the absence of real‑time data, we found that the agency did not use
                               the available GST/HST information to assess the eligibility criteria for
                               demonstrating revenue decline.

                               10.75 GST/HST filing requirements are not in real time and may
                               be submitted monthly, quarterly, or annually. This meant the agency
                               could only do analyses after businesses submitted GST/HST returns,
                               which was not in time to assess employers applying for the subsidy.
                               After the subsidy ended, we analyzed the GST/HST return filings the
                               agency received throughout 2020 and 2021. We estimated $15.5 billion
                               in benefits were paid to recipients whose GST/HST filings did not
                               demonstrate a sufficient revenue decline to be eligible for the subsidy.
                               A more definitive estimate of payments to ineligible recipients and
                               amounts to be recovered by the government will be determined only after
                               the agency has completed its post‑payment verifications.

                               10.76 Other jurisdictions have implemented electronic invoicing and
                               reporting to collect sales tax information in real time. In Spain, the tax
                               administration receives real‑time data on sales from certain businesses.
                               In Quebec, the sharing of real‑time sales data is being implemented on
                               an industry‑by‑industry basis: for example, sales in the remunerated
                               passenger transportation sector are submitted to Revenu Québec as
                               they happen.

                               10.77       More broadly, real‑time GST/HST reporting could also
                                  • reduce the reporting burden on businesses
                                  • reduce errors and improve compliance on tax assessments
                                  • help in informing, designing, and assessing public policies

                               10.78 Recommendation. In order to improve the efficiency of the tax
                               and programs administration and to follow good practices, the Canada
                               Revenue Agency should assess the value of implementing a real‑time
                               business revenue data requirement.

                               The agency’s response. Agreed.

                               See Recommendations and Responses at the end of this report for
                               detailed responses.

                               No real‑time payroll data

                               10.79 We found that the Canada Revenue Agency and Employment
                               and Social Development Canada did not have a modern real‑time payroll
                               data requirement for businesses. Real‑time data could have been used



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                               to assess program eligibility, calculate the benefit payment, and improve
                               the overall efficiency of managing the COVID‑19 programs as reported in
                               the above section on limited pre-payment controls.

                               10.80 Other jurisdictions have implemented systems and reporting
                               requirements to collect payroll information in a timely manner. We noted
                               that the United Kingdom and Ireland used their real‑time payroll data to
                               help manage their COVID‑19 benefits.

                               10.81       More broadly, real‑time payroll data could also
                                  • reduce the reporting burden on businesses
                                  • reduce errors and improve compliance on tax assessments
                                  • help provide benefits for citizens that can adapt more quickly to
                                    evolving situations (such as loss of employment)
                                  • support the collection of timely data to better inform, design, and
                                    assess public policies
                                  • help the government to more efficiently and accurately manage the
                                    benefits it provides to Canadians and Canadian businesses

                               10.82 We also noted that in 2017, the Employment Insurance Service
                               Quality Review recommended that Employment and Social Development
                               Canada engage with key stakeholders in the co‑creation of a real‑time
                               payroll information‑sharing solution. In the mandate letter to the Minister
                               of National Revenue in 2019, the responsibility to implement a voluntary,
                               real‑time electronic payroll system with an initial focus on small
                               businesses was transferred to the Canada Revenue Agency.

                               10.83 At the time of our audit, limited progress had been made. The
                               agency planned to develop a business case in 2024 to request additional
                               funding for a real‑time e‑payroll system. According to the agency’s
                               plan, the project was facing delays—for example, the period for official
                               consultations was initially set to end in March 2022 but was extended to
                               March 2023.

                               10.84 Recommendation. In order to improve its efficiency of delivering
                               benefit programs, the Canada Revenue Agency, with the collaboration
                               of Employment and Social Development Canada, should pursue the
                               development and implementation of a real‑time payroll system with clear
                               timelines and deliverables.

                               The agency’s response. Agreed.

                               See Recommendations and Responses at the end of this report for
                               detailed responses.




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Post‑payment verification and collection

Context

                               10.85 The COVID‑19 benefit program design required Employment
                               and Social Development Canada and the Canada Revenue Agency to
                               rely on personal attestations and minimal controls to confirm eligibility
                               before issuing benefit payments. This meant that verifying eligibility after
                               payment became very important. As a result, the department and agency
                               developed plans to verify the eligibility of approved recipients.

                               10.86 According to legislation, for most COVID‑19 benefit programs,
                               verifications of eligibility must be completed within 36 months after the
                               benefits have been paid. If either the department or the agency suspects
                               that recipients misrepresented information, then the verification time
                               frame could be extended to a maximum of 72 months. To illustrate, for
                               a payment issued in October 2020, in the absence of misrepresentation
                               and other specific circumstances that could extend the timeline, the last
                               possible date to conduct a post‑payment verification is October 2023.

                               10.87 In 2020, for some of the COVID‑19 individual benefit programs,
                               the department identified eligibility criteria that would not be investigated
                               due to the subjective nature of the criteria, the difficulty of proving
                               eligibility after the fact, and the undue burden investigation could create.
                               Examples of eligibility criteria where no post‑payment verification would
                               be performed are if a recipient
                                  • was caring for ill family members or in self‑isolation due
                                    to COVID‑19
                                  • stopped working due to school closures or daycare closures, or
                                    voluntarily due to COVID‑19


Employment and Social Development Canada and the Canada Revenue Agency were
planning to do few post‑payment verifications

What we found

                               10.88 We found that Employment and Social Development Canada’s
                               and the Canada Revenue Agency’s plans for verifying eligibility of
                               recipients of benefits after payments for individual programs were
                               incomplete. These plans did not include post‑payment verification of all
                               the overpayments or payments to recipients that either were ineligible or
                               should be investigated further to verify eligibility.

                               10.89 In addition, the department’s and agency’s plans were not
                               aligned with the early decision to focus on verifying eligibility after
                               payment, given the low number of post‑payment verifications to be
                               performed. We also found that, as the COVID‑19 pandemic evolved, the


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                               department and agency delayed their post‑payment verifications of
                               recipients’ eligibility. As a result, the department and agency are at risk of
                               not completing planned post‑payment verifications within the legislated
                               time frames.

                               10.90 We also found that for benefits to individuals, both the
                               department and the agency were delayed in conducting post‑payment
                               verifications and notifying recipients because of the need for
                               legislative changes.

                               10.91 The analysis supporting these findings discusses the
                               following topics:

                               Benefits for individuals:
                                  • Incomplete post‑payment verification plans and delays in
                                    conducting verifications for individuals
                                  • Low percentage of post‑payment verifications to be performed on
                                    programs for individuals

                               Benefits for employers:
                                  • Risk that post‑payment verification will not be completed within the
                                    legislated time frame

Why this finding matters

                               10.92 This finding matters because the government needs strong
                               post‑payment verifications to mitigate the risks created by the limited
                               pre‑payment controls. Post‑payment verifications are also important
                               because they are the means through which the government will confirm
                               whether recipients were eligible for the payments and will identify the
                               amounts to recuperate.

Analysis to support
this finding
                               Incomplete post‑payment verification plans and delays in conducting
                               verifications for individuals

                               10.93 In our spring 2021 Report 6—Canada Emergency Response
                               Benefit, we recommended that Employment and Social Development
                               Canada and the Canada Revenue Agency finalize and implement
                               their post‑verification plans for the benefit. At the time of the audit,
                               we found that this recommendation was not fully addressed, as both
                               organizations’ post‑payment verification plans were incomplete. For
                               example, the following were not included in the plan:
                                  • The agency had identified more than 375,000 recipients for
                                    follow‑up because they did not respond to a request for further
                                    information regarding their eligibility.




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                                  • The department had identified more than 1.8 million recipients of
                                    Employment Insurance Emergency Response Benefit lump‑sum
                                    payments to be recovered.

                               10.94 We also found that for COVID‑19 benefit programs for
                               individuals, the agency and the department started post‑payment
                               verification of applicants’ eligibility later than stated in the timelines of
                               their initial plans. The following are examples:
                                  • The agency was delayed in notifying individuals who received more
                                    than 1 benefit during a benefit period because it was waiting for
                                    legislative amendments. The amendments, which were passed
                                    in June 2022 as part of the Budget Implementation Act, 2022,
                                    No. 1, determined how amounts owed were to be calculated for
                                    overpayments for this group of recipients. We also found that the
                                    follow‑up on these overpayments had not been included in the
                                    department’s and agency’s post‑payment verification plans.
                                  • The department’s initial plan for post‑payment verifications for
                                    the Employment Insurance Emergency Response Benefit was
                                    scheduled to review 44,920 cases in 2021–22. However, the
                                    post‑payment verifications only started in 2022–23.

                               10.95 Such delays mean that the department and the agency will face
                               significant challenges completing all of their verifications before the
                               expiry of the legislated time frames for most of the individual benefits.
                               Given that payments for some of the individual benefit programs started
                               in spring 2020, and considering the delays in starting post‑payment
                               verifications, there is limited time left to conduct post‑payment
                               verifications of cases that do not represent suspected fraud or
                               misrepresentation. Even for cases of fraud or misrepresentation, for
                               which the timeline is extended to 72 months, a significant amount of
                               time has already elapsed and both the department and the agency have
                               just started the post‑payment verifications.

                               Low percentage of post‑payment verifications to be performed on
                               programs for individuals

                               10.96 Based on the information obtained during the audit and
                               the agency’s current plans, we estimated that approximately 12% of
                               individuals who received a benefit would be selected for post‑payment
                               verification. In addition, the agency identified $1.5 billion in payments
                               to recipients that received more than 1 benefit for the same period. The
                               agency planned to notify all of these recipients.

                               10.97 We noted that the Canada Revenue Agency started
                               post‑payment verification work on 1 specific criterion for the Canada
                               Emergency Response Benefit in January 2022 using data available
                               from their Business Intelligence Division. The agency identified
                               over 2.1 million recipients that potentially did not meet this eligibility
                               criterion. However, according to the post‑payment verification plan dated


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                               April 2022, only 150,000 recipients of these 2.1 million recipients (or 7%)
                               would be selected for verification. As of 12 May 2022, the agency had
                               contacted around 104,000 recipients requesting additional information
                               but had to pause this work due to a recent decision of an appeal by an
                               Employment Insurance Emergency Response Benefit recipient. This
                               highlighted the need for analysis of the alignment of post‑payment
                               verification activities related to the Canada Emergency Response
                               Benefit and the Employment Insurance Emergency Response Benefit.
                               An additional 150,000 verifications are planned at a later date, across
                               all benefit programs for individuals. However, few details on those
                               additional verifications, such as the criteria to be verified, were included
                               in the agency’s plan.

                               10.98 For Employment and Social Development Canada, we
                               estimated that around 4% of individuals who received a benefit would
                               be selected for post‑payment verification. The department made
                               Employment Insurance Emergency Response Benefit payments to a
                               total of 3.7 million recipients. We found that the department’s most
                               recent post‑payment verification plan included verifying approximately
                               130,000 of these recipients. In addition, the department identified
                               $3.1 billion in Employment Insurance Emergency Response Benefit
                               lump‑sum payments. The department planned to notify all recipients of
                               these payments.

                               10.99 In our opinion, the department and agency had not adopted a
                               rigorous and comprehensive approach to post‑payment verifications
                               considering the limited pre‑payment controls and the decision made at
                               the onset of these programs to focus on verifying eligibility of recipients
                               after payment. We believe that the low number of post‑payment
                               verifications planned was insufficient to address all payments at risk
                               of being ineligible. Given the limited pre‑payment controls in place, we
                               expected the department and the agency to conduct extensive and
                               comprehensive post‑payment verifications.

                               10.100 According to the International Public Sector Fraud Forum, given
                               the limited ability to implement pre‑payment controls in an emergency
                               situation, it is important that verifications following payment are carried
                               out to uphold the stewardship of public funds. In addition, considering
                               the Treasury Board’s policy on financial management, organizations
                               should follow up and recover payments made in error. Therefore, we are
                               of the view that all cases identified as representing a risk of not meeting
                               program criteria must be followed up and verified for fairness to all
                               recipients and Canadians.

                               10.101 Recommendation. The Canada Revenue Agency and
                               Employment and Social Development Canada should
                                  • update their post‑payment verification plans to include all activities
                                    to identify payments to ineligible recipients of COVID‑19 benefit
                                    programs, taking into account the legislated time frames



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                                  • increase the extent of post‑payment verifications for
                                    COVID‑19 benefit programs for individuals to include all cases
                                    identified as being at risk of being ineligible

                               The agency and department’s response. Partially agreed.

                               See Recommendations and Responses at the end of this report for
                               detailed responses.

                               Risk that post‑payment verification will not be completed within the
                               legislated time frame

                               10.102 While the post‑payment verifications for the Canada Emergency
                               Wage Subsidy started in August 2020, we found that the agency is at risk
                               of not being able to complete all the planned post‑payment verifications.
                               This is because of their complexity, as well as the significant amount
                               of time and effort required to conduct them. Subject to exceptions,
                               the agency normally has 36 or 48 months, depending on the type of
                               recipient, to complete the verifications. See Exhibit 10.10 for the status of
                               post‑payment verifications for the Canada Emergency Wage Subsidy.

Exhibit 10.10—Status of post‑payment verifications for the Canada Emergency Wage Subsidy



The Canada Revenue Agency began the process of verifying the eligibility of recipients of the Canada
Emergency Wage Subsidy in August 2020.
In phase 1 of its post‑payment verification plan, the agency selected a total of 730 audits with $1.5 billion in
subsidies paid from eligibility periods 1 to 4. Employers to be verified were selected in several ways: through
data analytics, manual identification during pre‑payment controls, and random selection. This phase included
a limited sample number in order to gain insights and develop a more thorough audit program for the next
phase.
Phase 2 verifications began in May 2021. Audits were selected based almost entirely on data analytics
(using risk indicators identified in phase 1) and manual identification during pre‑payment controls. A total
of 2,770 audits with $10.7 billion in subsidies paid were selected for phase 2 verifications.
As of May 2022, 712 (98%) of phase 1 verifications had been completed. Of completed verifications, 42%
resulted in adjustments totalling $81.5 million (6% of the amounts audited). Phase 1 verifications took an
average of 341 days to complete. Given the complexity of some audits, 18 were still in progress for phase 1.
As of May 2022, only 487 (18%) phase 2 verifications had been completed, while 49% were in progress
and 33% were not started. Of the completed verifications, 61% resulted in adjustments totalling $40 million
(13% of the amounts audited). Phase 2 verifications took an average of 195 days to complete.
The agency is planning to conduct an additional phase of verifications depending on the outcomes of current
phases and the availability of resources. Considering the above, the agency is at risk of not completing
phase 2 and any additional phase within the time frames referred to in paragraph 10.102.
While the number of employers selected for verification in the first 2 phases totalled approximately 0.8% of
the unique recipients, the value of subsidies being verified represented about 12% of the value of Canada
Emergency Wage Subsidy paid.
(See Part 2 of this report for a breakdown of Canada Emergency Wage Subsidy recipients and verifications by
business size.)




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The Canada Revenue Agency performed limited collection activities on
COVID‑19 programs

What we found

                               10.103 We found that because of the delays in post‑payment
                               verification work, the Canada Revenue Agency’s collection activities were
                               at the early stages for the COVID‑19 programs we audited. The agency
                               had sent few notices of amounts owed, with the exception of notices
                               to recipients of lump‑sum advance payments, which were sent by
                               Employment and Social Development Canada. We also found that once
                               notifications were sent, the agency’s collection activities were limited to
                               answering incoming calls from individual recipients or employers. For
                               benefits to individuals, the information the department and the agency
                               provided showed that approximately $2.3 billion of ineligible payments
                               have been repaid: $1.35 billion as of July 2022 for Employment and
                               Social Development Canada, and $925 million as of June 2022 for
                               the Canada Revenue Agency. We were unable to audit the amounts
                               the agency received from individuals and businesses for each of the
                               COVID-19 programs under audit because the agency could not provide
                               detailed and disaggregated reporting data.

                               10.104 At the time of the audit, we found that it was too early
                               to assess with certainty the unrecoverable amounts related to
                               the COVID‑19 programs we audited given the limited number of
                               post‑payment verifications and collection activities completed.

                               10.105 The analysis supporting this finding discusses the
                               following topics:
                                  • Few cases in collection for most COVID‑19 benefit programs
                                  • Unrecoverable amounts

Why this finding matters

                               10.106 This finding matters because undertaking collection activities
                               quickly will increase the chances of repayment and maximize the
                               recovery of overpayments and amounts paid to ineligible recipients. This,
                               in turn, will reduce the government’s loss of public funds.

Context

                               10.107 When a post‑payment verification is completed and results
                               in an amount to be repaid to the government, Employment and Social
                               Development Canada and the Canada Revenue Agency send notices to
                               advise the recipient of the amount to be repaid. Collection efforts can
                               then begin. The agency is responsible for collecting overpayments and
                               ineligible payments of COVID‑19 benefits to individuals and employers.




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                               10.108 The agency told us that its COVID‑19 collections approach is
                               to be empathetic and client‑focused and to provide flexible payment
                               arrangements. The agency has different levels of collection actions:
                                  • COVID‑19 payments in collection are first given to the agency’s
                                    debt management call centre to give individuals time to proactively
                                    pay their amounts owed. The call centre receives and makes
                                    calls, sends reminders to individuals and businesses, and makes
                                    payment arrangements.
                                  • If individuals do not repay their amount owed in full or do not
                                    contact the agency call centre to make a payment arrangement
                                    within 90 days of the notice date, the agency can move to
                                    enforcement actions. Examples of enforcement actions include
                                    garnishing wages and bank accounts, putting liens on personal
                                    property, and seizing and selling assets.

                               10.109 For most of the COVID‑19 benefit programs, the timeline to
                               collect an amount owed has been established in legislation at 6 years
                               from the date the notice is issued to the recipient of the amount owed or
                               when the debt became payable.

Analysis to support
this finding

                               Few cases in collection for most COVID‑19 benefit programs

                               10.110 We found that the delayed and slow progress of post‑payment
                               verifications for most COVID‑19 benefit programs limited the collection
                               work that could be done.

                               10.111 At the time of the audit, the agency’s collection activities for the
                               individual benefit programs were limited to responding to calls received
                               from recipients wanting to repay or make payment arrangements for
                               COVID‑19 amounts owed. We found that no other collection actions
                               occurred because very few notices were sent to recipients, with the
                               exception of Employment Insurance Emergency Response Benefit
                               lump‑sum advance payments, for which all notices had been sent
                               to individuals.

                               10.112 For benefits to individuals, approximately $2.3 billion of
                               COVID‑19 benefit overpayments had been repaid by recipients. This
                               amount is composed of repayments of $1.35 billion as of July 2022 for
                               Employment and Social Development Canada and of $925 million as of
                               June 2022 for the Canada Revenue Agency. We were unable to confirm
                               the amounts the agency received from individuals and businesses for
                               each of the COVID-19 programs under audit because of a lack of detailed
                               and disaggregated reporting data. For example, the capabilities of the
                               agency’s information technology system were limited and could not
                               provide disaggregated information on amounts owed and amounts
                               repaid for each benefit program.


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                               10.113 We also found that the agency’s information technology system
                               did not have the capability to apply future government payments
                               against a COVID‑19 benefit amount owed by an individual, whereas the
                               department’s system had this functionality. For example, the agency
                               could not apply income tax refunds or GST payments against the
                               amounts owed. Such a tool would help to support efficient collection
                               activities for high‑volume, low‑dollar value amounts. The agency told
                               us that it expected its system would have this capability by fall 2022,
                               but the current information provided did not have a specific time frame
                               for implementing this new functionality. In our view, implementing this
                               system function would increase the agency’s ability to collect amounts
                               owed by individuals for COVID‑19 benefits.

                               10.114 Recommendation. To increase the recovery of COVID‑19
                               amounts owed and reduce the administrative burden, the Canada
                               Revenue Agency should, before the end of December 2022, put
                               system functionalities in place to apply refunds against COVID‑19
                               amounts owed.

                               The agency’s response. Agreed.

                               See Recommendations and Responses at the end of this report for
                               detailed responses.

                               10.115 Recommendation. To improve the usefulness of information and
                               the transparency of COVID‑19 reporting, the Canada Revenue Agency
                               should improve its information collection and reporting capabilities to
                               accurately report for each benefit program how much has been collected
                               for each individual and business.

                               The agency’s response. Agreed.

                               See Recommendations and Responses at the end of this report for
                               detailed responses.

                               Unrecoverable amounts

                               10.116 Our findings above highlight the importance of post‑payment
                               verifications and of sending notifications of amounts individuals and
                               businesses owe the government as soon as possible so the collection
                               process to recuperate amounts can start. During the collection process,
                               situations may arise that limit recovery of amounts owed by businesses
                               and individuals (for example, bankruptcies, inability to repay, inability
                               to locate recipients, or potential fraudulent activities). During the audit,
                               we were told that Employment and Social Development Canada and the
                               Canada Revenue Agency had identified cases and referred some of them
                               to law enforcement for investigation:
                                  • As of June 2022, the department identified approximately
                                    13,000 cases of identity theft in Employment Insurance Emergency
                                    Response Benefit payments worth $7.9 million.



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                                  • As of July 2022, the agency identified more than 23,000 cases of
                                    identity theft in COVID‑19 benefit payments for individuals worth
                                    $131 million.
                                  • As of September 2022, the agency and the department had
                                    identified employees that claimed COVID‑19 benefits.
                                  • As of June 2022, for the Canada Emergency Wage Subsidy,
                                    36 referrals worth $60 million were under criminal investigation
                                    for suspicious activities, and payments to 179 business accounts
                                    worth $39 million were identified as amounts paid as a result of
                                    unauthorized access.

                               10.117 We did not carry out additional audit procedures on the cases
                               identified above because they were being internally reviewed or were
                               already referred to law enforcement for investigation.

                               10.118 When the agency and department have exhausted all avenues
                               of collection, the amount still owed on cases that could not be collected
                               will be reported either as write‑offs5 each year in the Government of
                               Canada’s consolidated financial statements, or in volume 3 of the Public
                               Accounts of Canada6 under loss of public money. At the time of our
                               audit, the agency had not reported any write‑off amount or loss of public
                               money related to COVID‑19 benefits. The department had reported
                               $9.7 million for 2020–21 and $75,000 for 2021–22 as written‑off, and
                               had also reported $7.6 million for 2021–22 in the public accounts as a
                               loss of public money.

                               10.119 We found that it was too early to assess the total potential
                               unrecoverable amounts related to COVID‑19 programs that we audited
                               given the limited number of post‑payment verifications and collection
                               activities completed. It will take many years to have an accurate and
                               complete summary of unrecoverable amounts.



Conclusion
                               10.120 We concluded that COVID‑19 programs offered quick financial
                               relief to individuals and employers. In this way, they prevented an
                               increase in poverty and income inequalities and helped the economy
                               bounce back from the effects of the pandemic.

                               10.121 Offering quick financial relief to individuals and employers, as
                               requested by the government, was made possible by the early decision

                                   5     Write‑off—Cancellation of an amount owed, removal from official records,
                                   and acknowledgement of the loss or failure to recover by reporting it in the financial
                                   statements.
                                   6    Public Accounts of Canada—The government’s annual report, which includes
                                   the audited consolidated financial statements of the Government of Canada and other
                                   unaudited financial information, such as the financial statements discussion and analysis
                                   and supporting tables.



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                               to rely on attestations and limited pre‑payment controls. However, we
                               found that this approach resulted in $4.6 billion of overpayments made
                               to ineligible recipients of benefits for individuals. We also estimated
                               that this resulted in at least $27.4 billion of payments that were made
                               to individuals and employers that should be investigated further to
                               verify eligibility. We concluded that the Canada Revenue Agency and
                               Employment and Social Development Canada did not manage the
                               selected COVID‑19 programs efficiently given the significant amount
                               paid to ineligible recipients, the limited adjustments as programs were
                               extended, and the slow progress on post‑payment verifications.

                               10.122 Finally, we concluded that the department and the agency
                               were not performing a sufficient number of post‑payment verifications
                               to be able to identify payments made to ineligible recipients. While,
                               the department and agency had received approximately $2.3 billion
                               in repayments, collection activities had only just begun and much
                               work remains once post‑payment verifications are completed. The
                               actions taken by the department and the agency to identify and recover
                               overpayments or payments made to ineligible recipients have not been
                               timely. Significant unrecoverable amounts are likely to materialize.




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Part 2—Additional Information and Findings on
Specific COVID-19 Programs

A—Canada Emergency Response Benefit
Overview of the program

                               Objective

                               10.A.1 The purpose of the Canada Emergency Response Benefit
                               was to support individuals who lost income as a result of the
                               COVID-19 pandemic. That support was to
                                  • help affected individuals meet their financial obligations
                                  • allow individuals to stay home to help stop further spread
                                    of the virus
                                  • reduce the disease’s toll on individuals and the health care system

                               10.A.2 Individuals could apply for the benefit either through the Canada
                               Revenue Agency or through Employment and Social Development
                               Canada. The applications for the benefit received by Employment and
                               Social Development Canada were known as the Employment Insurance
                               Emergency Response Benefit.

                               10.A.3 In this report, we refer to the combined Canada Emergency
                               Response Benefit and Employment Insurance Emergency Response
                               Benefit as the Canada Emergency Response Benefit, unless there is a
                               need to distinguish between them.

                               Roles and responsibilities

                               10.A.4 Policy development and program design: Employment and
                               Social Development Canada

                               10.A.5 Administration: Employment and Social Development Canada
                               (Employment Insurance Emergency Response Benefit) and Canada
                               Revenue Agency (Canada Emergency Response Benefit)

                               Period of availability of the benefit

                               10.A.6      From 15 March 2020 to 3 October 2020




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                               Support to recipient

                               10.A.7      The support was as follows:


                               Gross amount per week:                    $500.00

                               Tax withholding at source:                None

                               Net amount per week:                      $500.00

                               Income tax impact:                        • Canada Emergency Response
                                                                           Benefit: taxable through T4A slip
                                                                           (RL-1 for Quebec residents)
                                                                         • Employment Insurance
                                                                           Emergency Response Benefit:
                                                                           taxable through T4E slip (T4E(Q)
                                                                           for Quebec residents)

                               Interest on erroneous payments            None
                               or overpayment:


Program delivery and
controls

                               Eligibility conditions and pre-payment controls

                               10.A.8 The pre-payment controls were different—both in type of control
                               and in number of controls implemented—for the Employment Insurance
                               Emergency Response Benefit and the Canada Emergency Response
                               Benefit. As this was an emergency benefit, the program was designed
                               to rely on applicants’ attestation of eligibility, with limited pre-payment
                               controls. This was to allow benefits to be paid to Canadians as quickly as
                               possible. In addition, much of the information needed to put pre-payment
                               controls in place, such as income tax information, was not available at
                               the time payments were being issued.

                               10.A.9 Benefit applications were processed by either the agency
                               or department using different information technology systems.
                               Exhibit 10.A‑1 summarizes the controls implemented for pre-validation
                               of criteria for the Canada Emergency Response Benefit program. Some
                               eligibility criteria were not verified through pre-payment controls, as
                               shown in Exhibit 10.A-1. As with other COVID-19 programs, Employment
                               and Social Development Canada and the Canada Revenue Agency
                               decided to put the emphasis on post-payment verifications to confirm
                               the eligibility of recipients.




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Exhibit 10.A-1—Summary of pre-payment controls for eligibility criteria for the Canada Emergency
Response Benefit (CERB) and the Employment Insurance Emergency Response Benefit (EI-ERB)


                                                                                  CERB—                  EI‑ERB—
                            Eligibility criteria1                           Pre‑payment control     Pre‑payment control
                                                                                  applied                 applied
                                                                                          2                       3
     Is a resident in Canada


     Is at least 15 years old at the time of application4


     Earned at least $5,000 in the 12 months leading                                      5

     up to the application or in 2019 from 1 of the
     following sources:
     • employment income
     • self-employment income
     • maternity and parental benefits from Employment
       Insurance or a provincial plan


     Did not quit or voluntarily cease their employment


     Is affected by the COVID-19 pandemic in 1 of the
     following ways:
     • had work hours reduced because of the pandemic
       and, as of mid-April 2020, does not expect to
       receive more than $1,000 over a period of at least
       14 consecutive days during the 4-week period the
       application covers
     • stopped working because of the pandemic for at least
       14 consecutive days within the 4-week period the
       application covers
     • is unable to work because of the pandemic, including
       because of the need to take care of a dependant
     • received regular Employment Insurance or fishing
       benefits for at least 1 week since 29 December 2019
       and exhausted those benefits

      Yes           Partial           No
1
  This exhibit is intended to summarize some of the eligibility information as administered by Employment and Social
Development Canada and the Canada Revenue Agency at the time of program delivery. The complete list of detailed criteria is
included in the Canada Emergency Response Benefit Act and the Employment Insurance Act.
2
    Control was limited to restricting applicants without a social insurance number.
3
 Control was limited to redirecting applicants with selected types of social insurance numbers to contact Employment and
Social Development Canada.
4
    This criterion was not required for all applicants for EI-ERB.
5
    Control was limited as discussed in paragraphs 10.67 and 10.68 in Part 1 of our report.




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                               Limited pre-payment controls

                               10.A.10 The following are additional examples supporting our finding
                               of limited pre-payment controls. These examples of pre-payment
                               controls that were added during the programs should be read with
                               paragraphs 10.67 to 10.70 in Part 1 of our report.

                               10.A.11 Finding. We found that the Canada Revenue Agency and
                               Employment and Social Development Canada added some pre-payment
                               controls throughout the Canada Emergency Response Benefit program.
                               Examples include the following:
                                  • Days after the benefit program was launched, a pre-payment
                                    control was put in place to prevent applicants from receiving more
                                    than 1 benefit at the same time.
                                  • In July 2020, the agency automatically stopped payments to
                                    applicants once they had reached the maximum number of periods
                                    allowable for the benefit.
                                  • The agency and the department also increased pre-payment
                                    controls by stopping applications considered high risk or suspicious.

                               10.A.12 However, the department’s and agency’s systems did not track
                               all the applications they automatically stopped. As a result, we could
                               not determine the effectiveness or the number of applications stopped
                               by these controls. We also noted that several payments were made to
                               ineligible recipients despite those additional pre-payment controls.

                               10.A.13 Finding. Over the course of the program, the Canada Revenue
                               Agency added a control related to the minimum $5,000 earning criterion.
                                  • Starting in July 2020, the agency stopped some applicants from
                                    receiving benefits who did not appear to meet the income eligibility
                                    criterion and asked them to provide additional information to
                                    confirm eligibility.
                                  • In fall 2020, the agency reviewed benefit payments made and
                                    identified over 1 million recipients that did not appear to meet the
                                    income eligibility criterion. Instead of stopping these applicants
                                    from receiving benefits as soon as they were identified, the agency
                                    chose to contact approximately 440,000 of those individuals via
                                    letters to inform them of the program eligibility criteria. In our view,
                                    these 440,000 recipients, whom the agency estimated received
                                    $5.8 billion in payments, should have stopped receiving payments as
                                    soon as they were identified. See our recommendation in Part 1 at
                                    paragraph 10.101.

Summary information

                               10.A.14 Exhibit 10.A-2 summarizes information about the Canada
                               Emergency Response Benefit, including about payments, overpayments,
                               and payments to ineligible recipients or to recipients that should be
                               investigated further.

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                                  10.A.15 The payments identified in Exhibit 10.A-2 are based on the best
                                  information available to the Canada Revenue Agency and Employment
                                  and Social Development Canada as at 31 March 2022. Note that much
                                  of the information was not available to the department and agency when
                                  the payments were issued unless they contacted the applicants, which
                                  would have hindered payment expediency. This was because it was not
                                  requested on the applications and was not readily available through
                                  income tax return information. For example, the $5,000 income criterion
                                  could be calculated using earnings from the 12 months prior to the
                                  application date. Additional information would be provided to the agency
                                  or department if requested as part of post-payment verification work.

Exhibit 10.A-2—Summary information for the Canada Emergency Response Benefit program

                                                                      Number of unique
                                                                                                         Total amount
                                                                         recipients
                                                                                                          (in billions)
                                                                        (in millions)

    Recipients who received a benefit payment and                                          8.5                           $74.8
    total amount paid as at 31 March 2022


                                                                                                        Days (average)

    Amount of time between receipt of application and issuance of payment                                                       3
    (for Canada Revenue Agency–managed program only)


                        Overpayments or payments to recipients that either were ineligible
                             or should be investigated further1 (as at 31 March 2022)

                                                                      Number of unique                   Total amount
      Program requirement at risk of not being met
                                                                         recipients                       (in billions)

    Recipients earned less than $5,000                                               562,540                               $5.2

    Recipients received an advance lump-sum                                        1,845,073                               $3.1
    overpayment for the Employment Insurance
    Emergency Response Benefit

    Recipients earned more than $1,000 during                                      1,414,835                               $3.8
    a 4-week period2

    Recipients received more than 1 benefit per period                               655,066                               $1.4

    Total overpayments or payments to recipients                                  4,063,9653                            $13.43
    that either were ineligible or should be
    investigated further
1
  See paragraphs 10.A.16–10.A.22, which explain how we determined our findings of overpayments or payments to recipients
that either were ineligible or should be investigated further. The results specific to the Canada Emergency Response Benefit are
included in the overall findings from Part 1, Exhibit 10.9.
2
 Findings are based on eligibility information as administered by Employment and Social Development Canada and the Canada
Revenue Agency at the time of program delivery.
3
 Some payments have been identified as ineligible in more than 1 program requirement. Therefore, we adjusted our findings to
exclude duplicates.



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                   Other instances of payments to recipients that should be investigated further1
                               excluded from the total above (as at 31 March 2022)

                                                                    Number of unique                   Total amount
       Program requirement at risk of not being met
                                                                       recipients                       (in millions)

    Recipients quit their employment                                              190,254                          $1,601

    Recipients received duplicate benefit payment                                      692                              $4.6

    Recipients were incarcerated for the entire                                      1,522                              $6.1
    benefit period

    Recipients did not reside in Canada                                                704                              $3.3

    Recipients were below 15 years old at the time of                                  434                              $2.2
    application2

    Recipients were deceased                                                           391                              $1.2
1
  See paragraphs 10.A.16–10.A.22, which explain how we determined our findings of payments to recipients that should be
investigated further.
2
    All instances relate to payments made under the Employment Insurance Emergency Response Benefit.

      Post-payment verifications and collections as at
                                                                    Number of unique                   Total amount
      June 2022 for the agency and July 2022 for the
                                                                       recipients                       (in billions)
                       department

    Amounts owed established following                                 Unable to confirm               Unable to confirm
    post‑payment verification by the agency

    Amounts owed established following                                 Unable to confirm                                $3.2
    post‑payment verification by the department

    Benefit payments in collection                                                        0                                   0

    Benefit repayments for the agency and                              Unable to confirm                                $2.2
    department1
1
    Benefit repayments are unaudited—see paragraphs 10.A.27–10.A.28.




Assumptions

                                   10.A.16 Below we list some assumptions and provide further
                                   explanations on our findings of overpayments and payments to
                                   recipients of the Canada Emergency Response Benefit that either
                                   were ineligible or should be investigated further as summarized in
                                   Exhibit 10.A-2. Given the assumptions used in our analysis, the amounts
                                   reported in Exhibit 10.A-2 are the minimum amounts that should be
                                   investigated further through post-payment verifications.




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                               Amount paid to recipients who earned less than $5,000

                               10.A.17 To be eligible for the Canada Emergency Response Benefit,
                               most applicants had to have earned at least $5,000 in the 12 months
                               leading up to the application or in the 2019 calendar year. We performed
                               an analysis and relied on personal income tax returns filed by individuals
                               to assess if the eligibility criterion was met. We identified recipients
                               as ineligible or at risk of being ineligible if their combined 2019
                               and 2020 earnings (gross earnings for self-employed) were below
                               $5,000. A less conservative approach would have been to use an average
                               of the 2019 and 2020 earnings instead of combining them. This would
                               have led to an increase in ineligible recipients being identified in our
                               analysis.

                               Amount paid to recipients who received more than $1,000 during
                               a 4-week period

                               10.A.18 As of mid-April 2020, Employment and Social Development
                               Canada and the Canada Revenue Agency began to administer the
                               program to permit Canada Emergency Response Benefit recipients
                               to earn up to $1,000 during a 4-week period and still receive a benefit
                               payment. We performed our analysis in the same way that both the
                               department and agency administered this eligibility criterion at the
                               time of program delivery. In order to assess this eligibility criterion,
                               we relied on the disaggregated income information employers were
                               required to report on the employee’s T4 for 2020. The reliability of the
                               information included on the employee’s T4 will be determined only once
                               post-payment verification activities occur. Given that the additional
                               information on the T4 combined 2 benefit periods, it is impossible to
                               determine during which of the 2 periods the income was earned unless
                               additional information is obtained from the recipient.

                               10.A.19 For example, income earned during benefit period 1 and
                               period 2 were combined in the additional information reported on
                               box 57 of the T4. For the purpose of our audit, we performed an analysis
                               and made the presumption that all of the earnings in box 57 applied to
                               period 1. As a result, we identified the period 1 payment as ineligible and
                               the period 2 payment as eligible. A less conservative analysis would have
                               been to assume that the earnings in box 57 were earned equally between
                               benefit periods 1 and 2 and to deem both payments as ineligible. This
                               would have increased payments to ineligible recipients to $6.8 billion.
                               The results of the more conservative approach have been shown in
                               Exhibit 10.A-2.

                               Amount paid to recipients who quit their employment

                               10.A.20 In order to apply for a benefit, applicants had to attest that
                               they had not quit their employment. To expedite payments, applicants
                               were not required to submit a record of employment (ROE) to receive



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                               the Canada Emergency Response Benefit, as is typically the case
                               when receiving regular Employment Insurance benefits. Employees
                               whose ROE includes their status as having quit are usually unable to
                               receive Employment Insurance benefits unless Employment and Social
                               Development Canada performs validation activities to determine that
                               benefits should be paid to them. Employers continued to submit ROEs to
                               the department as required.

                               10.A.21 For the purpose of our work, we considered the information
                               about ROEs to be an indicator of risk and payments that should be
                               investigated further given that this information has not been validated
                               to confirm its reliability. The department collects the ROE information to
                               manage regular Employment Insurance benefits. At the time of our audit
                               the department had not shared this information with the agency.

                               Amount paid to recipients who did not reside in Canada

                               10.A.22 Applicants had to attest that they resided in Canada to be
                               eligible for the benefit. We identified recipients who had both their home
                               and their mailing addresses on record at the Canada Revenue Agency as
                               being outside of Canada. We considered them as recipients of payments
                               that should be investigated further to confirm eligibility.

Post-payment
verifications and
collection

                               Incomplete post-payment verification plans and delays in conducting
                               verifications for individuals

                               10.A.23 Finding. We found, as noted in Part 1 of this report, that
                               Employment and Social Development Canada’s and the Canada Revenue
                               Agency’s post‑payment verification plans were incomplete. The plans
                               did not include all the post-payment verification work. In addition, the
                               department and agency delayed their post-payment verifications.

                               10.A.24 We found that Employment and Social Development Canada’s
                               post‑payment verifications for the Employment Insurance Emergency
                               Response Benefit, initially planned to start in November 2021,
                               were delayed. The initial post-payment verification plan, dated
                               January 2021, covered a period of 4 years starting in 2021–22 and a
                               total of 157,000 verifications. The revised version of the plan included
                               fewer than 130,000 verifications starting in 2022–23 to be completed
                               by 2024–25. Issuance of post-payment verification letters started in
                               May 2022. As of August 2022, the department had no results to report
                               on its post-payment verifications.

                               10.A.25 We found that the Canada Revenue Agency’s post-payment
                               verification plan dated April 2022 focused mostly on the Canada
                               Emergency Response Benefit. It included 3 phases of review and a total



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                               of 300,000 cases to be reviewed for all COVID-19 benefit programs
                               for individuals. After multiple delays, the agency started phase 1 of its
                               post-payment verification work for the Canada Emergency Response
                               Benefit in January 2022, using its Business Intelligence Division and
                               available data. We found that this work permitted the agency to identify
                               over 2.1 million cases where individuals had potentially received more
                               than $1,000 in employment and/or self-employment income during the
                               benefit period and could potentially be ineligible. From the 2.1 million
                               cases identified, the agency contacted only around 104,000 recipients
                               and asked them to provide additional information to confirm
                               eligibility. Only 10,743 (10.3%) replies were received by the agency as
                               of 12 May 2022.

                               10.A.26 In addition, as of August 2022, post-payment verification
                               work was ongoing related to individuals who were stopped from
                               receiving any further benefits and were asked by the agency to provide
                               additional information. For example, 475,495 individuals who received
                               $5 billion in Canada Emergency Response Benefit payments were
                               requested to provide additional information to confirm that they met the
                               $5,000 income threshold. The agency told us that it would complete any
                               remaining verifications as part of its post-payment verification work.
                               While the agency intended to perform post-payment verifications on
                               those payments, this work had not been included in its post-payment
                               verification plan.

                               Collection work status

                               10.A.27 Collection activities had not started on Canada Emergency
                               Response Benefit payments as of July 2022. The agency and
                               department respectively reported repayments of benefits of
                               approximately $2.2 billion composed of $1.3 billion as of July 2022 for
                               Employment and Social Development Canada, and $900 million as
                               of June 2022 for the Canada Revenue Agency. We were unable to
                               confirm the amounts the agency received from individuals for each
                               of the COVID-19 programs under audit because of a lack of detailed
                               and disaggregated reporting data. For example, the agency told us
                               that over 25,000 notices, totalling over $71 million, were issued as of
                               July 2022, but those numbers included the Canada Emergency Response
                               Benefit and other amounts owed that were not part of this audit. See our
                               recommendation in Part 1 at paragraph 10.115.

                               10.A.28 Similarly, while there is $3.2 billion of amounts owing following
                               post‑payment verifications (identified in Exhibit 10.A-2), we were unable
                               to confirm when the agency and department sent notifications to
                               recipients because of a lack of detailed and reliable reporting.




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Demographic
information

Exhibit 10.A-3—Demographic information about recipients of the Canada Emergency Response
Benefit as at 31 March 2022
                                              Nunavut
                                                                                                     Number of recipients           Total amount (in millions)
                                                    9,727
                         Northwest
                                                    92.3
                         Territories
                            11,235                                                                   Total recipients by province and territory
                            108.4                                                                        8,510,452 (including 211,306 unknown*)
                                                                                                         74,815.2 (including $511.2 unknown*)
      Yukon
        8,687                                                                                       Quebec
        77.5                                                                                         1,876,869
                                                                                                     15,440.7
                                                                                                                     Newfoundland
                                                                                                                     and Labrador
      British                                                                                                            109,732
     Columbia                                                                                                            944.8
       1,117,200
       10,228.9

                                                                                                                      Prince Edward
                                                                                                                          Island
          Alberta                                                                                                          32,589
           999,850                                                                                                         261.9
           9,242.2

                            Saskatchewan                                                                             Nova Scotia
                                224,135                                                                                  202,373
                                                     Manitoba                                 New Brunswick
                                2,029.7                                      Ontario                                     1,811.2
                                                       258,168                                      156,163
                                                       2,260.7               3,292,418              1,320.2
                                                                             30,485.5



                                     Canada Emergency Response Benefit recipients by gender

                                                               Unknown*                                                                    Unknown*
                                                                 191,867                                                                    $329.7
               Female                                                                         Female
               4,076,879                                                                     $37,229.8

                                                                                                                   $74,815.2
                                       8,510,452                                                                    million

                                                               Male                                                                        Male
                                                            4,241,706                                                                  $ 37,255.7




                                Canada Emergency Response Benefit recipients by age group

                                                      25–34 age                                                                      25–34 age
                  0–24 age                             2,032,570                                   0–24 age                          $18,069.0
                   1,001,254                                                                       $8,683.6

                                                                                         Unknown*
       Unknown*                                                                           $313.5
        189,236
                                                                                            65+ age
            65+ age                                                                         $6,642.1               $74,815.2
               721,487                 8,510,452                 35–44 age                                                                  35–44 age
                                                                                                                    million                  $15,387.6
                                                                 1,696,397

                                                                                             55–64 age
                55–64 age                                                                     $12,600.0
                  1,414,444
                                                   45–54 age                                                                45–54 age
                                                   1,455,064                                                                   $13,119.4


* Unknown means that gender, age, or province of residence was either missing or not specified in the information provided by the Canada
Revenue Agency.
Note: Dollars in the exhibit are rounded.
Source: Data provided by the Canada Revenue Agency and Employment and Social Development Canada


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B—Canada Recovery Benefit
Overview of the program

                               Objective

                               10.B.1 The Canada Recovery Benefit succeeded the Canada
                               Emergency Response Benefit and gave income support to employed and
                               self‑employed individuals who were directly affected by COVID-19 and
                               were not entitled to Employment Insurance benefits.

                               Roles and responsibilities

                               10.B.2 Policy development and program design: Employment and
                               Social Development Canada

                               10.B.3      Administration: Canada Revenue Agency

                               Period of availability of the benefit

                               10.B.4      From 27 September 2020 to 23 October 2021

                               Support to recipient

                               10.B.5      The support was as follows:


                               Gross amount per week:                    $500.00, reduced to $300.00 for
                                                                         individuals who received payments
                                                                         for a total of 42 weeks or applied
                                                                         for the first time for a benefit period
                                                                         beginning on or after 18 July 2021

                               Tax withholding at source:                10% ($50.00 or $30.00)

                               Net amount per week:                      $450.00 or $270.00

                               Income tax impact:                        Taxable through T4A slip (RL-1 for
                                                                         Quebec residents)

                               Interest on erroneous payments            None
                               or overpayment:


Program delivery and
controls

                               Eligibility conditions and pre-payment controls

                               10.B.6 For the Canada Recovery Benefit, several eligibility criteria
                               were not verified through pre-payment controls, as summarized
                               in Exhibit 10.B‑1. The program was designed to rely on applicants’
                               attestation of eligibility, with limited pre-payment controls. This was to


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                                      allow benefits to be paid to Canadians as quickly as possible. In addition,
                                      much of the information that was needed to put pre-payment controls in
                                      place was not available at the time payments were being issued. As with
                                      other COVID-19 programs, the emphasis would be put on post-payment
                                      verification to confirm the eligibility of recipients.

Exhibit 10.B-1—Summary of pre-payment controls for eligibility criteria for the Canada
Recovery Benefit

                                     Eligibility criteria1                                    Pre-payment control applied

     Has a valid social insurance number

                                                                                                              2
     Is a resident in Canada


     Is present in Canada


     Is at least 15 years old on the first day of the benefit period


     Earned at least $5,000 in the 12 months leading up to the application or                                 3

     in 2019 or 2020 (depending on the timing of the application) from 1 of
     the following sources:
     • employment income
     • self-employment income
     • maternity and parental benefits from Employment Insurance or
       a provincial plan, or regular or special benefits from Employment
       Insurance if the claim began on or after 27 September 2020


     Is not receiving benefits under other programs


     Is not required to isolate as a result of travel


     Has met all conditions related to quitting or voluntarily ceasing to work


     Filed a tax return4


     Experienced a reduction of at least 50% of average weekly employment
     or self-employment income during the period covered by the
     application

      Yes           Partial           No
1
  This exhibit is intended to summarize some of the eligibility information as administered by the Canada Revenue Agency at the
time of program delivery. The complete list of detailed criteria is included in the Canada Recovery Benefits Act.
2
    Control was limited to restricting applicants without a social insurance number.
3
    Control was limited as discussed in paragraphs 10.67 and 10.68 in Part 1 of our report.
4
    Filing of a tax return was required for some applicants starting in July 2021.


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Summary information

                                   10.B.7 Exhibit 10.B-2 summarizes information about the Canada
                                   Recovery Benefit regarding payments to recipients that either were
                                   ineligible or should be investigated further.

                                   10.B.8 The payments identified in Exhibit 10.B-2 are based on
                                   the best information available to the Canada Revenue Agency as
                                   at 31 March 2022. We noted that much of the information was not
                                   available to the agency when the payments were issued unless the
                                   agency contacted the applicants, which would have hindered payment
                                   expediency. This was because the information was not requested
                                   on the applications and was not readily available through income tax
                                   return information. For example, the $5,000 income criterion could be
                                   calculated using earnings from the 12 months prior to the application
                                   date. Additional information would be provided to the agency if
                                   requested as part of post-payment verification work.

Exhibit 10.B-2—Summary information for the Canada Recovery Benefit

                                                                       Number of unique                  Total amount net
                                                                          recipients                          of taxes
                                                                         (in millions)                      (in billions)

    Recipients who received a benefit payment and                                            2.3                           $25.6
    total amount paid as at 31 March 2022


                                                                                                          Days (average)

    Amount of time between receipt of application and issuance of payment                                                           4


               Payments to recipients that either were ineligible or should be investigated further1
                                              (as at 31 March 2022)

                                                                                                         Total amount net
                                                                       Number of unique
      Program requirement at risk of not being met                                                           of taxes
                                                                          recipients
                                                                                                           (in millions)

    Recipients earned less than $5,000                                                 194,558                            $2,147

    Recipients received more than 1 benefit per period                                  68,095                                  $88

    Total payments to recipients who were either                                     259,5022                             2,2312
    ineligible or should be investigated further
1
  See paragraphs 10.B.9–10.B.13, which explain how we determined our findings of payments to recipients that either were
ineligible or should be investigated further. The results specific to the Canada Recovery Benefit are included in the overall
findings from Part 1, Exhibit 10.9.
2
 Some payments have been identified as ineligible in more than 1 program requirement. Therefore, we adjusted our finding to
exclude duplicates.




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             Other instances of payments to recipients that should be investigated further1 excluded
                                   from the total above (as at 31 March 2022)

                                                                    Number of unique                Total amount net
      Program requirement at risk of not being met
                                                                       recipients                       of taxes

    Recipients were below age 15 on the first day of                                       0                                 0
    the benefit period

    Recipients were not present in Canada                                                85                      $368,100

    Recipients quit their employment                                                64,922                   $563,419,170

    Recipient were incarcerated for the entire                                          384                      $640,980
    benefit period

    Recipients were deceased                                                            141                      $360,810

    Recipients received duplicate benefit payment                                     1,661                    $4,003,740

    Recipients failed to file a tax return                                                 0                                 0
1
  See paragraphs 10.B.9–10.B.13, which explain how we determined our findings of payments to recipients that should be
investigated further.

        Post-payment verifications and collections                  Number of unique
                                                                                                      Total amount
                   as at June 2022                                     recipients

    Amounts owed established following                                  Unable to confirm              Unable to confirm
    post‑payment verifications

    Benefit payments in collection                                                         0                                 0

    Benefit repayments1                                                 Unable to confirm                     $44,685,717
1
 Amounts of benefit repayments were provided by the Canada Revenue Agency but could not be audited because of a lack of
detailed and disaggregated reporting data. See our finding in Part 1, paragraph 10.112.



Assumptions

                                  10.B.9 Below we list some assumptions and provide further
                                  explanations on our findings of payments to recipients of the Canada
                                  Recovery Benefit that either were ineligible or should be investigated
                                  further, as summarized in Exhibit 10.B-2. Given the assumptions
                                  used in our analysis, the amounts reported in Exhibit 10.B‑2 are
                                  the minimum amounts that should be investigated further through
                                  post-payment verifications.

                                  Amount paid to recipients who earned less than $5,000

                                  10.B.10 To be eligible for the Canada Recovery Benefit, applicants
                                  had to have earned at least $5,000 in the 12 months leading up to the
                                  application or in the 2019 or 2020 calendar year, depending on the timing
                                  of the application. We performed an analysis and relied on personal


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                               income tax returns filed by individuals to assess if the eligibility criterion
                               was met. We identified recipients as ineligible or at risk of being ineligible
                               if their combined 2019 and 2020 earnings were below $5,000. A less
                               conservative approach would have been to use an average of the 2019
                               and 2020 earnings instead of combining them. This would have led to an
                               increase in ineligible recipients being identified in our analysis.

                               Amount paid to recipients who quit their employment

                               10.B.11 In order to apply for a benefit, applicants had to attest that
                               they had not quit their employment. To expedite payments, applicants
                               were not required to submit a record of employment (ROE) to receive
                               the Canada Recovery Benefit, as is typically the case when receiving
                               regular Employment Insurance benefits. Employees whose ROE includes
                               their status as having quit are usually unable to receive Employment
                               Insurance benefits unless Employment and Social Development Canada
                               performs validation activities to determine that benefits should be
                               paid to them. Employers continued to submit ROEs to the department
                               as required.

                               10.B.12 For the purpose of our work, we considered the information
                               about ROEs as an indicator of risk and payments that should be
                               investigated further, given that the information has not been validated
                               to confirm its reliability. The department collects the ROE information
                               to manage regular Employment Insurance benefits. At the time of our
                               audit, the department had not shared this information with the Canada
                               Revenue Agency.

                               Amount paid to recipients who were not present in Canada

                               10.B.13 Applicants had to attest that they were a resident and present
                               in Canada to be eligible for the benefit. We identified recipients who
                               had both their home and their mailing addresses on record at the
                               Canada Revenue Agency as being outside of Canada. We considered
                               them as recipients of payments that should be investigated further to
                               confirm eligibility.

Post-payment
verifications and
collection

                               Incomplete post-payment verification plans and delays in conducting
                               verifications for individuals

                               10.B.14 Finding. We found, during our review of the Canada Revenue
                               Agency’s post-payment verification plan, that the plan was incomplete.
                               It did not include all post-payment verifications the agency intended to
                               perform. For example, the plan excluded individuals who had already




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to the Parliament of Canada—2022
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                               received benefit payments and who were subsequently prevented from
                               receiving further benefits until they provided additional information
                               needed to assess their eligibility.

                               10.B.15 In addition, the post-payment verification plan was developed
                               based on eligibility criteria and not on individual programs. Therefore,
                               we could not find specific information related to post-payment
                               verifications for the Canada Recovery Benefit. The only information
                               the agency included in the post-payment verification plan was that
                               a total of 150,000 cases would be reviewed including the Canada
                               Recovery Benefit and the other COVID-19 programs for individuals.
                               The number of cases that will be reviewed for each of these individual
                               COVID-19 programs was not specified, nor was the time frame in which
                               they would be done.

                               Post-payment verification work status

                               10.B.16 As of August 2022, post-payment verification work for the
                               Canada Recovery Benefit was limited to individuals who were stopped
                               from receiving any further benefits as part of pre-payment controls
                               and were asked by the Canada Revenue Agency to provide additional
                               information. For example, 270,300 individuals who received $2.7 billion in
                               Canada Recovery Benefit payments were requested to provide additional
                               information to confirm that they met the $5,000 income threshold. The
                               agency told us that it would complete any remaining verifications as part
                               of its post-payment verification work.

                               Collection work status

                               10.B.17 Collection activities had not started on Canada Recovery
                               Benefit payments as of July 2022. The agency reported that repayments
                               of these benefits of approximately $44.7 million were received as
                               of 30 June 2022. We were unable to confirm the amounts the agency
                               received from individuals for each of the COVID-19 programs under audit
                               because of a lack of detailed and disaggregated reporting data. See our
                               recommendation in Part 1 at paragraph 10.115.




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Demographic
information

Exhibit 10.B-3—Demographic information about recipients of the Canada Recovery Benefit as
at 31 March 2022
                                            Nunavut
                      Northwest
                                                 3,270                                           Number of recipients           Total amount (in millions)
                                                 22.2
                      Territories
                          3,752
                          33.2
                                                                                                 Total recipients by province and territory
                                                                                                     2,299,522 (including 630 unknown*)
                                                                                                     25,568.3 (including $4.9 unknown*)
      Yukon
         2,308                                                                                  Quebec
         23.5                                                                                    394,062
                                                                                                 4,129.4
                                                                                                                  Newfoundland
                                                                                                                  and Labrador
      British                                                                                                          26,713
     Columbia                                                                                                          262.6
        288,089
        3,315.4

                                                                                                                  Prince Edward
                                                                                                                      Island
          Alberta                                                                                                      5,922
           309,923
                                                                                                                       64.0
           3,354.1


                          Saskatchewan                                                                            Nova Scotia
                                 64,305                                                                              52,983
                                                 Manitoba                                 New Brunswick
                                 643.9                                       Ontario                                 541.8
                                                        75,930                                  34,799
                                                        732.3                1,036,836
                                                                                                357.6
                                                                             12,083.4



                                           Canada Recovery Benefit recipients by gender

                                                                 Unknown*                                                            Unknown*
                                                                                                                                        $2.0
                                                                   203
                Female                                                                    Female
            1,094,272                                                                    $11,565.5


                                                                                                               $25,568.3
                                    2,299,522                                                                   million


                                                                Male                                                                 Male
                                                          1,205,047                                                                $14,000.8




                                          Canada Recovery Benefit recipients by age group

                     65+ age                     0–24 age                                        65+ age                        0–24 age
                      177,802                     268,385                                        $2,250.6                        $2,459.8



           55–64 age                                                                     55–64 age
            389,614                                                                       $4,866.6
                                                                                                                                       25–34 age
                                                                 25–34 age                                     $25,568.3                $5,613.6
                                     2,299,522                    556,710                                       million

           45–54 age
                420,653                                                                   45–54 age
                                                                                           $5,017.5
                                                   35–44 age                                                                    35–44 age
                                                        486,358                                                                  $5,360.2


* Unknown means that gender, age, or province of residence was either missing or not specified in the information provided by the
Canada Revenue Agency.
Note: Dollars in the exhibit are rounded.
Source: Data provided by the Canada Revenue Agency



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C—Canada Recovery Caregiving Benefit
Overview of the program

                               Objective

                               10.C.1 The Canada Recovery Caregiving Benefit gave income support
                               to employed and self-employed individuals who were unable to work
                               because they were caring for their child under 12 years old or a family
                               member who needed supervised care. This applied if the child's or family
                               member’s school, regular program, or facility was closed or unavailable
                               to them due to COVID-19 or if they were sick, self-isolating, or at risk of
                               serious health complications due to COVID-19.

                               Roles and responsibilities

                               10.C.2 Policy development and program design: Employment and
                               Social Development Canada

                               10.C.3      Administration: Canada Revenue Agency

                               Period of availability of the benefit

                               10.C.4      From 27 September 2020 to 7 May 2022

                               Support to recipient

                               10.C.5      The support was as follows:

                               Gross amount per week:                    $500.00

                               Tax withholding at source:                10% ($50.00)

                               Net amount per week:                      $450.00

                               Income tax impact:                        Taxable through T4A slip (RL-1 for
                                                                         Quebec residents)

                               Interest on erroneous payments            None
                               or overpayment:


Program delivery and
controls

                               Eligibility conditions and pre-payment controls

                               10.C.6 For the Canada Recovery Caregiving Benefit, several eligibility
                               criteria were not verified through pre-payment controls, as summarized
                               in Exhibit 10.C-1. The program was designed to rely on applicants’
                               attestation of eligibility, with limited pre-payment controls. This was to
                               allow benefits to be paid to Canadians as quickly as possible. In addition,


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to the Parliament of Canada—2022
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                                     much of the information that was needed to put pre-payment controls in
                                     place was not available at the time payments were being issued. As with
                                     other COVID-19 programs, the emphasis would be put on post-payment
                                     verification to confirm the eligibility of recipients.

Exhibit 10.C-1—Summary of pre-payment controls for eligibility criteria for the Canada Recovery
Caregiving Benefit


                                    Eligibility criteria1                                     Pre-payment control applied

     Has a valid social insurance number

                                                                                                              2
     Is a resident in Canada


     Is present in Canada


     Is at least 15 years old on the first day of the benefit period


     Earned at least $5,000 in the 12 months leading up to the application                                    3

     or in 2019, 2020, or 2021 (depending on the timing of the application)
     from 1 of the following sources:
     • employment income
     • self-employment income
     • maternity and parental benefits from Employment Insurance or a
       provincial plan


     Is not receiving benefits under other programs


     Is not required to isolate as a result of travel


     Is the only individual in the household to receive the benefit


     Is not on paid leave from employer for the weeks covered by
     the application

     Is unable to work at least 50% of regular scheduled workweek for 1 of
     the following reasons:
     • caring for a child under 12 years of age
     • caring for a family member who requires supervised care

      Yes           Partial          No
1
  This exhibit is intended to summarize some of the eligibility information as administered by the Canada Revenue Agency at the
time of program delivery. The complete list of detailed criteria is included in the Canada Recovery Benefits Act.
2
    Control was limited to restricting applicants without a social insurance number.
3
    Control was limited as discussed in paragraphs 10.67 and 10.68 in Part 1 of our report.


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to the Parliament of Canada—2022
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Summary information

                                   10.C.7 Exhibit 10.C-2 summarizes information about the Canada
                                   Recovery Caregiving Benefit regarding payments to recipients that either
                                   were ineligible or should be investigated further.

                                   10.C.8 The payments identified in Exhibit 10.C-2 are based on
                                   the best information available to the Canada Revenue Agency as
                                   at 31 March 2022. Note that much of the information was not available to
                                   the agency when the payments were issued unless the agency contacted
                                   the applicants, which would have hindered payment expediency. This
                                   was because it was not requested on the applications and was not
                                   readily available through income tax return information. For example,
                                   the $5,000 income criterion could be calculated using earnings from
                                   the 12 months prior to the application date. Additional information
                                   would be provided to the agency if requested as part of post-payment
                                   verification work.

Exhibit 10.C-2—Summary information for the Canada Recovery Caregiving Benefit


                                                                                                       Total amount net
                                                                      Number of unique
                                                                                                            of taxes
                                                                         recipients
                                                                                                          (in billions)

    Recipients who received a benefit payment and                                     557,617                            $3.82
    total amount paid as at 31 March 2022


                                                                                                         Days (average)

    Amount of time between receipt of application and issuance of payment                                                       4


               Payments to recipients that either were ineligible or should be investigated further1
                                              (as at 31 March 2022)

                                                                                                       Total amount net
                                                                      Number of unique
      Program requirement at risk of not being met                                                         of taxes
                                                                         recipients
                                                                                                         (in millions)

    Recipients earned less than $5,000                                                 93,581                             $879

    Recipients received more than 1 benefit per period                                 11,532                              $13

    Total payments to recipients that either were                                    104,1152                            $8912
    ineligible or should be investigated further
1
  See paragraphs 10.C.9–10.C.11, which explain how we determined our findings of payments to recipients that either were
ineligible or should be investigated further. The results specific to the Canada Recovery Caregiver Benefit are included in the
overall findings from Part 1, Exhibit 10.9.
2
  Some payments have been identified as ineligible in more than 1 program requirement. Therefore, we adjusted our finding so
that duplicates were excluded.




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to the Parliament of Canada—2022
                                                                                                  Specific COVID-19 Benefits



     Other instances of payments to recipients that should be investigated further1 excluded from the total
                                         above (as at 31 March 2022)

                                                                    Number of unique                Total amount net
      Program requirement at risk of not being met
                                                                       recipients                       of taxes

    Recipients were deceased                                                             71                      $142,650

    Recipients were incarcerated for the entire                                         143                      $202,050
    benefit period

    Recipients were below age 15 on the first day                                          0                                 0
    of the benefit period

    Recipients were not present in Canada                                                10                        $13,050

    Recipients received duplicate benefit payment                                          8                       $18,000
1
  See paragraphs 10.C.9–10.C.11, which explain how we determined our findings of payments to recipients that should be
investigated further.

     Post-payment verifications and collections as at               Number of unique
                                                                                                       Total amount
                       June 2022                                       recipients

    Amounts owed established following                                  Unable to confirm              Unable to confirm
    post‑payment verifications

    Benefit payments in collection                                                         0                                 0

    Benefit repayments1                                                 Unable to confirm                      $8,260,001
1
 Amounts of benefit repayments was provided by the Canada Revenue Agency but could not be audited because of a lack of
detailed and disaggregated reporting data. See our finding in Part 1, paragraph 10.112.


Assumptions

                                  10.C.9 Below we list some assumptions and provide further
                                  explanations on our findings of payments to recipients of the Canada
                                  Recovery Caregiving Benefit that either were ineligible or should
                                  be investigated further, as summarized in Exhibit 10.C-2. Given
                                  the assumptions used in our analysis, the amounts reported in
                                  Exhibit 10.C‑2 are the minimum amounts that should be investigated
                                  further through post-payment verifications.

                                  Amount paid to recipients who earned less than $5,000

                                  10.C.10 To be eligible for the Canada Recovery Caregiving Benefit,
                                  applicants had to have earned at least $5,000 in the 12 months leading
                                  up to the application or in the 2019, 2020 or 2021 calendar year,
                                  depending on the timing of the application. We performed an analysis
                                  and relied on personal income tax returns filed by individuals to assess
                                  if the eligibility criterion was met. We identified recipients as ineligible or
                                  at risk of being ineligible if their combined 2019 and 2020 earnings were
                                  below $5,000. A less conservative approach would have been to use an


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to the Parliament of Canada—2022
                                                                                   Specific COVID-19 Benefits


                               average of the 2019 and 2020 earnings instead of combining them. This
                               would have led to an increase in ineligible recipients being identified in
                               our analysis.

                               Amount paid to recipients who were not present in Canada

                               10.C.11 Applicants had to attest that they were a resident and present
                               in Canada to be eligible for the benefit. We identified recipients who
                               had both their home and their mailing addresses on record at the
                               Canada Revenue Agency as being outside of Canada. We considered
                               them as recipients of payments that should be investigated further to
                               confirm eligibility.

Post-payment
verifications and
collection

                               Incomplete post-payment verification plans and delays in conducting
                               verifications for individuals

                               10.C.12 Finding. We found, during our review of the Canada Revenue
                               Agency’s post-payment verification, that the plan was incomplete.
                               It did not include all post-payment verifications the agency intended to
                               perform. For example, the plan excluded individuals who had already
                               received benefit payments and who were subsequently prevented from
                               receiving further benefits until they provided additional information
                               needed to assess their eligibility.

                               10.C.13 In addition, the post-payment verification plan was developed
                               based on eligibility criteria and not on individual programs. Therefore, we
                               could not find specific information related to post-payment verifications
                               for the Canada Recovery Caregiving Benefit. The only information the
                               agency included in the post-payment verification plan was that a total
                               of 150,000 cases would be reviewed including the Canada Recovery
                               Caregiving Benefit and the other COVID-19 programs for individuals.
                               The number of cases that will be reviewed for each of these individual
                               COVID-19 programs was not specified, nor was the time frame in which
                               they would be done.

                               Post-payment verification work status

                               10.C.14 As of August 2022, post-payment verification work for the
                               Canada Recovery Caregiving Benefit was limited to individuals who
                               were stopped from receiving any further benefits as part of pre-payment
                               controls and were asked by the Canada Revenue Agency to provide
                               additional information. For example, 113,797 individuals who received
                               $888 million in Canada Recovery Caregiving Benefit payments were
                               requested to provide additional information to confirm that they met the
                               $5,000 income threshold. The agency told us that it would complete any
                               remaining verifications as part of its post-payment verification work.



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to the Parliament of Canada—2022
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                                                 Collection work status

                                                 10.C.15 Collection activities had not started on Canada Recovery
                                                 Caregiving Benefit payments as of July 2022. The agency reported that
                                                 repayments of approximately $8.3 million were received for the benefit
                                                 program as of 30 June 2022. We were unable to confirm the amounts
                                                 the agency received from individuals for each of the COVID-19 programs
                                                 under audit because of a lack of detailed and disaggregated reporting
                                                 data. See our recommendation in Part 1 at paragraph 10.115.

Demographic
information

Exhibit 10.C-3—Demographic information about recipients of the Canada Recovery Caregiving
Benefit (as at 31 March 2022)

                                             Nunavut
                                                                                                      Number of recipients             Total amount (in millions)
                                                  4,074
                       Northwest
                                                  36.7
                       Territories
                           2,399                                                                     Total recipients by province and territory
                           20.5                                                                          557,617 (including 60 unknown*)
                                                                                                         3,819.9 (including $0.3 unknown*)
    Yukon
       809                                                                                          Quebec
       5.7                                                                                           99,712
                                                                                                     504.4
                                                                                                                     Newfoundland
                                                                                                                     and Labrador
    British                                                                                                               7,082
   Columbia                                                                                                               51.8
      46,542
      323.4

                                                                                                                       Prince Edward
                                                                                                                           Island
       Alberta                                                                                                                 1,322
        76,994
                                                                                                                               6.9
        522.3


                          Saskatchewan                                                                                Nova Scotia
                                  31,568                                                                                  13,583
                                                   Manitoba                                    New Brunswick
                                  273.5                  36,488              Ontario                                      96.5
                                                                                                     10,151
                                                         330.3                226,833                70.0
                                                                              1,577.6



                                    Canada Recovery Caregiving Benefit recipients by gender

                                                                  Unknown*                                                                  Unknown*
                                                                     12                                                                        $0.1

          Female                                                                               Female
             357,079                                                                          $2,443.5

                                                                                                                    $3,819.9
                                       557,617                                                                       million
                                                                  Male                                                                       Male
                                                              200,526                                                                       $1,376.3




                                  Canada Recovery Caregiving Benefit recipients by age group

                                                    25–34 age                                                                          25–34 age
                                                         171,143                         0–24 age                                        $1,234.2
     0–24 age                                                                              $217.6
      29,756
                                                                                         65+ age
     65+ age
Reports   of the Auditor General of Canada
       2,424
                                                                                           $20.4                                                    Report 10   |   57
to the Parliament of Canada—2022                                                        55–64 age                   $3,819.9
   55–64 age                                                                                                         million
     37,662
                                       557,617                                           $262.3
          76,994
                                                                                                                6.9
          522.3


                         Saskatchewan                                                                  Nova Scotia
                             31,568                                                                       13,583
                                            Manitoba                                New Brunswick
                             273.5                                Ontario                                 96.5
                                              36,488                                        10,151                    Specific COVID-19 Benefits
                                              330.3                226,833                  70.0
                                                                   1,577.6



                               Canada Recovery Caregiving Benefit recipients by gender

                                                       Unknown*                                                           Unknown*
                                                           12                                                                $0.1

           Female                                                                   Female
           357,079                                                                 $2,443.5

                                                                                                     $3,819.9
                                  557,617                                                             million
                                                       Male                                                                Male
                                                   200,526                                                                $1,376.3




                             Canada Recovery Caregiving Benefit recipients by age group

                                             25–34 age                                                                25–34 age
                                               171,143                        0–24 age                                 $1,234.2
      0–24 age                                                                  $217.6
        29,756
                                                                              65+ age
      65+ age                                                                   $20.4
        2,424

                                                                             55–64 age               $3,819.9
    55–64 age                                                                                         million
      37,662
                                  557,617                                     $262.3



          45–54 age                               35–44 age                       45–54 age                              35–44 age
                96,522                                 220,110                          $659.2                             $1,426.2




* Unknown means that gender, age, or province of residence was either missing or not specified in the information provided by the Canada
Revenue Agency.
Note: Dollars in the exhibit are rounded.
Source: Data provided by the Canada Revenue Agency




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to the Parliament of Canada—2022
                                                                                        Specific COVID-19 Benefits



D—Canada Recovery Sickness Benefit
Overview of the program

                               Objective

                               10.D.1 The Canada Recovery Sickness Benefit gave income support
                               to employed and self-employed individuals who were unable to work
                               because they were sick or needed to self-isolate due to COVID-19 or
                               had an underlying health condition that put them at greater risk of
                               getting COVID-19.

                               Roles and responsibilities

                               10.D.2 Policy development and program design: Employment and
                               Social Development Canada

                               10.D.3      Administration: Canada Revenue Agency

                               Period of availability of the benefit

                               10.D.4      From 27 September 2020 to 7 May 2022

                               Support to recipient

                               10.D.5      The support was as follows:

                               Gross amount per week:                    $500.00

                               Tax withholding at source:                10% ($50.00)

                               Net amount per week:                      $450.00

                               Income tax impact:                        Taxable through T4A slip (RL-1 for
                                                                         Quebec residents)

                               Interest on erroneous payments or         None
                               overpayment:


Program delivery and
controls

                               Eligibility conditions and pre-payment controls

                               10.D.6 For the Canada Recovery Sickness Benefit, several eligibility
                               criteria were not verified through pre-payment controls, as summarized
                               in Exhibit 10.D-1. The program was designed to rely on applicants’
                               attestation of eligibility with limited pre-payment controls. This was to
                               allow benefits to be paid to Canadians as quickly as possible. In addition,
                               much of the information that was needed to put pre-payment controls in




Reports of the Auditor General of Canada                                                         Report 10   |   59
to the Parliament of Canada—2022
                                                                                                    Specific COVID-19 Benefits


                                     place was not available at the time payments were being issued. As with
                                     other COVID-19 programs, the emphasis would be put on post-payment
                                     verification to confirm the eligibility of recipients.

Exhibit 10.D-1—Summary of pre-payment controls for eligibility criteria for the Canada Recovery
Sickness Benefit


                                    Eligibility criteria1                                     Pre-payment control applied

     Has a valid social insurance number

                                                                                                              2
     Is a resident in Canada


     Is present in Canada


     Is at least 15 years old on the first day of the benefit period


     Is unable to work at least 50% of regular scheduled workweek for 1 of
     the following reasons:
     • sick with COVID-19 or suspected COVID-19
     • advised to self-isolate due to COVID-19
     • has an underlying health condition putting them at greater risk of
       getting COVID-19

     Earned at least $5,000 in the 12 months leading up to the application or                                 3

     in 2019, 2020, or 2021 from 1 of the following sources:
     • employment income
     • self-employment income
     • maternity and parental benefits from Employment Insurance or a
       provincial plan


     Is not receiving benefits under other programs


     Is not required to isolate as a result of travel


     Is not on paid leave from employer for the period covered by
     the application

      Yes           Partial          No
1
  This exhibit is intended to summarize some of the eligibility information as administered by the Canada Revenue Agency at the
time of program delivery. The complete list of detailed criteria is included in the Canada Recovery Benefits Act.
2
    Control was limited to restricting applicants without a social insurance number.
3
    Control was limited as discussed in paragraphs 10.67 and 10.68 in Part 1 of our report.




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to the Parliament of Canada—2022
                                                                                                      Specific COVID-19 Benefits


Summary information

                                   10.D.7 Exhibit 10.D-2 summarizes information about the Canada
                                   Recovery Sickness Benefit regarding payments to recipients that either
                                   were ineligible or should be investigated further.

                                   10.D.8 The payments identified in Exhibit 10.D-2 are based on
                                   the best information available to the Canada Revenue Agency as
                                   at 31 March 2022. Note that much of the information was not available to
                                   the agency when the payments were issued unless the agency contacted
                                   the applicants, which would have hindered payment expediency. This
                                   was because it was not requested on the applications and was not
                                   readily available through income tax return information. Also, recipients
                                   may have additional information that could confirm their eligibility. This
                                   information would be provided to the agency if requested as part of
                                   post‑payment verification work.

Exhibit 10.D-2—Summary information for the Canada Recovery Sickness Benefit


                                                                       Number of unique                 Total amount net
                                                                           recipients                       of taxes
                                                                        (in thousands)                    (in millions)

    Recipients who received a benefit payment and                                         1,132                          $1,215
    total amount paid as at 31 March 2022


                                                                                                          Days (average)

    Amount of time between receipt of application and issuance of payment                                                        4


               Payments to recipients that either were ineligible or should be investigated further1
                                              (as at 31 March 2022)

                                                                       Number of unique             Total amount paid net of
      Program requirement at risk of not being met
                                                                          recipients                   taxes (in millions)

    Recipients earned less than $5,000                                                  47,916                            $46.6

    Recipients received more than 1 benefit per period                                  11,909                              $7.4

    Total payments to recipients that either were                                      59,4272                           $53.82
    ineligible or should be investigated further
1
 See paragraphs 10.D.9–10.D.11, which explain how we determined our findings of payments to recipients that either were
ineligible or should be investigated further. These results specific to the Canada Recovery Sickness Benefit are included in the
overall findings from Part 1, Exhibit 10.9.
2
 Some payments have been identified as ineligible in more than 1 program requirement. Therefore, we adjusted our finding to
exclude duplicates.




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to the Parliament of Canada—2022
                                                                                                  Specific COVID-19 Benefits



                 Other instances of payments to recipients that should be investigated further1
                             excluded from the total above (as at 31 March 2022)

                                                                    Number of unique              Total amount paid net
      Program requirement at risk of not being met
                                                                       recipients                        of taxes

    Recipients were below age 15 on the first day of                                       0                                 0
    the benefit period

    Recipients were deceased                                                             37                        $31,500

    Recipients were incarcerated for the entire                                          39                       $30,600
    benefit period

    Recipients were not present in Canada                                                18                        $15,750

    Recipients received duplicate benefit payment                                        10                        $12,600
1
  See paragraphs 10.D.9–10.D.11, which explain how we determined our findings of payments to recipients that should be
investigated further.

       Post-payment verifications and collections                   Number of unique
                                                                                                      Total amount
                  as at June 2022                                      recipients

    Amounts owed established following                                  Unable to confirm              Unable to confirm
    post‑payment verifications

    Benefit payments in collection                                                         0                                 0

    Benefit repayments1                                                 Unable to confirm                      $5,870,028
1
 Amounts of benefit repayments was provided by the Canada Revenue Agency but could not be audited because of a lack of
detailed and disaggregated reporting data. See our finding in Part 1, paragraph 10.112.



Assumptions

                                  10.D.9 Below we list some assumptions and provide further
                                  explanations on our findings of payments to recipients of the
                                  Canada Recovery Sickness Benefit that either were ineligible or
                                  should be investigated further, as summarized in Exhibit 10.D-2.
                                  Given the assumptions used in our analysis, the amounts reported in
                                  Exhibit 10.D‑2 are the minimum amounts that should be investigated
                                  further through post-payment verifications.

                                  Amount paid to recipients who earned less than $5,000

                                  10.D.10 To be eligible for the Canada Recovery Sickness Benefit,
                                  applicants were required to have earned at least $5,000 in the 12 months
                                  leading up to the application or in the 2019, 2020 or 2021 calendar
                                  year, depending on the timing of the application. We performed a
                                  conservative analysis and relied on personal income tax returns filed
                                  by individuals to assess if the eligibility criterion was met. We identified
                                  recipients as ineligible or at risk of being ineligible if their combined 2019



Reports of the Auditor General of Canada                                                                    Report 10    |   62
to the Parliament of Canada—2022
                                                                                  Specific COVID-19 Benefits


                               and 2020 earnings were below $5,000. A less conservative approach
                               would have been to use an average of the 2019 and 2020 earnings
                               instead of combining them. This would have led to an increase in
                               ineligible recipients being identified in our analysis.

                               Amount paid to recipients who were not present in Canada

                               10.D.11 Applicants had to attest that they were a resident and present
                               in Canada to be eligible for the benefit. We identified recipients who
                               had both their home and their mailing addresses on record at the
                               Canada Revenue Agency as being outside of Canada. We considered
                               them as recipients of payments that should be investigated further to
                               confirm eligibility.

Post-payment
verifications and
collection

                               Incomplete post-payment verification plans and delays in conducting
                               verifications for individuals

                               10.D.12 Finding. We found, during our review of the Canada Revenue
                               Agency’s post-payment verification plan, that the plan was incomplete.
                               It did not include all the post-payment verifications the agency intended
                               to perform. For example, the plan excluded individuals who had already
                               received benefit payments and who were subsequently prevented from
                               receiving further benefits until they provided additional information
                               needed to assess their eligibility.

                               10.D.13 In addition, the post-payment verification plan was developed
                               based on eligibility criteria and not on individual programs. Therefore,
                               we could not find specific information related to post-payment
                               verification activities for the Canada Recovery Sickness Benefit.
                               The only information the agency included in the plan was that a total
                               of 150,000 cases would be reviewed including the Canada Recovery
                               Sickness Benefit and the other COVID-19 benefit programs for
                               individuals. The number of cases that will be reviewed for each of these
                               individual COVID-19 programs was not specified, nor was the time frame
                               in which they would be done.

                               Post-payment verification work status

                               10.D.14 As of August 2022, post-payment verification work for the
                               Canada Recovery Sickness Benefit was limited to individuals who were
                               stopped from receiving any further benefits as part of pre-payment
                               controls and were asked by the Canada Revenue Agency to provide
                               additional information. For example, 109,466 individuals who received
                               $122 million in Canada Recovery Sickness Benefit payments were




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                                         requested to provide additional information to confirm that they met the
                                         $5,000 income threshold. The agency told us that it would complete any
                                         remaining verifications as part of its post-payment verification work.

                                         Collection work status

                                         10.D.15 Collection activities had not started on the Canada Recovery
                                         Sickness Benefit payments as of July 2022. The agency reported that
                                         repayments of approximately $5.9 million were received for the benefit
                                         program as of 30 June 2022. We were unable to confirm the amounts
                                         the agency received from individuals for each of the COVID-19 programs
                                         under audit because of a lack of detailed and disaggregated reporting
                                         data. See our recommendation in Part 1 at paragraph 10.115.

Demographic
information

Exhibit 10.D-3—Demographic information about recipients of the Canada Recovery Sickness
Benefit (as at 31 March 2022)

                                        Nunavut
                                             2,105
                                                                                              Number of recipients            Total amount (in millions)
                  Northwest
                                             2.7
                  Territories
                      1,913                                                                   Total recipients by province and territory
                      2.4                                                                       1,132,254 (including 190 unknown*)
                                                                                                1,214.9 (including $0.2 unknown*)
    Yukon
      932                                                                                    Quebec
      1.0                                                                                     215,760
                                                                                              213.0
                                                                                                            Newfoundland
                                                                                                            and Labrador
    British                                                                                                      12,814
   Columbia                                                                                                      13.9
     132,108
     141.3

                                                                                                              Prince Edward
                                                                                                                  Island
       Alberta                                                                                                        4,059
        194,904
                                                                                                                      $3.8
        209.7

                      Saskatchewan                                                                           Nova Scotia
                              46,424                                                                            27,396
                                             Manitoba                                  New Brunswick
                              52.4                 59,735              Ontario                                  30.1
                                                                                             21,216
                                                   67.9                 412,698
                                                                                             23.3
                                                                        453.2



                                 Canada Recovery Sickness Benefit recipients by gender

                                                            Unknown*                                                              Unknown*
                                                               99                                                                     $0.1
            Female                                                                     Female
            570,863                                                                    $603.6


                                                                                                           $1,214.9
                                 1,132,254                                                                  million

                                                        Male                                                                       Male
                                                       561,292                                                                     $611.2




                               Canada Recovery Sickness Benefit recipients by age group

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             0–24 age
to the Parliament  of Canada—2022
              175,055
                                       25–34 age                                             $181.0                             25–34 age
                                                       345,737                                                                     $373.1

     65+ age                                                                      65+ age
                                                                                   $35.9
                                                                                                               $3.8
          209.7

                        Saskatchewan                                                                  Nova Scotia
                             46,424                                                                      27,396
                                             Manitoba                              New Brunswick
                             52.4              59,735              Ontario                               30.1
                                                                                           21,216
                                               67.9                 412,698
                                                                                           23.3                       Specific COVID-19 Benefits
                                                                    453.2



                                Canada Recovery Sickness Benefit recipients by gender

                                                        Unknown*                                                         Unknown*
                                                           99                                                               $0.1
            Female                                                                 Female
             570,863                                                               $603.6


                                                                                                    $1,214.9
                                1,132,254                                                            million

                                                    Male                                                                  Male
                                                   561,292                                                                $611.2




                              Canada Recovery Sickness Benefit recipients by age group

                  0–24 age                                                              0–24 age
                                                 25–34 age                                $181.0                        25–34 age
                   175,055
                                                   345,737                                                               $373.1

       65+ age                                                                65+ age
                                                                               $35.9
        32,903
                                                                                                    $1,214.9
                                 1,132,254                                    55–64 age              million
        55–64 age
                                                                                 $130.3
          123,570


                                                 35–44 age                                                              35–44 age
              45–54 age                            265,347
                                                                                       45–54 age                          $290.0
                  189,642                                                                 $204.6




* Unknown means that gender, age, or province of residence was either missing or not specified in the information provided by the Canada
Revenue Agency.
Note: Dollars in the exhibit are rounded.
Source: Data provided by the Canada Revenue Agency




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E—Canada Worker Lockdown Benefit
Overview of the program

                               Objective

                               10.E.1 The Canada Worker Lockdown Benefit gave temporary income
                               support to employed and self-employed people who could not work due
                               to a COVID-19 lockdown. The benefit was available to them only when a
                               COVID-19 lockdown order was designated for their region.

                               Roles and responsibilities

                               10.E.2 Policy development and program design: Employment and
                               Social Development Canada

                               10.E.3      Administration: Canada Revenue Agency

                               Period of availability of the benefit

                               10.E.4      From 24 October 2021 to 7 May 2022

                               Support to recipient

                               10.E.5      The support was as follows:

                               Gross amount per week:                    $300.00

                               Tax withholding at source:                10% ($30.00)

                               Net amount per week:                      $270.00

                               Income tax impact:                        Taxable through T4A slip (RL-1 for
                                                                         Quebec residents)

                               Interest on erroneous payments or         None
                               overpayment:


Program delivery and
controls

                               Eligibility conditions and pre-payment controls

                               10.E.6 For the Canada Worker Lockdown Benefit, several eligibility
                               criteria were not verified through pre-payment controls, as summarized
                               in Exhibit 10.E-1. The program was designed to rely on applicants’
                               attestation of eligibility with limited pre-payment controls. This was to
                               allow benefits to be paid to Canadians as quickly as possible. In addition,
                               much of the information that was needed to put pre-payment controls
                               in place was not available at the time payments were being issued. As




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                                     with other COVID-19 programs, the Canada Revenue Agency decided to
                                     put the emphasis on post-payment verification to confirm the eligibility
                                     of recipients.

Exhibit 10.E-1—Summary of pre-payment controls for eligibility criteria for the Canada Worker
Lockdown Benefit

                                    Eligibility criteria1                                     Pre-payment control applied

     Has a valid social insurance number

                                                                                                              2
     Is a resident in Canada


     Is present in Canada


     Is at least 15 years old on the first day of the application period


     Earned at least $5,000 in the 12 months leading up to the application or                                 3

     in 2020 or 2021 from 1 of the following sources:
     • employment income
     • self-employment income
     • maternity and parental benefits from Employment Insurance or a
       provincial plan

                                                                                                              4
     Is not receiving benefits under other programs


     Is not required to isolate as a result of travel


     Has met all conditions related to quitting or voluntarily ceasing to work


     Filed a 2020 tax return


     Experienced a reduction of at least 50% of average weekly employment
     or self-employment income during the period covered by the
     application

     Works or provides a service in a region designated as a COVID-19
     lockdown region during the 1-week period covered by the application


      Yes           Partial          No
1
  This exhibit is intended to summarize some of the eligibility information as administered by the Canada Revenue Agency at the
time of program delivery. The complete list of detailed criteria is included in the Canada Worker Lockdown Benefit Act.
2
    Control was limited to restricting applicants without a social insurance number.
3
    Control was limited as discussed in paragraphs 10.67 and 10.68 in Part 1 of our report.
4
    Control was paused during the program—see paragraphs 10.E.7–10.E.8.


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                               Limited pre-payment controls

                               10.E.7 The following example supports our finding of limited pre-
                               payment controls. This summary should be read with paragraphs 10.67
                               to 10.70 in Part 1 of our report.

                               10.E.8 Finding. We found that the pre-payment control performed
                               to prevent applicants from receiving regular Employment Insurance
                               benefits from Employment and Social Development Canada and the
                               Canada Worker Lockdown Benefit at the same time was paused from
                               30 December 2021 to 31 January 2022 because of capacity issues. This
                               led to an increase in payments made to ineligible recipients. We noted
                               that 1,300 recipients of the Canada Worker Lockdown Benefit were paid
                               a total of $838,000 as a result of this pre-payment control being paused.
                               See our recommendation in Part 1 at paragraph 10.101.

Summary information

                               10.E.9 Exhibit 10.E-2 summarizes information about the Canada Worker
                               Lockdown Benefit regarding payments to recipients that either were
                               ineligible or should be investigated further.

                               10.E.10 The payments identified in Exhibit 10.E-2 are based on
                               the best information available to the Canada Revenue Agency as
                               at 31 March 2022. Note that much of the information was not available to
                               the agency when the payments were issued unless the agency contacted
                               the applicants, which would have hindered payment expediency. This
                               was because it was not requested on the applications and was not
                               readily available through income tax return information. For example,
                               the $5,000 income criterion could be calculated using earnings from
                               the 12 months prior to the application date. Additional information
                               would be provided to the agency if requested as part of post-payment
                               verification work.




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Exhibit 10.E-2—Summary information for the Canada Worker Lockdown Benefit

                                                                                                       Total amount net
                                                                      Number of unique
                                                                                                           of taxes
                                                                         recipients
                                                                                                         (in millions)

    Recipients who received a benefit payment and                                     450,743                              $811
    total amount paid as at 31 March 2022


                                                                                                         Days (average)

    Amount of time between receipt of application and issuance of payment                                                        4


               Payments to recipients that either were ineligible or should be investigated further1
                                              (as at 31 March 2022)

                                                                                                       Total amount net
                                                                      Number of unique
      Program requirement at risk of not being met                                                          of taxes
                                                                         recipients
                                                                                                        (in thousands)

    Recipients earned less than $5,000                                                   1,692                          $3,121

    Recipients received more than 1 benefit for the                                      1,515                            $892
    same period

    Total payments to recipients that either were                                      3,2052                          $4,0122
    ineligible or should be investigated further
1
  See paragraphs 10.E.11–10.E.15, which explain how we determined our findings of payments to recipients that either were
ineligible or should be investigated further. These results specific to the Canada Worker Lockdown Benefit are included in the
overall finding from Part 1, Exhibit 10.9.
2
 Some payments have been identified as ineligible in more than 1 program requirement. Therefore, we adjusted our findings so
that duplicates were excluded.

                  Other instances of payments to recipients that should be investigated further1
                              excluded from the total above (as at 31 March 2022)

                                                                      Number of unique              Total amount paid net
      Program requirement at risk of not being met
                                                                         recipients                        of taxes

    Recipients quit their employment                                                    11,719                    $17,915,310

    Recipients received duplicate benefit payment                                             0                                  0

    Recipients were incarcerated for the entire period                                        3                        $2,430

    Recipients were deceased                                                                  6                        $5,400

    Recipients were not present in Canada                                                     1                          $540

    Recipients were below age 15 on the first day of                                          0                                  0
    the application period

    Recipients failed to file a 2020 tax return                                               0                                  0
1
  See paragraphs 10.E.11–10.E.15, which explain how we determined our findings of payments to recipients that should be
investigated further.



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     Post-payment verifications and collections as at             Number of unique
                                                                                                   Total amount
                       June 2022                                     recipients

    Amounts owed established following                               Unable to confirm              Unable to confirm
    post‑payment verifications

    Benefit payments in collection                                                      0                                0

    Benefit repayments1                                              Unable to confirm                       $854,064
1
 Amounts of benefit repayments was provided by the Canada Revenue Agency but could not be audited because of a lack of
detailed and disaggregated reporting data. See our finding in Part 1, paragraph 10.112.



Assumptions

                                 10.E.11 Below we list some assumptions and provide further
                                 explanations on our findings of payments to recipients of the
                                 Canada Worker Lockdown Benefit that either were ineligible or
                                 should be investigated further as summarized in Exhibit 10.E-2.
                                 Given the assumptions used in our analysis, the amounts reported in
                                 Exhibit 10.E‑2 are the minimum amounts that should be investigated
                                 further through post-payment verifications.

                                 Amount paid to recipients who earned less than $5,000

                                 10.E.12 To be eligible for the Canada Worker Lockdown Benefit,
                                 applicants had to have earned at least $5,000 in the 12 months leading
                                 up to the application or in the 2020 or 2021 calendar year, depending on
                                 the timing of the application. We performed an analysis and relied on
                                 personal income tax returns filed by individuals to assess if the eligibility
                                 criterion was met. We identified recipients as ineligible or at risk of being
                                 ineligible if their combined 2020 and 2021 earnings were below $5,000.
                                 A less conservative approach would have been to use an average of
                                 the 2020 and 2021 earnings instead of combining them. This would have
                                 led to an increase in ineligible recipients being identified in our analysis.

                                 Amount paid to recipients who quit their employment

                                 10.E.13 In order to apply for a benefit, some applicants had to attest that
                                 they had not quit their employment. To expedite payments, applicants
                                 were not required to submit a record of employment (ROE) to receive
                                 the benefit, as is typically the case when receiving regular Employment
                                 Insurance benefits. Employees whose ROE includes their status as
                                 having quit are usually not able to receive Employment Insurance
                                 benefits unless Employment and Social Development Canada performs
                                 validation activities to determine that benefits should be paid to them.
                                 Employers continued to submit ROEs to the department as required.

                                 10.E.14 For the purpose of our work, we considered the information
                                 about ROEs as an indicator of risk and payments that should be



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                               investigated further given that this information has not been validated
                               to confirm its reliability. The department collects the ROE information
                               to manage regular Employment Insurance benefits. At the time of our
                               audit, the department had not shared this information with the Canada
                               Revenue Agency.

                               Amount paid to recipients who were not present in Canada

                               10.E.15 Applicants had to attest that they were present in Canada to be
                               eligible for the benefit. We identified recipients who had both their home
                               and mailing addresses on record at the Canada Revenue Agency as
                               being outside of Canada. We considered them as recipients of payments
                               that should be investigated further to confirm eligibility.

Post-payment
verifications and
collection

                               Incomplete post-payment verification plans and delays in conducting
                               verifications for individuals

                               10.E.16 Finding. We found, during our review of the Canada Revenue
                               Agency’s post-payment verification plan, that the plan was incomplete.
                               It did not include all post-payment verifications the agency intended to
                               perform. For example, the plan excluded individuals who had already
                               received benefit payments and who were subsequently prevented from
                               receiving further benefits until they provided additional information
                               needed to assess their eligibility.

                               10.E.17 In addition, the post-payment verification plan was developed
                               based on eligibility criteria and not on individual programs. Therefore, we
                               could not find specific information related to post-payment verification
                               for the Canada Worker Lockdown Benefit. The only information the
                               agency included in the post-payment verification plan was that a total
                               of 150,000 cases would be reviewed including the Canada Worker
                               Lockdown Benefit and the other COVID-19 benefit programs for
                               individuals. The number of cases that will be reviewed for each of these
                               individual COVID-19 programs was not specified, nor was the time frame
                               in which they will be done.

                               Post-payment verification work status

                               10.E.18 As of August 2022, post-payment verification work for the
                               Canada Worker Lockdown Benefit was limited to individuals who were
                               stopped from receiving any further benefits as part of pre-payment
                               controls and were asked by the Canada Revenue Agency to provide
                               additional information. For example, 32,544 individuals who received
                               $50 million in Canada Worker Lockdown Benefit payments were
                               requested to provide additional information to confirm that they met the




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                               $5,000 income threshold. The agency told us that it would complete any
                               remaining verifications as part of its post-payment verification work.

                               Collection work status

                               10.E.19 Collection activities had not started on the Canada Worker
                               Lockdown Benefit payments as of July 2022. The agency reported that
                               repayments of the benefit of approximately $850,000 were received as
                               of 30 June 2022. We were unable to confirm the amounts the agency
                               received from individuals for each of the COVID-19 programs under audit
                               because of a lack of detailed and disaggregated reporting data. See our
                               recommendation in Part 1 at paragraph 10.115.




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Demographic
information

Exhibit 10.E-3—Demographic information about recipients of the Canada Worker Lockdown Benefit
(as at 31 March 2022)
                                              Nunavut
                        Northwest
                                                  259                                             Number of recipients           Total amount (in millions)
                                                  0.5
                        Territories
                            276
                            0.5                                                                  Total recipients by province and territory
                                                                                                    450,743 (including 4 unknown*)
                                                                                                    811 (including $0.1 unknown*)
     Yukon
        90                                                                                   Quebec
        0.2                                                                                       106,314
                                                                                                  177.8
                                                                                                                 Newfoundland
                                                                                                                 and Labrador
     British                                                                                                          4,552
    Columbia                                                                                                          8.3
        31,282
        53.0

                                                                                                                 Prince Edward
                                                                                                                     Island
        Alberta                                                                                                          1,401
          30,718                                                                                                         2.3
          61.8

                          Saskatchewan                                                                          Nova Scotia
                                  189                                                                                7,608
                                                  Manitoba                              New Brunswick
                                  0.3                                       Ontario                                  15.2
                                                        8,805                                    8,575
                                                        14.4                 250,670
                                                                                                 10.4
                                                                             466.2



                                        Canada Worker Lockdown Benefit recipients by gender

                                                                 Unknown*                                                            Unknown*
                                                                    47                                                                   $0.1
               Female                                                                    Female
               225,884                                                                   $383.3

                                                                                                               $811.0
                                        450,743                                                                million

                                                                 Male                                                                  Male
                                                             224,812                                                                   $427.6




                                    Canada Worker Lockdown Benefit recipients by age group

                   0–24 age                             25–34 age                           0–24 age                             25–34 age
                    77,512                                106,736                                $117.6                            $180.8



              65+ age                                                                  65+ age
               25,453                                                                    $52.8
                                                                                                               $811.0
                                        450,743                                                                million                  35–44 age
                                                                                                                                            $156.3
         55–64 age                                              35–44 age              55–64 age
               73,713                                             87,105                $149.2


                                                  45–54 age                                                                 45–54 age
                                                        80,224                                                                $154.3


* Unknown means that gender, age, or province of residence was either missing or not specified in the information provided by the Canada
Revenue Agency.
Note: Dollars in the exhibit are rounded.
Source: Data provided by the Canada Revenue Agency


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F—Canada Emergency Wage Subsidy
Overview of the program

                               Objective

                               10.F.1 The Canada Emergency Wage Subsidy was provided to eligible
                               employers for up to 75% of eligible remuneration. The objective of
                               the program was to help employers avoid layoffs and terminations by
                               keeping employees on their payrolls.

                               Roles and responsibilities

                               10.F.2      Administration: Canada Revenue Agency

                               Period of availability of the subsidy

                               10.F.3 The program started on 15 March 2020 and was extended
                               multiple times. The program ended on 23 October 2021, for a total
                               of 21 qualifying periods.

                               10.F.4 As of 24 October 2021, the Canada Emergency Wage Subsidy
                               was replaced with 2 new programs offering wage and rent support
                               to employers: the Tourism and Hospitality Recovery Program and the
                               Hardest-Hit Business Recovery Program. These newer programs were
                               not part of our audit.

Summary information

                               10.F.5 Exhibit 10.F-1 summarizes the total number and amounts of
                               applications received and approved for the Canada Emergency Wage
                               Subsidy program.

Exhibit 10.F-1—Summary information of applications for the Canada Emergency Wage Subsidy


     Applications            Number of             Percentage of         Amount              Percentage of
      processed             applications         total applications    (in millions)         total amount

  Total applications               5,077,613                 100%            $102,249                    100%
  received

  Total applications              5,069,698                  99.8%           $100,738                   98.5%
  approved



                               10.F.6 Exhibit 10.F-2 summarizes the number of unique Canada
                               Emergency Wage Subsidy recipients and the amounts that they
                               received. Over 98% of subsidies were paid to employers with fewer
                               than 100 employees. This represents 62% of the total dollar value of
                               paid subsidies. In comparison, employers with 100 or more employees
                               received 38% of the total dollar value of paid subsidies.

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Exhibit 10.F-2—Breakdown of Canada Emergency Wage Subsidy recipients by employer size

   Employer size                                                                              Percentage of
                          Number of unique        Percentage of        Subsidy paid
  based on number                                                                           total subsidy paid
                             recipients          total recipients       (in billions)
    of employees

  0 to 5                            253,231               56.62%                    $9.8                 9.73%

  6 to 19                            140,609               31.45%                  $21.8                21.65%

  20 to 99                           46,409               10.38%                   $30.8                30.59%

  100 to 499                           6,154                1.38%                  $22.1                21.95%

  500 to 999                               462              0.10%                   $5.6                 5.56%

  1,000 to 4,999                           260              0.06%                   $8.2                  8.14%

  5,000+                                    24              0.01%                   $2.4                 2.38%

  Total                              447,149                100%                $100.7                    100%

Note: Percentages are rounded.




Assumptions

                                 10.F.7 Below, we list some assumptions we made in determining
                                 payments made to employers that appear to have an insufficient revenue
                                 decline and that should be investigated further.

                                 10.F.8 As noted in Part 1, Exhibit 10.9, we estimated that total
                                 payments of $15.5 billion were made to employers that had an indicator
                                 of ineligibility based on the revenue decline criterion for the Canada
                                 Emergency Wage Subsidy. In order to perform this analysis, we focused
                                 on monthly goods and services tax / harmonized sales tax (GST/HST)
                                 filers (Exhibit 10.F-3).

Exhibit 10.F-3—Canada Emergency Wage Subsidy recipients and GST/HST filing frequency

                                                           Percentage of subsidy          Subsidy amount
               Frequency of GST/HST filing
                                                                recipients              received (in billions)

  Monthly                                                                    20%                          $64.2

  Quarterly                                                                  51%                          $26.7

  Annually                                                                   20%                             $5.9

  Non‑filers or exempt                                                        9%                             $3.9

  Total                                                                     100%                        $100.7




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                               10.F.9 We were aware of a difference between the GST/HST reporting
                               periods and the subsidy’s claim periods. We used the recipients’ reported
                               GST/HST revenue in the month that had the largest number of
                               overlapping days with the subsidy program’s claim period. We compared
                               it with the reported GST/HST revenue in the prior reference period (the
                               month or average of months against which the revenue in the current
                               period is compared). In addition, our analysis excluded recipients that
                               did not file a GST/HST return.

                               10.F.10 We were aware of differences between the revenue reported
                               for GST/HST purposes and the specific definition of qualifying revenue7
                               according to the Canada Emergency Wage Subsidy. In addition,
                               employers could make use of choices to modify how they calculated
                               their qualifying revenue for their subsidy claim. These differences could
                               result in employers being eligible for the subsidy even if their GST/HST
                               reported revenue did not show the expected decline. However, we are of
                               the view that, in the absence of other sources of information, the revenue
                               reported on a GST/HST return could have been used as a source of data
                               to assess the reasonableness of the revenue decline claimed on the
                               application. This assessment could have been used for the purpose of
                               either halting future claims or identifying applicants for post-payment
                               verification.

                               10.F.11 Our analysis identified 51,049 employers that received
                               $9.87 billion in Canada Emergency Wage Subsidy payments whose
                               monthly GST/HST filings did not demonstrate a sufficient revenue drop
                               to be eligible for the subsidy. Based on monthly GST/HST data alone,
                               this represents 15.37% of payments made to monthly filers. It follows
                               logically that if this estimated potential ineligibility rate were applied to
                               the full population, this would amount to $15.5 billion of payments that
                               represent a risk of being ineligible. We noted that the Canada Revenue
                               Agency targeted Canada Emergency Wage Subsidy claimants with an
                               insufficient revenue drop based on GST/HST returns (as well as other
                               risk factors) when selecting claims for post-payment verification. See
                               Exhibit 10.F-6 for additional details on post-payment verification.

                               10.F.12 Our analysis of Canada Emergency Wage Subsidy payments
                               that should be investigated further based on GST/HST revenue decline
                               is an estimate. Actual ineligible amounts will only be determinable once
                               comprehensive post-payment verifications are completed.




                                   7    Qualifying revenue—The inflow of cash, receivables, or other consideration arising in
                                   the course of an eligible entity’s ordinary activities (generally, from the sale of goods, the
                                   rendering of services, and the use by others of the eligible entity’s resources) in Canada in
                                   a particular period.



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Eligibility and
pre‑payment controls

                                 10.F.13 In order to validate Canada Emergency Wage Subsidy
                                 applications prior to issuing subsidy payments, the Canada Revenue
                                 Agency applied a number of controls. In Exhibit 10.F-4, we have
                                 outlined the controls the agency applied at various stages of the
                                 validation process.

Exhibit 10.F-4—Stages of pre-payment controls for Canada Emergency Wage Subsidy applications

        Stage                       Description                    Controls applied by the Canada Revenue Agency
    Automated          A series of automated validation            Validation checks included confirming the
    pre-validation     controls were applied to the                employer met the following criteria:
                       application. If the application did
                                                                   • was an eligible employer type based on the
                       not pass, the applicant received a
                                                                     business operating type code
                       denial message. If the application
                       passed, the applicant was                   • had an active business number as
                       permitted to enter information                at 15 March 2020
                       related to the claim amount.
                                                                   • had an active payroll account as
                                                                     at 15 March 2020
                                                                   • had no duplicate claims for the same period
                                                                   • had no claims submitted after the 180-day
                                                                     cut-off period
                                                                   • had a valid business number1

    Automated risk     The agency’s systems assessed               Risk indicators included the following:
    assessment         application information to
                                                                   • employer included on various high risk lists
                       determine if certain risk indicators
                                                                     maintained by the agency
                       existed. Applications without
                       risk indicators were approved               • application received above a specific dollar
                       automatically. All others were                value
                       redirected for manual review.
                                                                   • reasonableness of number of employees
                                                                     and remuneration compared to previous
                                                                     T4 summaries
                                                                   • changes in direct deposit or address
                                                                     information after 15 March 2020 or the last
                                                                     claim

    Manual review      The agency performed manual                 Different groups within the agency developed
                       validations of high risk files.             their own manual review processes to review the
                                                                   following:
                                                                   • most aspects of the application information
                                                                     for reasonableness
                                                                   • the history of the employer for any previous
                                                                     compliance issues
1
 Employers whose applications were denied at this stage could contact the agency and be placed manually on a valid business
number list to allow them to submit their application in exceptional circumstances).




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                                  Assessment of pre-payment controls and audit findings

                                  10.F.14 Exhibit 10.F-5 is a summary of the eligibility criteria for the
                                  Canada Emergency Wage Subsidy that we tested as part of our audit, a
                                  description of the Canada Revenue Agency pre-payment controls, and
                                  our audit findings.

Exhibit 10.F-5—Summary of eligibility criteria, pre-payment controls, and audit findings for the
Canada Emergency Wage Subsidy program

   Eligibility criteria      Description of pre-payment controls                            Audit findings

  Eligible employer         The Canada Revenue Agency                       Although this control was generally well
                            automatically compared the                      designed, the operating type code list
                            operating type code of the applicant            was not aligned with employers eligible
                            to a list of acceptable codes to                for the subsidy. For example, the list
                            validate the applicant was an eligible          could not identify employers controlled
                            employer. Operating type codes                  by public institutions, which were
                            are numbers attributed to every                 ineligible for the subsidy. The agency
                            employer to describe the type of                identified this concern and updated
                            operations (for example, a hospital or          pre-payment controls in late 2020. The
                            a financial institution).                       agency estimated that, prior to that
                                                                            date, approximately $73.5 million were
                                                                            paid to 136 employers that the agency
                                                                            suspects were ineligible. The agency is
                                                                            currently reviewing these 136 entities as
                                                                            part of its post‑payment audits.

  Revenue decline           There was no automated                          See paragraphs 10.F.7–10.F.12 for details.
                            pre‑payment control used to test this
                            eligibility criterion.

  Eligible employees        The agency performed a                          We performed a reasonableness test
  (remuneration)            reasonableness test by comparing                and did not find significant instances of
                            remuneration claimed with historical            overpayment on the basis of historical
                            payroll remittances.                            T4 summaries.

  Active payroll            The agency performed a validation               We performed a targeted sample to
  account as                check to ensure the applicant                   assess this eligibility criterion and found
  at 15 March 2020          had an active payroll account as                that despite the inactive status of certain
                            at 15 March 2020.                               accounts, evidence of activity justified
                                                                            the payments in the sample we selected.
                                                                            See paragraph 10.F.15.

  Application               The system prevented an                         We noted that $100 million were paid
  received within           application from being submitted                to applicants who submitted their
  the 180-day               after the 180‑day deadline. To                  application past the deadline. We
  deadline                  be processed after this time,                   performed a targeted sample and found
                            an application required manual                  that in 20% of cases, the agency’s
                            approval. Each case was                         documentation on file lacked justification
                            evaluated individually.                         for the payment.
Note: This exhibit summarizes key eligibility information administered by the Canada Revenue Agency at the time of program
delivery. The complete list of detailed criteria is included in the Income Tax Act.




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                               Missing up-to-date information on business status

                               10.F.15 Finding. Up-to-date information on business closures was
                               unavailable to the Canada Revenue Agency. This information would
                               have helped the agency assess the active status of employers and
                               improve the efficiency of the Canada Emergency Wage Subsidy program.
                               We found that 3,724 employers representing $564 million received
                               the subsidy while being registered inaccurately as inactive or closed
                               businesses in the agency’s system. This is a consequence of the agency
                               not having or updating its information on businesses that are inactive,
                               closed, non‑operating, or bankrupt. The consequence of outdated
                               account status information (that is, active versus inactive) reduced
                               the agency’s ability to efficiently deliver the Canada Emergency Wage
                               Subsidy program, as well as other programs for businesses.

Post-payment
verifications and
collection
                               Post-payment verification and collection work status

                               10.F.16 The Canada Revenue Agency used a risk-based audit selection
                               approach. Exhibit 10.F-6 shows that a higher percentage of claims and
                               claim values were being audited by the agency for employers with 100 or
                               more employees. A total of 0.8% of the unique recipients and 12% of the
                               value of the subsidy paid were being audited.




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Exhibit 10.F-6—Allocation of the Canada Revenue Agency’s post-verification audits of the Canada
Emergency Wage Subsidy program by employer size

                                                      Number                                Value in millions
   Employer size
                          Number of unique        (percentage) of     Subsidy paid           (percentage) of
  based on number
                             recipients          unique recipients     (in billions)        the subsidy paid
    of employees
                                                    under audit                                under audit

  0 to 5                            253,231                    868                $9.8                   $59.2
                                                           (0.34%)                                     (0.60%)

  6 to 19                            140,609                   662              $21.8                   $103.0
                                                           (0.47%)                                     (0.47%)

  20 to 99                            46,409                  1,151             $30.8                $1,388.8
                                                           (2.48%)                                    (4.51%)

  100 to 499                           6,154                   553              $22.1                 $3,317.9
                                                           (8.99%)                                    (15.01%)

  500 to 999                               462                  92                $5.6               $1,328.1
                                                          (19.91%)                                   (23.72%)

  1,000 to 4,999                           260                 85                 $8.2               $4,350.1
                                                         (32.69%)                                    (53.05%)

  5,000+                                    24                  10                $2.4               $1,636.5
                                                          (41.67%)                                   (68.19%)

  Total                              447,149                 3,421             $100.7                12,183.6
                                                            (0.8%)                                      (12%)
Note: Percentages are rounded.

                                 10.F.17 Exhibit 10.F-7 summarizes information on the phases of
                                 post‑payment verification and collections for the Canada Emergency
                                 Wage Subsidy program. The Canada Revenue Agency was unable to
                                 provide detailed and disaggregated data to confirm the total amounts
                                 collected for the program. The agency’s reporting noted $76.7 million
                                 currently in collections as of June 2022. We were unable to confirm
                                 the amounts the agency received from employers for each of the
                                 COVID-19 programs under audit because of a lack of detailed and
                                 disaggregated reporting data. In addition, we have not audited the
                                 amounts in collection resulting from post-payment verifications
                                 shown in Exhibit 10.F‑7 because of the timing of the completion of the
                                 post‑payment verifications.




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Exhibit 10.F-7—Post-payment verification and collections for the Canada Emergency Wage
Subsidy program

                                                                                                      Total claim amount
              Status on post-payment as at 30 May 2022                      Number of audits
                                                                                                          (in billions)

    Post-payment verification: Phase 11

    Number of audit files                                                                   730                         $1.52

    Audits completed                                                                        712                         $1.29

    Audits still in progress                                                                  18                     $0.22

    Claims denied as a result of post-payment verification                                  298                      $0.08

    Post-payment verification: Phase 22

    Number of audit files                                                                 2,770                    $10.66

    Audits completed                                                                        487                      $0.31

    Audits still in progress                                                              2,283                    $10.36

    Claims denied as a result of post-payment verification                                  298                      $0.04

    Amounts owed established following                                      Unable to confirm           Unable to confirm
    post‑payment verifications


                                                                                Number of             Total claim amount
                  Status on collection as of June 2022
                                                                                employers                (in millions)

    Accounts in collections3                                                Unable to confirm                            $77

    Repayments                                                              Unable to confirm           Unable to confirm
1
    Average file completion time in phase 1 was 341 days.
2
    Average file completion time in phase 2 was 195 days.
3
 Amounts of benefit repayments were provided by the agency but could not be audited because of a lack of detailed and
disaggregated reporting data. See our finding from Part 1, paragraph 10.112.

                                    10.F.18 The agency told us that as of June 2022, 179 employers
                                    were impacted by unauthorized account access. Of these, $72 million
                                    in payments were prevented from being issued, $39 million were
                                    paid in error, and $60 million worth of payments were under criminal
                                    investigation. As a result of data issues and data being combined with
                                    another subsidy program, the agency could not provide a clear total of
                                    how many identity theft cases were identified for the Canada Emergency
                                    Wage Subsidy program only. See our recommendation in Part 1 at
                                    paragraph 10.115.




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About the Audit
This independent assurance report was prepared by the Office of the Auditor General of Canada
on specific COVID‑19 benefits. Our responsibility was to provide objective information, advice,
and assurance to assist Parliament in its scrutiny of the Government of Canada’s management
of resources and programs, and to conclude on whether the specific COVID‑19 benefit programs
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

Employment and Social Development Canada confirmed that the audit report is factually accurate.

The Canada Revenue Agency confirmed that the audit report is factually accurate with the exception
of our estimate of payments that require further investigation for the Canada Emergency Wage
Subsidy estimated at $15.5 billion. The agency disagreed with our use of monthly GST/HST
information to assess the revenue decline criteria of the subsidy program. We used this information
because monthly revenue information was not gathered upon application. Based on the results
of the limited post-payment verifications completed to date, the agency’s view was that ineligible
subsidy payments will be significantly lower than our estimate.

Audit objective

The objective of this audit was to determine the following:
  • whether the Canada Revenue Agency and Employment and Social Development Canada,
    according to their roles and responsibilities, ensured that COVID‑19 benefit payments were
    accurate, paid to eligible applicants, and undertook timely procedures to recover payments
    made to ineligible recipients and overpayments




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  • whether the Canada Revenue Agency and Employment and Social Development Canada
    managed the COVID‑19 programs efficiently and measured their administrative effectiveness.
    Furthermore, the audit will examine whether programs’ objectives were achieved and provided
    value‑for‑money outcomes

The COVID‑19 benefit programs covered by this audit are the following:
  • Canada Worker Lockdown Benefit
  • Canada Recovery Benefit
  • Canada Recovery Sickness Benefit
  • Canada Recovery Caregiving Benefit
  • Canada Emergency Response Benefit, including the Employment Insurance Emergency
    Response Benefit
  • Canada Emergency Wage Subsidy

Scope and approach

The audit scope included the Canada Revenue Agency and Employment and Social Development
Canada and covered the benefits and programs listed above.

This audit included the following 3 lines of enquiry for all the benefits and programs subject to
the audit:
  • Compliance. This line of enquiry provided assurance that recipients of COVID‑19 benefits met
    the eligibility criteria, according to the programs’ requirements, and that the payments made
    were accurate.
  • Recovery of ineligible payments. This line of enquiry examined the post‑payment verification
    plans and processes in place as well as the actions undertaken to recover in a timely way
    payments made to ineligible recipients and overpayments.
  • Efficiency, measures of effectiveness, and outcomes. This line of enquiry examined the
    efficiency of the agency’s and department’s management of the programs under audit, as well
    as the means to measure the effectiveness of the programs’ delivery.

The audit also sought to determine whether the programs provided value‑for‑money outcomes by
analyzing various metrics and statistics. The assessment of value‑for‑money outcomes is not the
responsibility of the Canada Revenue Agency.

The audit did not examine
  • other COVID‑19 programs put in place by the federal government that are not identified in An Act
    to provide further support in response to COVID‑19
  • COVID‑19 provincial and municipal support programs offered to individuals, businesses,
    and organizations




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Criteria
We used the following criteria to determine the following:
  • whether the Canada Revenue Agency and Employment and Social Development Canada,
    according to their roles and responsibilities, ensured that COVID‑19 benefit payments were
    accurate, paid to eligible applicants, and undertook timely procedures to recover payments
    made to ineligible recipients and overpayments
  • whether the Canada Revenue Agency and Employment and Social Development Canada
    managed the COVID‑19 programs efficiently and measured their administrative effectiveness.
    Furthermore, the audit will examine whether programs’ objectives were achieved and provided
    value‑for‑money outcomes

                         Criteria                                           Sources
  Compliance                                           • Taxpayer Bill of Rights, Canada Revenue Agency
  The Canada Revenue Agency and Employment             • Related Amendment to the Canada Recovery
  and Social Development Canada ensured that             Benefits Regulations, An Act to provide further
  COVID‑19 benefits payments were accurate and           support in response to COVID‑19
  that recipients met eligibility criteria.
                                                       • Canada Worker Lockdown Benefit Act
                                                       • Canada Recovery Benefits Act
                                                       • Canada Emergency Response Benefit Act
                                                       • Income Tax Act
                                                       • Employment Insurance Act
  Recovery of ineligible payments                      • Related Amendment to the Canada Recovery
                                                         Benefits Regulations, An Act to provide further
  The Canada Revenue Agency and Employment and
                                                         support in response to COVID‑19
  Social Development Canada have developed and
  are implementing post‑payment verification plans     • Income Tax Act
  and processes and are taking timely actions to
                                                       • Canada Worker Lockdown Benefit Act
  recover payments made to ineligible recipients and
  overpayments.                                        • Canada Recovery Benefits Act
                                                       • Canada Emergency Response Benefit Act
                                                       • Employment Insurance Act
                                                       • Taxpayer Bill of Rights, Canada Revenue Agency
  Efficiency, measures of effectiveness, and           • Related Amendment to the Canada Recovery
  outcomes                                               Benefits Regulations Income Tax Act, An Act to
                                                         provide further support in response to COVID‑19
  The Canada Revenue Agency and Employment
  and Social Development Canada managed the            • Policy on Results, Treasury Board.
  COVID‑19 programs efficiently and measured their
                                                       • Canada Worker Lockdown Benefit Act
  administrative effectiveness.
                                                       • Canada Recovery Benefits Act
  Employment and Social Development Canada
  monitored, analyzed, and reported on policy          • Canada Emergency Response Benefit Act
  outcomes for the benefits covered by this audit,
                                                       • Employment Insurance Act
  with the exception of the Canada Emergency
  Wage Subsidy.                                        • Income Tax Act
                                                       • Transforming Our World: The 2030 Agenda for
                                                         Sustainable Development, United Nations




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                                                                             Specific COVID-19 Benefits


Period covered by the audit

The audit covered the period from 15 March 2020 to 30 September 2022. This is the period to which
the audit conclusion applies. However, to gain a more complete understanding of the subject matter
of the audit, we also examined certain matters that preceded the start date of this period.


Date of the report

We obtained sufficient and appropriate audit evidence on which to base our conclusion
on 1 November 2022, in Ottawa, Canada.


Audit team

This audit was completed by a multidisciplinary team from across the Office of the Auditor General
of Canada led by Mélanie Cabana, Principal. The principal has the overall responsibility for audit
quality, including conducting the audit in accordance with professional standards, applicable legal
and regulatory requirements, and the office’s policies and system of quality management.




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Recommendations and Responses
In the following table, the paragraph number preceding the recommendation indicates the location
of the recommendation in the report.

                   Recommendation                                            Response

  10.47 In the administration of future programs, the   Agreed. As the administrator of future government
  Canada Revenue Agency should engage with its          programs, the Canada Revenue Agency will
  partners, such as Statistics Canada and relevant      continue to engage with program departments to
  departments, to ensure it collects pertinent data     discuss the data required to measure and report
  from applicants to better monitor and measure the     on the effectiveness of these programs, as well
  effectiveness and outcomes of programs.               as the framework to exchange this information in
                                                        a timely and secure manner. While the program
                                                        departments are responsible for measuring and
                                                        reporting on the outcome of initiatives under their
                                                        responsibility, the agency will be an active partner,
                                                        supporting them in their data needs.

  10.78 In order to improve the efficiency of the tax   Agreed. The Canada Revenue Agency continuously
  and programs administration and to follow good        strives to enhance its program administration
  practices, the Canada Revenue Agency should           through the review of new international best
  assess the value of implementing a real‑time          practices. The agency is already advancing its
  business revenue data requirement.                    understanding of real‑time business revenue data
                                                        requirements to support program administration
                                                        and increase business efficiencies. Within its
                                                        legislative authority, the agency will assess the
                                                        value of implementing a real‑time business
                                                        revenue data requirement, including the necessary
                                                        infrastructure analysis, completion of a cost
                                                        benefit analysis, and required policy and legislative
                                                        changes to implement such a requirement.

  10.84 In order to improve its efficiency of           Agreed. Budget 2021 announced funding of
  delivering benefit programs, the Canada Revenue       $43.9 million over three years, starting in 2020–21,
  Agency, with the collaboration of Employment          for the Canada Revenue Agency and Employment
  and Social Development Canada, should pursue          and Social Development Canada to develop
  the development and implementation of a               options for the implementation of an ePayroll
  real‑time payroll system with clear timelines and     solution for the Government of Canada that will
  deliverables.                                         increase the speed and accuracy of services
                                                        and benefits to Canadians. Now in its second
                                                        year, the current phase of the project will deliver
                                                        a fully costed implementation plan consisting
                                                        of 3 deliverables: a business case that will
                                                        recommend an ePayroll solution, supported
                                                        by a transformation blueprint and a project
                                                        management framework, with a view to moving to
                                                        the implementation phase beyond March 2024.




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to the Parliament of Canada—2022
                                                                                      Specific COVID-19 Benefits



                   Recommendation                                             Response

  10.101 The Canada Revenue Agency and                   Partially agreed. Employment and Social
  Employment and Social Development Canada               Development Canada and the Canada Revenue
  should                                                 Agency have ensured that their plans include both
                                                         reconciliation activities such as the collection
  • update their post‑payment verification plans
                                                         of lump‑sum payments as well as post‑payment
    to include all activities to identify payments
                                                         verifications of potentially ineligible applicants.
    to ineligible recipients of COVID‑19 benefit
                                                         As part of their integrity work, the department
    programs, taking into account the legislated
                                                         and agency have assessed all COVID‑19 benefit
    time frames
                                                         programs against the eligibility criteria and will
  • increase the extent of post‑payment                  leverage a risk‑based approach to verifications that
    verifications for COVID‑19 benefit programs          focuses on the highest risk files and the greatest
    for individuals to include all cases identified as   dollars at risk.
    being at risk of being ineligible
                                                         The department and the agency were provided
                                                         funding by the government to conduct risk‑based
                                                         post‑payment verifications at a level that balances
                                                         the number of resources required to investigate a
                                                         potentially ineligible recipient against the amount
                                                         paid to an individual. It would not be cost effective
                                                         nor in keeping with international and industry
                                                         best practices to pursue 100% of all potentially
                                                         ineligible claims. This approach is evergreen, and
                                                         will be adapted as the circumstances warrant.

  10.114 To increase the recovery of                     Agreed. The functionality to automatically apply
  COVID‑19 amounts owed and reduce the                   refunds from other tax lines (such as T2 income
  administrative burden, the Canada Revenue              tax, GST/HST, etc.) to Canada Emergency
  Agency should, before the end of December 2022,        Wage Subsidy debts has been operational
  put system functionalities in place to apply refunds   since the subsidy was first implemented.
  against COVID‑19 amounts owed.                         Beginning 17 October 2022, the agency has had the
                                                         ability to apply T1 refunds to COVID‑19 individual
                                                         benefit debts. The functionality to apply GST
                                                         credits to COVID‑19 individual benefit debts is
                                                         currently planned for February 2023.

  10.115 To improve the usefulness of information        Agreed. The Canada Revenue Agency has
  and the transparency of COVID‑19 reporting,            continually enhanced its systems since it began
  the Canada Revenue Agency should improve its           the administration of COVID‑19 benefits for
  information collection and reporting capabilities      individuals and subsidies for businesses in an
  to accurately report for each benefit program          iterative fashion. This includes enhancements
  how much has been collected for each individual        to support post‑issuance compliance, reporting,
  and business.                                          and collection activities. As part of this ongoing
                                                         process, the agency will continue its efforts to
                                                         accurately report how much has been collected for
                                                         each COVID‑19 benefit and subsidy program.




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