2015-2016 Compliance Assessment Action Plan

Table of contents

Arctic Connection

Auditors Recommendations for Arctic Connection Arctic Connection Action Plan Status
1. Processing and Reporting Controls: Implement a process whereby there is an independent review of claims prior to submission to NNC for processing. This has the potential to reduce the number of errors in the claims. 1-3.Processing and Reporting Controls/Ineligible Clients: The Recipient has developed and implemented a process to review claims prior to submitting them to NNC's Third Party Claims Processor for processing. This process ensures that the correct subsidy rates and coding have been applied and reflected on associated invoices, and that ineligible clients do not have access to goods shipped by the Recipient under the Nutrition North Canada program. The Recipient will contact their NNC representatives should they have any questions regarding coding and eligibility.              Complete - Document Received
2. Processing and Reporting Controls: The Recipient should ensure that the preparers and reviewers of claims are familiarized with the most recent NNC coding and obtain clarification from NNC representatives where coding classification is unclear.  This will ensure that claims are maximized for the consumer. Complete - Document Received
3. Ineligible Clients: The Recipient should establish a process to ensure that the ultimate consumer is an eligible consumer per the terms and conditions of the Program. We recommend that the Recipient implement a process to ensure that ineligible parties do not have access to goods shipped by the Recipient under the Nutrition North Canada program. Complete - Document Received
4. Profit Margins: The Recipient should establish a clear policy in regards to profit margins in order to ensure that markups calculated on goods and invoices are correctly applied and do not erode the subsidy.  The Recipient should be able to demonstrate that the margins do not erode the subsidies. 4. Profit Margins: The Recipients markup is consistent between communities, finding the best price for customers and passing all deals along to them. Complete - Document Received
5. Supply Chain: The Recipient should consider implementing a process to periodically review their agreed upon rates with preferred airlines with market rates published online in order to ensure they are shipping goods at the most cost-effective prices. 5. Supply Chain: The Recipients airline rates stay the same, if rates do go up or down the Recipient is informed and passes that notice to their customers. Complete

Arctic Co-Operatives Ltd.

Auditors Recommendation for Arctic Co-Operatives Ltd. Arctic Co-Operatives Ltd. Action Plan Status
1. Processing and Reporting Controls: The Recipient should consider implementing data entry controls to ensure subsidy rates and eligibility as entered into the retail system are accurate and appropriate. The auditors noted that the full subsidy was passed to the member co-ops however; they were unable to observe pricing methodology as well as profit margins applied to determine retail prices to end users at the member co-op level. 1. Processing and Reporting Controls: The Recipient has developed and implemented a change log and dual sign-off process for all changes related to subsidy rates to ensure a greater degree of control. The greater degree of frequency of item additions and changes make the area of item eligibility one requiring a greater degree of specialization and expertise. Arctic Co-ops will explore greater cross-training options and practical means to introduce greater oversight in this area. Complete – Document Received

The Northern Shopper

Auditors Recommendation for The Northern Shopper The Northern Shopper Action Plan Status
The Compliance Assessment Report describes the Auditor's observations, conclusions and recommendations for your organization. The Auditors found that the full subsidy is being passed on to the consumer but were not able to assess your pricing methodology as policies were inconsistently applied. Deloitte also noted the need to improve control environment in order to detect any errors that may occur before submission to NNC. They noted that a new process has been implemented to standardize pricing methodology and to provide an independent review of claims. Pricing Methodology:

A new process to show Product, Produce and Freight Markups has been developed and implemented. Documentation detailing the new process has been provided to INAC and is on file.
Complete – Document Received
Control Environment: The Recipient has developed and implemented a process to review claims prior to submitting them to NNC's Third Party Claims Processor for processing. This process ensures that the correct subsidy rates and coding have been applied and reflected on associated invoices, and that ineligible clients do not have access to goods shipped by the Recipient under the Nutrition North Canada program. The Recipient will contact their NNC representatives should they have any questions regarding coding and eligibility.        Complete – Document Received

Marché Central du Nord

Auditors Recommendation for Marché Central du Nord Marché Central du Nord Action Plan Status
1. Processing and Reporting Controls: Address weaknesses in its data integrity within the inventory management system used for reporting (i.e. weights, eligible communities, subsidy rates). We recommend that the Recipient ensure that programmed NNC data is reviewed after data input in order to ensure the validity and accuracy of claimed amounts. 1-3. Processing and Reporting Controls/Ineligible Clients: The Recipient has developed and implemented a process to review claims prior to submitting them to NNC's Third Party Claims Processor for processing. This process ensures that the correct subsidy rates and coding have been applied and reflected on associated invoices, and that ineligible clients do not have access to goods shipped by the Recipient under the Nutrition North Canada program. The Recipient will contact their NNC representatives should they have any questions regarding coding and eligibility.           Complete – Document Received
2. Processing and Reporting Controls: Implement a process whereby there is an independent review of claims prior to submission to NNC for processing. This has the potential to reduce the number of errors in the claims. Complete – Document Received
3. Ineligible Clients: Implement a process to ensure that the ultimate consumer is an eligible consumer according to the terms and conditions of the Program. We recommend that the Recipient implement a process to ensure that ineligible parties do not have access to goods shipped by the Recipient under the Nutrition North Canada program. Complete – Document Received
4. Profit Margin: Establish a defined pricing policy (markups and fees) and implement controls to ensure consistent application of the policy in establishing customer sales prices. 4. Profit Margin: We use the database of the Métro chain (BDMS) to manage our sales prices. We cannot raise the prices taken from this database. Weekly price changes are made automatically every Wednesday night. Clients benefit from the special prices in Métro's circular from Thursday to Wednesday each week. We keep a paper copy of the circular each week with our weekly billing. Additional amounts are added to Métro's prices: preparation and packaging costs, land transportation costs, and overhead for each order. These additional costs are added to the total billed, and the formula will be applied systematically to each order and will be recorded and given to auditors in the event of an assessment.   Complete – Document Received
5. Profit Margin: Obtain and retain supplier information related to the cost of goods to be able to consistently and accurately price products for sale. 5. Profit Margin: Since our main supplier is Métro and we use their database (BDMS), it is possible to consult this database and print out various BDMS reports on Métro's cost and selling prices. Complete – Document Received

Meechim North 2000 Inc.

Auditors Recommendation for Meechim North 2000 Inc. Meechim North 2000 Inc. Action Plan Status
Processing and Reporting Controls: Implement a process whereby there is an independent review of claims prior to submission to NNC for processing. This has the potential to reduce the number of errors in the claims. Processing and Reporting Controls: The Recipient has developed and implemented a process to review claims prior to submitting them to NNC's Third Party Claims Processor for processing. This process ensures that the correct subsidy rates and coding have been applied and reflected on associated invoices, and that ineligible clients do not have access to goods shipped by the Recipient under the Nutrition North Canada program. The Recipient will contact their NNC representatives should they have any questions regarding coding and eligibility.           Complete – Document Received

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