Members MEMO: Performance Assessment Committee
By Dave Newton, Chair Nov 30, 2012
The Board has approved an amendment to Rule 28 of the Bylaws, which states the performance assessment (PA) frequency. Going forward, the frequency of random PAs will be conducted at the ratio of 1 in 8, regardless of whether the submissions are standards or risk based. This change was proposed by the Performance Assessment Committee to reflect their observations over the past 4 years.
The proposed change was previously discussed at the June CSAP AGM and the recent October Workshop where it was noted as likely to be forthcoming. Effectively, this change means the frequency of Performance Assessments will decrease from 1 in 5 to 1 in 8 for risk based submissions while maintaining the frequency of standards submissions at 1 in 8. Although standards submissions were previously selected for a PA at a frequency of 1 in 10, the work of Standards APs was also subject to PA process via the risk assessment PA process; specifically, the Standards portion of the submission was also selected for a PA with each risk based PA. Over the past four plus years standards PAs have occurred at an effective, average frequency of 1 in 8 when all submissions signed by Standards AP were considered. Thus the past frequency of standards AP submissions is maintained by this Rule change.
The MoE has recently confirmed for CSAP that the following is their current policy. If there are multiple instruments being requested, based on a single set of reports, then each submission will require a separate SoSC report, but only a single fee of $2,000 plus GST will be required by the Ministry to review all of the SoSCs. Previously other alternatives had been allowed by the MoE but the above reflects their current position
Please be reminded that Scenario 4 and 5 releases under AG#6 that include a detailed risk assessment component must be signed by a CSAP Risk-based Approved Professional. Therefore 1 or 2 confirmation letters will be required to address the standards and/or risk assessment aspects of the proposed or completed remediation approaches.
It has come to our attention that there is some confusion amongst the membership in regards to how CSAP fees associated with applications for multiple instruments are calculated. To assist our membership when preparing cheques we have prepared the following reminder. The following is Footnote 2 from CSAP’s Submission Fee schedule:
“Fees for submission(s) containing multiple instrument applications but supported by a single report or set of reports (for example a single PSI, DSI and COR as separate reports or incorporated into a single report): Fees will be assessed at 100% of the most expensive instrument application, 50% of that the most expensive application for a second instrument application, and 25% of that the most expensive instrument application for any additional applications supported by the report or set of reports.”
Example Calculation: A submission arrives containing Detailed Risk based CoC, a standards based CoC and a risk based AIP supported by a single set of reports. The most expensive of the three instruments would be the risk based AiP. Calculation: most expensive instrument, AiP $15,000, second instrument 50% * $15,000, third instrument 25% * $15,000, total CSAP fees = $15,000 *1.75 = $26,250
A common error that we have observed is that submitters are not calculating the additional fees for the 2nd and 3rd instruments, etc, (e.g. 50%, 25%) based on the most expensive instrument but rather based on 50%, 25% of the other instruments being requested. So in the above example, the 50% fee for the second instrument is calculated by taking 50% of the risk based AIP fee, not 50% of the risk based CofC or standards CofC fee.