National Project Management System Directive on the Monitoring of Real Property Projects' Conformance to the National Project Management System

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1. Effective date

February 6, 2019

2. Cancellation

This directive supersedes the National Project Management System (NPMS) Directive on the Monitoring of Real Property Projects’ Conformance to NPMS, dated June 20, 2016.

3. Authority

This directive is issued under the authority of the Director General (DG), Service Lead, Project Management, Real Property Services (RPS), Public Services and Procurement Canada (PSPC).

4. Context

Project teams monitor a project's ongoing activities against the project plan and the project performance measurement baseline. However, it is also a good practice to monitor conformance with project management standards, policies, directives, and templates by means of NPMS conformance reviews.

To that end, the PSPC Policy on the National Project Management System (106) (page available on Government of Canada network only) imposes specific responsibilities surrounding monitoring and conformance of projects conducted by the Department. This policy stipulates that Branch/Agency Heads and Regional Directors General are responsible for monitoring compliance within their organization and addressing issues of non-compliance.

While projects with high value such as Major Crown Projects tend to be subjected to more stringent monitoring, the Policy on the National Project Management System applies to all real property projects. In addition, an audit conducted by the Office of Audit and Evaluation on the Economic Action Plan (Audit 2011-709) recommended that adequate compliance monitoring be performed on projects with a value of less than $1 million.

Note

The NPMS does not apply to RP-n contractors, instead they are required to follow the principles of the Project Management Body of Knowledge (PMBOK) when delivering projects in Government of Canada assets/facilities. However, there is a requirement for NPMS conformance on the activities performed by resources internal to PSPC.

The Treasury Board Policy on the Management of Projects also requires that an Organizational Project Management Capacity Assessment (OPMCA) be performed every three years. As the NPMS is one of the fundamental elements in the Department's project management structure, annual monitoring of the conformance to the NPMS ensures the Department's capacity for continual improvement of good project management practices.

As an internal auditing standard for the Government of Canada, the Institute of Internal Auditors' (IIA) approach was used for the structure of this directive. The IIA approach is outlined in IIA standards that are divided between attribute and performance areas. The two parts of this directive that correspond to IIA standards were named Organization of the work (Section 7.2) and Description of the work (Section 7.3) for practical purposes.

5. Scope

This directive applies to all PSPC employees involved in the management of real property projects.

As mentioned in the Policy on the National Project Management System, real property projects include all real property asset acquisitions or improvements, including entering into a lease, fit-up of accommodation space, construction, renovation and remediation of a built-work (building, bridge, dam, road, etc.) or crown-owned land. In addition, the review of projects delivered by an external contractor such as RP-n shall still be performed on the activities undertaken by PSPC employees.

Maintenance, demolition and disposal activities are real property projects when affecting real property assets or space. Maintenance activities are not considered projects only when the activity involves the same scope of work, on the same piece of equipment or site, and done every year or more frequently. For example, the same repetitive annual maintenance task performed on a given chiller (such as replacing filters) would not be a project, but the replacement of a chiller would be a project.

To minimize the burden on personnel, the projects reviewed shall:

The project sampling shall exclude projects reviewed in previous years, except projects >$100 million that shall be reviewed each year.

Some projects in SIGMA need not be reviewed when the documents produced for that activity are not part of an approved project. Examples of excluded projects include:

6. Purpose

The purpose of this document is to guide those tasked with conducting the NPMS project conformance reviews mandated under this directive, and to ensure that a formal and consistent conformance monitoring process is in place for all NPMS projects across the country.

7. Directive details

7.1 Activities for conformance monitoring of real property projects

This section describes the activities to be conducted for conformance monitoring of real property projects. Cursory reviews, consisting of a quick verification by a supervisor or a third party, that ensure project documentation is produced and stored for all projects above $250 thousand shall be performed on a continual basis. However, comprehensive reviews shall be performed on a select group of projects as described in this section.

7.2. Organization of the work

This section describes roles, responsibilities, and proficiency requirements. It corresponds to the IIA Attribute Standards. This directive as a whole would be analogous to the internal audit charter that is used in IIA audits.

The person conducting the NPMS conformance reviews must be familiar with the NPMS process and the departmental project management environment. They shall not also be the person managing the reviewed project on a daily basis. If the project to be reviewed is managed within the reviewer's team/division, the reviewer must be someone hierarchically higher than the individual responsible for the project (regardless of the position title of the individual), or someone from a third party area of the organization (such as a quality management group, or other independent departmental resource). To provide some independence where resources are limited, reviewers may come from other sections as long as the reviewer is not a project manager of projects also being reviewed. The reviewer-selection process should ensure that the person has the required independence and objectivity. The person shall report to a regional director, or higher authority, to remove operational influence.

The reviewer shall possess the knowledge, skills, and other competencies needed to perform the core project management review responsibilities, and be familiar with continual improvement activities. Additional professional resources (such as in Finance and Administration Branch or Acquisition Branch) are consulted for issue clarity as required.

Reviews respectful of all stakeholders are fundamental to the process mandated by this directive. The reviews are meant to identify issues and areas to be improved, but they shall also be educational sessions to confirm staff comprehensive understanding of the NPMS. Clear requirements shall also be established for the presentation of evidence.

Competence can be obtained through a mixture of experience and theoretical learning. Project experience gained in organizations of similar size, complexity, sector or industry, and technical issues is more valuable than less-relevant review experience.

7.3 Description of the work

This section describes how the review work is to be conducted. It corresponds to the IIA Performance Standards.

The review activity adds value to the organization (and its stakeholders) when it provides objective and relevant assurance, and contributes to the effectiveness and efficiency of governance, risk management, and control processes. It is recognized that adjustments to the process may be required during the course of the reviews.

7.3.1 Planning the review

The reviewer will develop and document a plan for each annual review process, including objectives, scope, timing, and resource allocations. The annual review consists of six phases:

  1. Planning phase: specific projects to be reviewed are identified according to the "sampling strategy"
  2. Review phase: using a conformance monitoring checklist, the reviewer conducts the reviews. A conformance review form (Annex 1) must be completed for each project reviewed
  3. Analysis phase: the reviewer analyzes the findings for inconsistencies leading to non-conformance
  4. Reporting phase: the reviewer prepares the annual regional/sector report, including the separate NPMS conformance summary report (Annex 2) for Regional Director General (RDG)/DG approval
  5. Action planning: the annual report identifies opportunities for improvement that senior management reviews to create and implement a regional management action plan. This management action plan includes the corrective actions to be undertaken. Responsibility for creation of targets and implementation rests with senior management
  6. Implementation phase: the improvement cycle requires relevant areas of the management action plan to be given a specific focus during the next year's reviews to demonstrate improvement

7.3.2 Performing the review

Reviewers must identify, analyze, evaluate, and document sufficient information to achieve the objectives of the review. The first step is to advise the supervisor/manager of the review framework, and schedule individual reviews based upon operational availability. National process consistency is required to allow for results comparison.

Project staff will be provided with 10 working days' notice prior to the commencement of the project review to ensure that they are available. The notice will explain the review process, and include the NPMS conformance review form. There is an expectation that NPMS-required documentation will be presented using the Electronic Project Filing Structure (EPFS) however, some projects predate EPFS (September 2013), and so there will be certain files that remain in paper or draft form. The review will then proceed.

Note

General notifications can be sent in advance of the review period to the project management population (this includes management, and senior executives), but it shall, under no circumstances, contain any identification of selected projects to be reviewed, nor shall specific project identification be shared whatsoever with anyone until such time as the auditee has been notified (10 business days prior to the actual review).

Project-specific preliminary findings are to be shared with the project leader/project manager to provide an opportunity to correct errors of fact. Project leaders/project managers are to be given five working days to respond.

The objective of performing reviews is to promote a climate of performance excellence, not demonstrate enforcement. Supervisors/managers are welcome to attend the review meetings (or teleconferences), and will be provided with the draft findings and the final regional/sector report. Corrective action(s) will be identified.

Retroactive requirements will not apply. There is a duty of care to ensure documents conform to NPMS requirements in place at the date of signing rather than the most current NPMS edition. For example, in the cases of several multi-year projects, approval phases occurred before 2012, and the NPMS wording in place on the date of signing has been applied.

The reviews of active projects are time dependent, and are to reflect the project progress up to the start day of the review. For on-going projects, there is no requirement to revisit the file for continuing project progress after the start of the review, unless there are non-conformances requiring corrective action, or if the project is selected for a subsequent review process.

The review is used to ensure that projects are managed in accordance with relevant NPMS policies, directives and guidelines in place, and that the necessary evidence of conformance with the NPMS is present.

The review verifies that all project documents:

  • listed in the Annex 1—National Project Management System conformance review form, or another NPMS-directed checklist, have been produced
  • are signed, when required, by the appropriate approval authority, or that there is an email attached to the project document to confirm approval
  • are in conformance with the NPMS and their level of details in accordance with the nature and size of the project
  • are properly stored/filed electronically for easy retrieval. To this end, the Electronic Project Filing Structure shall be used to store all projects documents electronically, including all evidence related to the review. The exact location of the documents should be specified in the Annex 1—National Project Management System conformance review form.

Note that some signed documents such as contracts must be kept in paper format for legal reasons, even if the paper format is not required for NPMS conformance purposes.

7.3.3 Communicating results

Communications must include the review's objectives and scope, as well as applicable conclusions, recommendations, and action plans.

The final report may be in two parts. The first part is a regional process and relates to findings and recommendations for corrective or preventative action for risks beyond NPMS basic conformance, and may be provided to regional management if requested. The second part is the mandatory regional/sector report conforming to the Annex 2—National Project Management System conformance review regional/sector report template.

Sensitivity of project reviews is recognized. Project-specific reviews and findings will not be distributed. Assessment of staff's work is also recognized as sensitive, and initial observations may be revised as additional evidence is provided. Only the reviewer, the supervisor/manager and the individual will be involved in the reviews. Recommendations for corrective action will be made, and a timeline will be identified for this to be implemented. Reviews are usually of on-going projects where there is time to take corrective action. Corrective action plans resulting from serious inability of an individual to implement recommendations may be brought to senior management attention.

The findings in the annual conformance regional/sector review report will be generic and not draw attention to any specific individual's work. These can be used as part of a training program to clarify departmental and professional expectations.

In order to standardize and streamline the reporting process, a regional/sector report template is attached (Annex 2—National Project Management System conformance review regional/sector report template), and shall be used for the production of regional/sector conformance reports. This report is to be produced once a year, no later than June 30.

Any PSPC organization with employees managing real property projects shall also follow this directive and produce the corresponding regional/sector report.

Note

While not required under this directive, it is expected that reviews or audits outside of the NPMS framework will require project evidence on a regular basis, as well as the OPMCA to be done every three years.

7.3.4 Monitoring progress

The reviewer will establish a method to monitor the disposition of results communicated to senior management, who is responsible for action and improvement.

In most cases, areas of non-conformance will be addressed during the review cycle, and this will be documented. Senior management is responsible for systematic problems requiring preventative action. Commitments will be requested and documented for all actions to be undertaken.

A formal progress report is required by the end of November. It should report on the status of the conformance corrections, progress of the action plan and any other relevant matter. This mid-year report is to address the questions that are issued by the Project Management Service Line (PMSL) every year.

7.3.5 Communicating the acceptance of risks

Identification of risk is the responsibility of the reviewer, but acceptance of risk by management may be observed through an assurance process, monitoring progress on actions taken by management, or other means. It is not the responsibility of the reviewer to resolve the risk. The reviewer will document commitments, and these commitments will be reviewed during the next annual conformance review.

7.4 Selecting projects

NPMS conformance reviews shall be conducted for all real property projects undertaken by employees. Note that this includes reviews of both PSPC-funded real property projects and those funded by other government departments (OGDs).

There are four phases to the reviews. In the first phase, regions are responsible for preparing the list of projects (stages 1-6). Regions are to then submit the project sample to PMSL Centre of Expertise (COE) for review. There is no common project sample format since each region has different tools and types of projects. The key is to provide a convincing analysis to justify the project review numbers per category matrix starting with the high level program and progressively filtering to get to NPMS applicable projects. The second phase is to select individual projects to provide a balanced representation of the program and have this approved. The third phase is to conduct the reviews. The fourth phase is for PMSL COE to review a sample of the regional reviews for consistency. 

Roles and responsibilities are explained in this more detailed matrix:

Roles and responsibilities of the Conformance Audit Team members and of the
Project Management Service Line Center of Expertise
Regional Conformance Audit Team (CAT) member Project Management Service Line Center of Expertise (PMSL COE)
1a. Prepares the unfiltered  SIGMA list of all project definitions 1b. Prepares a SIGMA-generated national unfiltered list of all project definitions for independent confirmation.
2a. Applies the dashboard report to filter active projects by directorate/business unit 2b. Prepares the initial assessment to confirm the national dashboard list is accurate and encompasses the review scope.
3a. Prepares the initial characterization showing numbers of projects per NPMS category 3b. Independently confirms the sample size per category reflects the regional workload.
4a. Filters the characterization by
  • NPMS milestone groups
  • NPMS project category segregation
 4b. Reviews, challenges and accepts the filtered characterization
5a. Determines the final stratified sample by NPMS category: this defines the total number of projects and the number subject to 10% review 5b. Confirms acceptance
6a. Selects random individual projects to reflect the characterization & submits to PMSL COE
  • Confirms multi-year total budget
  • Excludes previous year review
  • Confirms sufficient progress
6b. Reviews, challenges and accepts the final project sample.
7a. If required, modifies the sample to ensure it is distributed equitably to be reflective of the work. Submits the characterization and the sample list to PMSL COE review. 7b. File the list to GCdocs, with restricted permissions for PMSL COE, and respective CAT member
8a. Finalizes the list: changes require justification. 8b. Reviews the justification and accepts changes.
9a. Proceeds with reviews. 9b. No action required
10a. Prior to writing the region’s annual report, requests PMSL COE review of the overall process and of individual review results. 10b. Confirms the overall review process conforms to the directive. Selects 10% of the projects reviewed by the region for independent evaluation to confirm interpretation accuracy.
11a. Prepares the final regional annual report. 11b. Reviews the regional report and drafts the national report.
12a. Participates in the year end CAT debriefing, providing lessons learned, observations, and discussing respective regional action plans/recommendations 12b. Leads the findings discussion to identify areas requiring greater interpretation clarity. Gradually identify areas to include in the reviews and areas for improvement. Finalizes the annual national conformance report.

7.5 Integration with existing review or quality management processes

Some sectors or groups may already have a review process in which the requirements of this directive were integrated. Where a region or sector already has in place a review or audit process equivalent to, or more stringent than, the requirements of this directive, they are encouraged to use their established process (instead of a separate NPMS process). This practice is encouraged to minimize work burden, and help make the NPMS conformance review process an integral part of normal business. However, the annual NPMS conformance review shall follow, at minimum all protocols defined within this directive, including selection of projects, communication / notification protocols, and all reporting requirements.

7.6 Project Management Service Line Center of Expertise role

In an effort to verify that the regional reviewers’ annual processes and performance conform to the Directive on the Monitoring of Real Property Projects’ Conformance to NPMS, the PMSL COE will work with the CAT (chaired by a regional representative) to coordinate related activities.

The PMSL COE’s task is to review the performance of the regional review/ processes by assessing the accuracy and consistency of interpretation.  Where inconsistencies occur, a national and regional discussion will occur to determine the root cause of the problem. Where interpretation grey areas are identified, the PMSL COE will bring these topics to the CAT and/or the NPMS Continual Improvement Team for discussion to ensure future consistency.

PMSL COE will prepare an annual Report on National Project Management System (NPMS) Conformance by the end of October. The report will comment on regional conformance to the monitoring directive.

8. Responsibilities

Directors General and Regional Directors General are responsible for:

Managers of real property projects in every region and service line, as well as those in Parliamentary Precinct Branch, are responsible for:

Organizations providing services for projects led by another departmental organization do not have to perform NPMS conformance monitoring described under this directive. The organization responsible for the project to which services are being provided is responsible to undertake the necessary reviews.

9. Definitions

Asset project (Projet relatif aux biens)

A project where the primary driver is the need to build, upgrade or replace an existing real property asset and/or its components. An asset project is not a repetitive and frequent activity such as maintenance work required to keep the asset operational.

Compliance (Conformité)

The state of adherence of a regulated party or a product with a legislative or regulatory requirement.

Conformance (Respect)

The state of adherence to a regulated party's written programs or policies.

Other government department (OGD) project (Projet d'autres ministères)

A project to meet an OGD need with an asset for which an OGD is the custodian. The OGD is responsible for funding and project approvals. This type of project could be either a space or asset project.

Space project (Projet relatif aux locaux)

A project where the primary driver is the need for accommodation space through the provision (acquisition or construction) and/or modification of interior and/or exterior space. Examples of possible space projects include: lease; lease-purchase, purchase or construction of new space; additions to an existing PSPC owned building; and space optimization and fit-up or refit.

Substantially completed investment analysis report (IAR) (Analyse des investissements (RAI) presque achevé)

An IAR is considered substantially completed if the following will not change:

  • the recommended option (feasibility report has been signed by the appropriate approval body)
  • the scope of the project (m², timing of project, duration of projects, project size or dollar value, etc.)
  • the Project Complexity and Risk Management (PCRA) score
Tenant service project (Projet de services aux locataires)

Services requested by a tenant in PSPC-administered space. The OGD is responsible for funding and project approvals. This type of project could be either a space or asset project.

10. References

Treasury Board Publications

Public Services and Procurement Canada publications

External publications

11. Attachments

12. Enquiries

Please direct all enquiries about this directive to the Project Management Service Line Centre of Expertise to tpsgc.sngp-npms.pwgsc@tpsgc-pwgsc.gc.ca.

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