Proactive Disclosure
— Grant and Contribution Agreements

Why must we disclose the awarding of grants and contributions agreements?

The Government of Canada has implemented a series of measures to strengthen public sector management by enhancing transparency and oversight of public resources in the federal government.

One of these measures includes the proactive disclosure of financial and human resources related information by departments and agencies. By making this information rapidly available on departmental websites, Canadians and Parliament are better able to hold the Government and public sector officials to account.

On October 21, 2005, the Government announced its commitment to proactively disclose the awarding of grants and contributions over $25,000 as part of its Management Improvement Agenda. On April 1^st , 2018, TBS released the Guidelines on the Reporting of Grants and Contributions Awards, which sets out the public requirements for the Proactive Disclosure of Grants and Contributions. All awarded G&C's are to be reported (no minimum amount) as well as all award amendments (material and financial amendments).

Who is responsible for validating the reports?

The branch/region delivering the program must validate the agreements and amendments awarded during the period (based on fund center).

What information should be disclosed?

Since April 1^st, 2018, all awarded G&C's are to be reported (no minimum amount) as well as all awarded amendments (material and financial amendments). The rules and principles governing government grants and contributions are outlined in the Treasury Board Policy on Transfer Payments. Transfer payments are transfers of money, goods, services or assets made from an appropriation to individuals, organizations or other levels of government, without the federal government directly receiving goods or services in return, but which may require the recipient to provide a report or other information subsequent to receiving payment. These expenditures are reported in the Public Accounts of Canada. The major types of transfer payments are grants, contributions and 'other transfer payments'.

Included in this category, but not to be reported under proactive disclosure of awards, are (1) transfers to other levels of government such as Equalization payments as well as Canada Health and Social Transfer payments. (2) Grants and contributions reallocated or otherwise redistributed by the recipient to third parties; and (3) information that would normally be withheld under the Access to Information Act and the Privacy Act.

When is the reporting period?

Specific to Gs&Cs, there are two types of reports:

1. Quarterly CFOB G&C's submission which will require ADM official validation and approval before being made publically available on the Open Government web site. Quarterly reports will include all agreements and amendments that occurred and were completed in the Common System for Grants and Contributions (CSGC) during that specific quarter, as well as late reporting from previous quarter.

   Late reporting definition: activities for a specific quarter not captured in the initial submission (data entry issues, late data entry).

2. Monthly reports intended to facilitate the gradual and incremental validation of data for proactive disclosure. The monthly reports will give an idea of volume as well as a better understanding of the material amendment activity that will be present in the final quarterly reports. This will help reduce the pressures on Branches and Regions when the quarterly CFOB G&C's submission is made available. These reports will not be disclosed to the public and will only be used internally. No ADM official approval will be required.

Reporting shall be done on a quarterly basis, corresponding to the government's fiscal year quarters. Grants and Contributions information must be posted on-line within sixty (60) days of the end of each reporting period (once Bill C-58 receives Royal Assent, the information will need to be posted within thirty (30) days of the end of each reporting period).

The reporting period corresponds to the date at which the awarding of a grant or contribution has been officially authorized (signed) by both parties. The most recent date of both signatures resulting in the commitment made by our department in favor of a recipient.

Exceptions & Batch Reporting

1. Exceptions: When a department determines that information about a grant or contribution award should not be reported, the department is encouraged to disclose information that is unclassified or non-sensitive. The following exceptions apply to the Department:
   1. Payments to individuals under Employment Insurance (EI) Part 1 are excluded
   2. Work Sharing program agreements (funded by EI Part 1 & EI Part II) are excluded
   3. The Compensation for Employers of Reservists Program (CERP): According to the MOU signed with DND for the delivery of the CERP Program, under the Roles and Responsibilities for the Department of National Defense (DND) as defined, is responsible to report on proactive disclosure of Grants and Contributions (G&C's); as part of their Information Management responsibilities.
   4. Commission des normes la santé et sécurité du Québec (CNESST)
   5. Student loans
   6. Transfer payments to provinces/territories
   7. Memoranda's of understanding with other levels of government and foreign governments
2. Batch Reporting: Is a process that may be applied to a program that awards grants and/or contributions to recipients who may have been exempt from having certain information disclosed under the Privacy Act. The following programs are being reported on in this manner:
   1. Apprenticeship Incentive Grant (AIG)
   2. Apprenticeship Completion Grant (ACG)
   3. Apprenticeship Incentive Grant for Women (AIGW) – to be confirmed by TBS
   4. Parents of Missing or Murdered Children (PMMC)
   5. Parents of Young Victims of Crime (PYVC)

For additional information, please contact the proactive disclosure unit at the following email address: NC-PROACTIVE-FINANCIAL-REPORTING-GD@hrsdc-rhdcc.gc.ca

Link: https://www.canada.ca/en/employment-social-development/corporate/transparency/service-canada.html