Summary report to the Minister of the IIGB visit to the United States of America and Canada
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The Interim Inspector General of Biosecurity (IIGB) provides independent assurance, through audit and review, of the performance and appropriateness of Australia’s biosecurity systems and risk management measures that are the responsibility of the Department of Agriculture, Fisheries and Forestry (DAFF).
The IIGB reports to the Minister for Agriculture Fisheries and Forestry and is responsible to the Secretary of DAFF regarding administrative matters.
Ahead of a statutory Inspector General of Biosecurity (IGB) appointment and legislation, the Australian Government established an IIGB role in July 2009, which has now been in place for two years.
Purpose of the visit
During 23-30 May 2011, the IIGB met with government officials from the United States Department of Agriculture (USDA) and from the Canadian Food Inspection Agency (CFIA).
The focus on the visit was to:
- receive first-hand briefings of the US and Canadian systems for quarantine and biosecurity audit and review activities
- gain an understanding of these agencies views on key issues, challenges and risks for biosecurity and quarantine with emphasis on risk management verification systems
- develop an understanding of how the US Office of the Inspector-General (OIG) and other agencies establish and prioritise their biosecurity and quarantine audit and review activities, to cover the range of systems and measures in place
- compare and contrast the US Inspector-General role, with the Australian IIGB role, in respect to biosecurity and quarantine issues.
The discussions during the IIGB’s visit did not focus on policy, international trade issues, market access opportunities, or assessments of other countries’ quarantine activities. These matters are outside the scope of the IIGB’s role.
This summary is intended to better inform the future operation of the IIGB and IGB functions, and is not a reflection or assessment of the OIG, Animal and Plant Health Inspection Service (APHIS) or CFIA.
Both the USDA and CFIA have responsibility for national animal and plant biosecurity. These responsibilities are similar to those of DAFF.
In the US, the Office of the Inspector General (OIG) has statutory responsibility for independent audit, review and investigation of the USDA’s programs and operations. The OIG was legislatively established in 1978 under the Inspector General Act (Public Law 95-452).
The APHIS is the organisation in the USDA that is responsible for national biosecurity, including import and export regulation. Its role is similar to that of the Biosecurity division within DAFF.
- Within APHIS, program areas undertake internal auditing.
- All programs and operations of APHIS are also subject to independent audit by the OIG.
In Canada, while the CFIA has no dedicated independent audit system, officials undertake internal audits of its divisions and programs.
- Within CFIA, the internal auditing focuses on corporate and business matters.
- An extensive corporate Quality Management System has been implemented across all programs.
CFIA established an audit committee in 2009. This includes external membership such as provincial government and private sector financial representatives.
- The audit committee oversights a risk-based audit plan for CFIA.
- The audit plan is compiled on a rolling three-year cycle.
- This appears to be a similar approach to audit committee and audit planning arrangements that are in place in many Australian government agencies.
Key observations and learnings
The following observations and learnings (for Australia’s IIGB and IGB roles) resulted from the visit.
The IIGB undertakes audits and reviews of technical, procedural and operational program elements of DAFF’s biosecurity systems.
- The IIGB role does not review policy, but does undertake literature reviews as this relates to background information to inform the scope of IIGB activities and provide the general context of a biosecurity audit or review.
- The OIG, APHIS and CFIA (given their different mandates) undertake audits or reviews on a range of corporate elements such as financial accountability, governance and program performance. The latter can involve technical and operational effectiveness.
- As in the case in DAFF, the USDA and CFIA programs and operations are also subject to audit by their respective national government audit processes, equivalent to the National Audit Office in Australia.
The methodology for development of the IIGB work plan is essentially similar to that used by the OIG, APHIS and CFIA.
- This includes how agencies plan and undertake audit and review activities.
- Their consultation processes, scanning of issues and decision-making on potential audit topics follow established procedures.
- Timeframes for planned audit and review activities within the OIG, APHIS and CFIA are on an annual basis, while more long-term planning is projected across three or five-years. The OIG also undertakes mid-year planning.
- From July 2011, the IIGB proposes to revisit the IIGB program on a quarterly or six-monthly basis, to ensure the list of potential audit and review topics, remains current.
- Unlike the IIGB, the OIG and the CFIA do not appear to have direct consultation processes that involve industry, however this is likely a reflection of their different mandates as compared to the IIGB role.
The IIGB responsibilities for independent audit of biosecurity systems are very similar to that of the relevant part of the OIG role in the US.
- This relates to independence of function, audit approaches, consultation with central contact point throughout an audit and the preparation of draft reports and final reports.
- However, the mandate for the OIG is markedly broader that of the IIGB in terms of the scope beyond biosecurity programs and operations (also its focus on the investigation of fraud and abuse allegations) and the greater size of the resource base, including staffing and budget.
The OIG (also APHIS and CFIA) emphasise the need for audit, review and verification activities to provide findings about whether programs and operations are ‘doing what they should’ and to provide recommendations that are ‘implementable’ and lead to system improvements. This mirrors the directions that the IIGB role is working towards to provide independent reports to the Minister on the performance of DAFF’s biosecurity procedures and operations.
The IIGB reports to the minister and, in general, recommends that audit reports are made publicly available unless they contain a high-level of commercially sensitive information.
- The OIG and CFIA both operate on a policy to publish as many of their reports as possible.
- There is a legislative requirement for the OIG to publish reports in the public domain. However, provision exists for reports that contain sensitive information to undergo relevant amendment before being made publicly available.
- The IIGB proposes that any future IIGB horse pre-export quarantine inspection reports might follow a similar approach, to provide basic summary information that may be made publicly available without compromising commercially sensitive information.
Across the Australian, US and Canadian examples observed, audit and review activities can be broadly categorised as scientific/technical, financial/governance or systems-based audits.
- The IIGB role in Australia undertakes systems and risk management based audits that usually have a technical basis. This involves use of scientific and technical expertise complemented by some formal systems-audit skills.
- Neither the OIG nor the CFIA’s internal audit body have their own biosecurity scientific or technical expertise, to be involved in their audit activities. This is likely a reflection of their different mandates as compared to the IIGB role.
- Where audits of programs that are strongly technically based are undertaken, OIG and the CFIA internal auditors enlist scientific or technical assistance where required, either from relevant parts of their own agencies, academia and/or other external expertise.
Both the OIG and the CFIA were interested in the independent IIGB role that has been developed in Australia, in particular the incorporation of independent scientific and technical expertise in biosecurity into an audit and review role in biosecurity.
An invitation for ongoing contact and dialogue, on matters of common interest in audit and review, was extended to the IIGB by the OIG, CFIA and APHIS.
Dr Kevin Dunn
Interim Inspector General of Biosecurity
26 Sep 2011