Follow-up report to the 2020-2021 procurement practice review of Parks Canada

February 2025

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Introduction

1. In accordance with paragraph 22.1(3)(a) of the Department of Public Works and Government Services Act, the Procurement Ombud has the authority to review the procurement practices of departments to assess their fairness, openness and transparency and to make any appropriate recommendations to the relevant department for the improvement of those practices. Such reviews, which are performed by the Office of the Procurement Ombud (OPO), are referred to as Procurement Practice Reviews (PPRs).

2. In 2020-2021 OPO conducted a PPR entitled “Procurement Practice Review of Parks Canada,” which included four recommendations to address identified issues. A final report was issued in July 2021 and published on OPO’s website.

3. As a standard practice, OPO follows up on recommendations resulting from PPRs. This is done in order to determine whether federal departments have implemented their management action plans in response to the Procurement Ombud’s recommendations. This Follow-up Review includes a summary of results from the initial PPR and OPO’s assessment of progress made by Parks Canada in response to the Procurement Ombud’s four recommendations. This report also includes an organizational report card that facilitates comparisons across federal departments over time.

Results from initial procurement practice review

4. The objective of the initial PPR of Parks Canada was to determine whether the Department’s procurement practices pertaining to evaluation criteria and selection plans, solicitation, and evaluation of bids and contract award, supported the principles of fairness, openness and transparency.

5. For the PPR, OPO analyzed Parks Canada’s procurement practices under three Lines of Enquiry (LOE). Below are descriptions of the LOEs, a brief summary of observations for each, and the Procurement Ombud’s four recommendations included in the initial PPR report.

Line of Enquiry 1: Evaluation criteria and selection plans were established in accordance with applicable laws, regulations and policies

6. For LOE 1, OPO’s initial review found that overall, mandatory criteria were aligned with requirements and were not unnecessarily restrictive. However, in a number of files reviewed, the mandatory criteria were not communicated in a clear, precise or measurable manner. Point-rated criteria were found to be appropriate to the requirement and not unnecessarily restrictive. However, some solicitations contained missing, incorrect or unclear information regarding point-rated criteria or associated rating scales. Additionally, OPO found that the selection methodology was clear and aligned with the requirements in all solicitations reviewed.

7. The Procurement Ombud made one recommendation to address the issues identified under LOE 1:

Recommendation 1: Parks Canada should ensure that its existing Guide for the Bid Evaluation Process is followed and that evaluation criteria and rating scales are communicated in solicitations in a clear, precise, and measurable manner.

Line of Enquiry 2: Solicitation documents and organizational practices during the bid solicitation period were consistent with applicable laws, regulations and policies

8. For LOE 2, OPO’s initial review found that the duration of solicitation periods was appropriate and solicitations were open to an appropriate number of suppliers in all files reviewed. However, some solicitations included incomplete, incorrect or contradictory information. In addition, in most applicable solicitations reviewed, OPO found evidence of appropriate communication with suppliers during the solicitation period.

9. The Procurement Ombud made one recommendation to address the issues identified under LOE 2:

Recommendation 2: Parks Canada should develop and implement a process to ensure the completeness, consistency and accuracy of all information contained in solicitation documentation to avoid discrepancies in its solicitation processes.

Line of Enquiry 3: Evaluation of bids and contract award were conducted in accordance with the solicitation

10. For LOE 3, OPO’s initial review found that bids were evaluated consistently and in accordance with the planned approach, and bid evaluation results were adequately documented in more than half of the applicable files reviewed. In a significant number of files, however, OPO found irregularities or documentation issues in the evaluations. Otherwise, OPO found that Parks Canada’s procurement file documentation was generally complete.

11. The Procurement Ombud made two recommendations to address the issues identified under LOE 3:

Recommendation 3: Parks Canada should implement appropriate supervision and review mechanisms to ensure evaluations are carried out in accordance with the planned approach and are appropriately documented to support the transparency of the award process.

Recommendation 4: Parks Canada should update its procurement guidance to clarify procedures and documentation requirements related to evaluator conflict of interest attestations.

Methodology and management action plan assessment summary

12. When launching this Follow-up Review in March 2024, OPO asked Parks Canada to self-assess their progress in implementing the four recommendations stemming from the initial 2021 review, using a progress scale provided by OPO. This scale ranged from “No progress” (level 1) to “Full implementation” (level 5), as outlined in Appendix 1. Furthermore, Parks Canada was asked to provide OPO with documentation to support their self-assessment. OPO reviewed Parks Canada’s self-assessment and supporting documentation for its overall reasonableness and credibility.

13. Regarding recommendation 1, Parks Canada self-assessed the level of implementation of their actions between level 4, i.e., “Substantial implementation” and level 5, i.e., “Full implementation.” For recommendations 2, 3 and 4, Parks Canada self-assessed their level of implementation at level 5. While substantiating documentation provided by Parks Canada demonstrated progress and showed that structures and processes are in place and integrated within the Department, it did not clearly demonstrate that the results achieved are a direct and intended outcome of these interventions for three of the four recommendations. Therefore, OPO assessed Parks Canada’s level of implementation at level 4 for recommendations 1, 2 and 3. OPO agreed with Parks Canada’s self-assessment for recommendation 4 and assessed the level of implementation for this recommendation at level 5. Details of OPO’s assessment are provided in Appendix 3.

14. The Follow-up Review showed that overall, Parks Canada has implemented certain tools and training that support fairness, openness, and transparency in the procurement process with the purpose of meeting the intent of each recommendation. Some of these products and practices include:

  1. (Partial) training of its staff (i.e., Developing a Statement of Work (SOW) and Evaluation Criteria training, and Bid Evaluations and Contractor Section Methodologies training);
  2. Real Property Contracting and Goods and Services guides to Setting an Evaluation Board and Guides for the Bid Evaluation Process;
  3. Procurement Quality Assurance (QA) Program and related checklist (i.e., QA checklist);
  4. Evaluation Flowchart; and
  5. Bid evaluation meeting email template.

15. It should be noted that a number of these initiatives were already in place before the initial PPR report was issued in July 2021. For example, while the Goods and Services Guide was implemented in February 2024, the Real Property Contracting Guide has been in place since April 2021. Likewise, the department has continued to implement their Procurement QA Program created in 2017 and modified before 2021. Given that most of these tools and processes were already in place by the time OPO’s PPR report was issued in July 2021, it was not always clear what changes were made to respond to the recommendations and what impact these particular measures (whether changed or unchanged) had on Parks Canada’s procurement processes.

16. To further support the effectiveness of their initiatives, it is paramount for Parks Canada to have in place a tracking and monitoring mechanism to better connect the impact of measures taken with the results identified.

Report card

17. PPR follow-up reviews include a report card with a rating that depicts the department’s performance, taking into consideration the results from the initial review and the actions taken by the department to implement the recommendations under each LOE. The assessment ratings are as follows:

  • Satisfactory Plus
  • Satisfactory
  • Partially Satisfactory
  • Unsatisfactory

18. Note that a “Satisfactory Plus” assessment rating is only possible when the initial review resulted in no recommendations being issued under a particular LOE. As the initial Parks Canada review contained recommendations under all three LOEs, a “Satisfactory Plus” rating was not possible in this Follow-up Review, and the highest possible score Parks Canada could obtain for each LOE was “Satisfactory.” Assessment definitions and criteria are outlined in Appendix 2.

19. After reviewing progress made toward implementing the action plans for each recommendation, and in consideration of the established assessment ratings, OPO determined a rating of “Satisfactory” for LOE 1, LOE 2 and LOE 3. Overall, Parks Canada’s descriptions of actions taken and their supporting documentation demonstrate that reasonable and credible progress has been achieved. Moving forward, it is recommended to have in place a tracking and monitoring mechanism to better connect the impact of measures taken with the results identified. This step would assist the Department to be better prepared for the scrutiny of future internal audit activities or to defend against external challenges.

Details of the report card
Line of Inquiry Rating Assessment
Evaluation criteria and selection plans were established in accordance with applicable laws, regulations and policies. Satisfactory
  • Recommendation 1 applied to this LOE.
  • Parks Canada has applied a combination of new and existing tools, programs, and processes to address this recommendation.
  • Some delays - particularly related to the implementation of the training program - make it challenging to demonstrate the impact of these measures.
Solicitation documents and organizational practices during the bid solicitation period were consistent with applicable laws, regulations and policies. Satisfactory
  • Recommendation 2 applied to this LOE and it relates to the Procurement QA Program.
  • This program has been in place and operating without any modifications since before the release of OPO’s report in 2021.
  • The Department would further benefit from clearer linkages between actions taken and the results achieved.
Evaluation of bids and contract award were conducted in accordance with the solicitation. Satisfactory
  • Recommendations 3 and 4 applied to this LOE.
  • Parks Canada has applied a combination of new and existing tools, templates and products to address these recommendations.
  • Measures taken demonstrate that structures and processes are in place, followed and integrated within the organization and applied in a consistent manner.

Table 1 Note

Parks Canada’s overall report card rating is “Satisfactory.” The key factors contributing to this rating include:

  • The initial review resulted in one or more recommendations under each of the three LOEs, thus precluding a rating higher than “Satisfactory”;
  • Parks Canada’s Management Action Plan has achieved level 4 implementation for recommendations 1, 2 and 3, meaning that substantial progress has been made; and level 5 implementation for recommendation 4, meaning structures and processes are fully implemented and operating as intended and results have been identified; and
  • The lack of a tracking and monitoring mechanism that connects the actions taken with the results identified precludes this otherwise good assessment from receiving a level 5 “Full implementation” for most recommendations.

Conclusion

20. Parks Canada has used a combination of existing and new tools and training to support fairness, openness, and transparency in the procurement process, and to address the recommendations of the Procurement Ombud following the release of the initial Parks Canada’s PPR report in July 2021. The evidence provided showed that Parks Canada has taken certain measures designed to meet the intent of each of the four recommendations stemming from the initial review.

21. The Follow-up Review concluded that overall, Parks Canada’s self-assessment, supported by substantiating documentation, demonstrated progress made in relation to the recommendations in the initial PPR report. However, some aspects of the self-assessment have been adjusted following OPO’s review of substantiating documentation and additional clarifications provided by the Department to the questions posed.

22. OPO found that structures and processes are in place, followed and integrated within the organization; however, there was not always clear evidence showing that the results achieved are a direct consequence of these interventions. Not being able to directly connect the measures taken with the results noted would preclude most actions from a level 5, “Full implementation,” rating. As a result, OPO concludes that the progress noted is predominantly at level 4 “Substantial implementation.”

23. OPO reiterates the importance of having in place a tracking and monitoring mechanism that connects the actions taken with the results identified. This additional step will better prepare the Department for the scrutiny of future internal audit activities or to defend against external challenges. OPO is encouraged by the Department’s plans for the continuous improvement of its quality assurance process and for tracking linkages between changes implemented and results achieved.

24. Finally, the Procurement Ombud commends Parks Canada for its commitment to supporting fairness, openness, and transparency in the procurement process and for the progress noted to date. Parks Canada’s timely responses to OPO’s requests and follow-up questions pertaining to this review were appreciated.

Appendix 1: Assessment of implementation level

Assessment of implementation level
Implementation level Assessment
Level 1 No progress or insignificant progress. Actions such as establishing a new committee, conducting meetings, and generating informal plans have not advanced, or insignificant progress has been made.
Level 2 Planning stage. Formal plans for organizational changes have been created and approved.
Level 3 Preparations for implementation. Preparations for implementing a recommendation are in progress – e.g., hiring or training staff, developing necessary resources, etc.
Level 4 Substantial implementation. Structures and processes are in place and integrated within at least some parts of the organization, and some achieved results have been identified.
Level 5 Full implementation. Structures and processes are fully implemented and operating as intended and results have been identified.
Obsolete Recommendation is no longer applicable due to new policies, procedures, etc.

Appendix 2: Overall performance assessment scale

Overall performance assessment scale
Overall performance Assessment of performance
Satisfactory Plus
  • Findings from the initial PPR resulted in no recommendations being issued under the line of inquiry
  • A rating of Satisfactory + is based on results from the initial PPR
Satisfactory
  • Initial PPR resulted in one or more recommendations under the line of inquiry
  • Action plan(s) have achieved level 5 implementation or a combination of level 4 and level 5 that is deemed to be satisfactory, i.e. significant progress has been made to implement action plan(s) that address recommendation(s)
  • Organization's response is supported with adequate documentation and/or testing results
Partially satisfactory
  • Initial PPR resulted in one or more recommendations under the line of inquiry
  • Some progress has been made in implementing action plan(s), but not enough to adequately address all recommendations under the line of inquiry, e.g. one or more recommendations achieved level 3, but work remains to be done
  • Organization's response is supported with some documentation and/or testing results.
Unsatisfactory
  • Initial PPR resulted in one or more recommendations under the line of inquiry
  • No or insignificant progress made to implement action plan(s).
  • Inadequate supporting documentation provided or testing does not demonstrate that positive results have been achieved
  • Recommendation(s) not addressed and remain(s) outstanding.

Appendix 3: Assessment of recommendations

Office of the Procurement Ombud detailed assessment and summary of recommendations
Parks Canada’s Action Plan OPO’s Assessment Level
Recommendation 1: Parks Canada should ensure that its existing Guide for the Bid Evaluation Process is followed and that evaluation criteria and ratings scales are communicated in solicitations in a clear, precise, and measurable manner.

Parks Canada recognizes the importance of ensuring that procurement processes are followed, communicated clearly, and that criteria are precise and measurable. Parks Canada will continue with the work that has been completed to date regarding the development and delivery of mandatory training for all procurement staff on the bid evaluation process. The training will cover bid evaluation processes and development of evaluation criteria and rating scales in appropriate detail.

Timeline: Parks Canada is planning to have this training delivered to procurement staff by March 31, 2022.

Parks Canada will ensure that the Guide for the Bid Evaluation Process is followed, when applicable, and is communicated appropriately. The Guide will be shared with the bid evaluation team in pre-evaluation meetings (when applicable) that will occur between the contracting officer and the evaluation team prior to the evaluation getting underway.

Timeline: Parks Canada will create a templated bid evaluation meeting invitation which includes the Guide for the Bid Evaluation Process by March 31, 2022.

Parks Canada will continue its work to ensure that evaluation criteria and rating scales identified in bid solicitations are clear, precise and measurable.

Timeline: Ongoing through procurement quality assurance process.

Recommendation 1 had 3 sets of action items:

  1. Mandatory training of all procurement officers on selected topics;
  2. That the Guide for the Bid Evaluation Process is followed, communicated properly and in advance, including creating a template bid evaluation meeting invitation; and
  3. That evaluation criteria and rating scales are clear, precise and measurable.

On the first action item, Parks Canada activities included training for its procurement officers on developing SOWs and evaluation criteria, as well as on bid evaluation methodologies. By November 2024, most of its procurement staff were trained in developing SOWs and evaluation criteria, and all staff on bid evaluation and contractor section methodologies.

As per the action plan, the targeted deadline for Parks Canada to train its procurement staff was March 31, 2022. The Department noted in its self-assessment form that their procurement team has had significant turnover, resulting in the hiring of new employees, many at a junior level (PG-02). According to the Department, these courses are usually recommended to officers with a minimum of 1 to 2 years of contracting experience. Therefore, staff turnover and the junior level of the newly hired staff have impeded Parks Canada to fully meet the goals of this action item by the anticipated deadline.

Furthermore, given that the Bid Evaluation Course (COR6201) is no longer developed and delivered by Public Services and Procurement Canada (PSPC), Parks Canada delivered similar training in-house to all Parks Canada’s procurement officers on November 27, 2024.

On the second action item, Parks Canada noted that it has developed and implemented Real Property Contracting and Goods and Services respective Guides to Setting an Evaluation Board and Guides for the Bid Evaluation Process. The department has also developed and implemented the use of a bid evaluation meeting email template. As the Goods and Services Guide was developed in February 2024, a short time before this follow-up review was launched, it makes demonstrating the impact of the guide in the short-term challenging. In addition, Parks Canada has developed and implemented a bid evaluation meeting email template, as per the agreed action plan. Parks Canada confirmed that since the implementation of Evaluation Guides and templates it has not yet received any recent complaints to the available recourse mechanisms (Canadian International Trade Tribunal [CITT] or OPO).

On the third action item, Parks Canada noted that it continues to require pre-solicitation and evaluation consensus comments and quality assurance reviews of all solicitations which include point-rated criteria by PG-05 level contracting authorities and that no additional changes were implemented to their Procurement QA Program since the release of OPO’s PPR report in 2021. OPO received and reviewed two sample forms entitled “Parks Canada Agency Quality Assurance and Approval Document” issued in relation to a two-stage solicitation that included point-rated criteria in each stage. Both forms included QA notes and were properly dated and signed by the contracting authority and the approval authority.

While recognizing the progress noted, the delays in the implementation of the training component under this recommendation, as well as in issuing the Goods and Services Guide, precludes a level 5 rating for actions taken under this recommendation OPO agrees with the department’s self-assessment for this recommendation and assigns to it a level 4 rating.

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Recommendation 2: Parks Canada should develop and implement a process to ensure the completeness, consistency and accuracy of all information contained in solicitation documentation to avoid discrepancies in its solicitation processes.

The Agency has made significant enhancements to the delivery of procurement services and practices since 2019 (the period ending for this review). Parks Canada created its procurement quality assurance program in late 2017 and has continuously brought proactive modifications to it and now ensures that all procurements prior to solicitation require a review by a peer, or senior level contracting expert depending on value, complexity, risk and/or other considerations (e.g., sensitivity). This process ensures a second review on all procurement documents regardless of dollar value. Additionally, all requirements that contain point-rated evaluation criteria must be reviewed by a PG-05 (at a minimum) prior to the award. Parks Canada is confident that these changes have already begun to improve the quality and accuracy of evaluations in the Agency’s procurement processes.

Timeline: Complete. However, the Agency will further review procurement quality assurance processes based on all recommendations in this report and implement any improvements by March 31, 2022.

Parks Canada confirmed in its self-assessment form that the Department continues to require pre-solicitation and evaluation consensus comments with QA reviewing all solicitations that include point-rated criteria by PG-05 contracting authorities. Their purpose is to ensure that evaluations are conducted in accordance with the defined solicitation. The Department confirmed that no changes have taken place to their Procurement QA Program since the release of OPO’s PPR report in July 2021.

OPO received and reviewed two sample forms entitled “Parks Canada Agency Quality Assurance and Approval Document,” that were completed by procurement officers in relation to a two-stage solicitation that included point-rated criteria in each stage. Both forms included QA notes and were properly dated and signed by the contracting authority and the approval authority.

Back in 2021, Parks Canada expressed confidence that the changes implemented in their QA program prior to the release of the initial review report had begun to improve the quality and accuracy of evaluations and awards in the Parks Canada’s procurement processes. The QA forms OPO reviewed show that structures and processes are in place, followed and integrated within the organization. However, the Department would have benefited from the review of procurement quality assurance processes based on the recommendations of the initial report and from clearer linkage between the actions taken and results achieved. Lack of this final step precludes a level 5 rating for actions taken under this recommendation.

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Recommendation 3: Parks Canada should implement appropriate supervision and review mechanisms to ensure evaluations are carried out in accordance with the planned approach and are appropriately documented to support the transparency of the award process.

The Agency has made significant enhancements to the delivery of procurement services and practices since 2019 (the period ending for this review). Parks Canada created its procurement quality assurance program in late 2017 and has continuously brought proactive modifications to it and now ensures that all requirements which contain point-rated evaluation criteria must be reviewed by a PG-05 (at a minimum) prior to the award. Parks Canada is confident that these changes have already begun to improve the quality and accuracy of evaluations and awards in the Agency’s procurement processes.

Timeline: Complete. However, the Agency will further review procurement quality assurance processes based on all recommendations in this report and implement any improvements by March 31, 2022.

Additionally, Parks Canada will ensure that the contracting authority participates in the consensus meeting if and when required. Further, Parks Canada will ensure that more detailed individual evaluator and consensus notes are received from the evaluation board and placed on the file.

Timeline: Parks Canada will complete this update by March 31, 2022

Planned action items under this recommendation included:

  1. Parks Canada to continue with the application of the existing Procurement QA Program; and
  2. Parks Canada to ensure that the contracting authority participates in the consensus meeting, if and when required, and that more detailed individual evaluator and consensus notes are received and placed on file.

(i) On the first action item, Parks Canada confirmed that they require pre-solicitation and evaluation consensus comments, and Quality Assurance reviews of all solicitations which include point rated criteria by PG-05 contracting authorities to ensure evaluations are carried out in accordance with the defined solicitation.

OPO received and reviewed two sample forms entitled “Parks Canada Agency Quality Assurance and Approval Document” issued in relation to a two-stage solicitation that included point-rated criteria in each stage. Both forms included QA notes and were properly dated and signed by the contracting authority and the approval authority. The QA forms OPO reviewed show that structures and processes are in place, followed and integrated within the organization.

(ii) On the second action item, Parks Canada has incorporated language in the evaluation package and in the evaluation flow chart requesting that contracting authorities host and facilitate consensus evaluation meetings when point rated criteria are applied. These documents also show that contracting authorities are responsible for administering and clarifying consensus comments and ensuring that the same are reflective of defined evaluation criteria and subsequent grading documentation.

Collectively, the QA forms and the evaluation guide, package and flow chart demonstrate that structures and processes are in place, followed and integrated within the organization. However, the Department would have further benefited from the review of procurement quality assurance processes based on the recommendations of the initial PPR report and clearer linkages between the actions taken and results achieved. Lack of this additional step precludes a level 5 rating for actions taken under this recommendation.

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Recommendation 4: Parks Canada should update its procurement guidance to clarify procedures and documentation requirements related to evaluator conflict of interest attestations.

Parks Canada will review and update guidance for the bid evaluation process and ensure that conflict of interest is addressed appropriately. This guidance will be issued to evaluation team members on every procurement, as applicable.

Timeline: Parks Canada will complete this update by March 31, 2022.

Anticipated actions under this recommendation required Parks Canada to review and update guidance for the bid evaluation process and ensure that conflict of interest is addressed and that guidance is issued to evaluation team members.

OPO found that the Confidentiality and the Conflict of Interest declarations were part of the evaluation package and sent to evaluators ahead of the evaluation process. A small sample of three completed Conflict of Interest and Confidentiality declarations were provided to OPO related to a recent solicitation. These forms were properly signed and dated by the evaluators.

The evaluation guide, package, and flow chart, as well as the sample confidentiality and conflict of interest forms received demonstrate that structures and processes are fully implemented and operating as intended.

The Department has fully delivered on the action plan and level 5 implementation is allocated to this recommendation.

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