ONTARIO NATIVE EDUCATION COUNSELLING ASSOCIATION

P.O. Box 220, 37A Reserve Road, Naughton, Ontario, P0M 2M0 Phone: (705) 692-2999 Fax: (705) 692-9988 Email: oneca@oneca.com Website: www.oneca.com
July 9, 2013 Ms. Joanne Wilkinson Regional Director General Aboriginal Affairs and Northern Development Canada Gatineau, Quebec K1A 0H4 Dear Ms. Wilkinson: On July 15, 2013 the new Education Information System for post- secondary reporting will be implemented by AANDC. AANDC has informed First Nations that failure to meet the deadline can result in financial hold back for post-secondary funding. Members of ONECA have stated that they do not feel they have been adequately consulted nor prepared to implement the new guidelines and that the system they are expected to report under is flawed and that the information being requested is unreasonable. The system is not sufficiently developed to make this a seamless reporting for First Nations. The Education Information System (EIS) has been promoted since early 2010 and several versions of the system have been introduced and modified. AANDC with the Chiefs of Ontario undertook a two day planning session in Thunder Bay in March 2010 and in Toronto in November 2010. The regional sessions were held for the purpose of obtaining feedback on the development of the First Nation Education Information System. The reporting system that AANDC has produced contains significant deficiencies and was not in any state that First Nations could provide adequate and detailed response to the reporting system. The Post -Secondary report is part of an overall education information system that will include elementary secondary and special education which will be compiled into a single national system that is web based. The new EIS system is estimated to cost 27 million over 5 years based on 2010 predictions. It was expected that First Nations would develop their own student information data systems through the new First Nations School Success Program Funding. There were two specific early consultation processes with a system that was still undergoing development and First Nations presented their feedback, documented concerns and were to develop a strategy to discuss an internal preparatory dialogue for Ontario First Nation communities. First Nations have not been adequately consulted to determine that the information requested is within the preview of the First Nation to meet all the information requested. Instead AANDC has directed its staff to advise First Nations to supply the report by July 15, 2013 or risk having funding disrupted. We fully agree that it is critical to have accurate reports that reflect and give a true picture of what is being expended within the postsecondary program, however we cannot ascertain the relevance of some of the information that is required, nor are we confident that the information is necessary if the main goal is to collect data on expenditures. One of the main concerns expressed by First Nations is, that the information being requested may infringe on the privacy act and that students information is not being protected or shared between government departments without obtaining privacy authorization on the use of this information. Although this concern has been expressed since the onset it has yet to be addressed. We have prepared a comprehensive list of concerns and recommendations that have been put forward by First Nations in Ontario regarding the new guidelines and hope that AANDC will address these concerns and provide a reasonable extension to respond and provide adequate training on a reliable information system that has been debugged of deficiencies. AANDC must realize that many First Nations are under resourced by and will require additional resources to meet the current EIS reporting system. It is reasonable and necessary to make adjustments to the system before of these guidelines thus to protect student information and extensions should be provided to all first nations without penalty while AANDC does a comprehensive review of the systems functionality and responds to the feedback from the information sessions. We look forward to your immediate response. Respectfully, Roger Chum President.

Attachment: Concerns and Recommendations Regarding the AANDC Post-Secondary Reporting Guidelines July 2013

CONCERNS AND RECOMMENDATIONS REGARDING THE AANDC POST SECONDARY REPORTING GUIDELINES Re: AANDC Post Secondary Reporting Guidelines and Deadlines It has been brought to our attention by many of our members that the new reporting guidelines for the post secondary student support program are flawed and the deadline to submit 2012-2013 and 2013-2014 is a monumental task if it is to be completed by the deadline of July 15, 2013. The feedback we have received so far on the guidelines are as follows: 1. IfINAConlywantstoknowhowmuchisbeingspentperstudentthenthereiseasierwaysofpresentingthisinformation.Itis unnecessarytoreportbysemesterbecauseitusuallydoesntfluctuateenoughtojustifytheadditionaltimeandenergyspenton reporting.OnaverageFirstNationsarespendingtwiceasmuchtimecompletingthereportsbycompletingthemonasemester bysemesterbasis. 2. Thedeadlinesareunacceptable.TheprogramwastobeimplementedinMarch2012inordertogiveenoughtimetocomplete thereporting.ThenewreportinginstructionsbookletalsoreflectsthatthestartwouldbeMarch2012(page4)howeverthere hasbeena16monthlapsefromMarch2012toJuly2013andreportsaretobecompletedinfourweeks.Instructionswerenot presentedtoFirstNationsuntilMay2013andwerenotavailableonthewebsiteuntilsuchtime.SomeFirstNationshave upwardsof400studentsandhavelimitedstafftotransferthedataforallstudentswithinthetimeframe. 3. Theapplicationdeadlinesoccuratabadtime.TheAMBEPostSecondaryProgramhasanapplicationdeadlineandallsponsor lettersareduetothecollege. 4. ThefallintakeforPostSecondaryoccursatthesametimethereportingisdue. 5. FirstNationsareindicatingthatthesystemissignificantlyflawedandtheyarehavingahighdegreeofdifficultyfiguringoutthe system.Wehavecommunitiesreportingthattheyhavespent20hourstroubleshootingtheEISformsbecauseofissues. 6. Reportsfromcommunitiesindicatethatbecauseofthevolumeofinformationbeingrequested,oncetheyhavecompletedthe task,theywerethenrequiredtosplitthepdfsintoseveralformsandsendinthereportbecausetheEISsystemcannothandle thevolume. 7. SomeFirstNationswhoHAVEstafftotallydedicatedtothisreportinghaveindicatedthatithastakenmonthstopreparethis report,butallFirstNationsarenotallasfortunatetohaveaRecordsManagerwhosmainjobisdatabasemanagement.Often thereportingrolefallsonthedeskoftheEducationDirector,Counsellorsorifyouareluckytheremaybeaneducationassistant withintheofficetohelpwithreporting. 8. Thereportingguidelinesallowsandasksforinformationbeyondthefiscalyear,thereforetheinformationbeingreportedisnota truepictureofwhatisbeingspentwithinthefiscalyear. 9. Therearegraveconcernsregardingthefreedomofinformationandprivacyact,inrelationtotheinformationthatisbeing requestedinthereportingguidelines. 10. ThereportingdocumentdoesnottakeintoaccountownsourcerevenuethatisbeingcontributedbytheFirstNation,therefore doesnottrulyreflecttheamountoffundingthatisbeingtargetedtowardspostsecondary.Howshouldthesestudentswhoare beingsupportedthroughownsourcerevenuebereported?Shouldtheybereportedasdeferredstudents,notfunded,orfunded fromothersource? 11. DuringthesecondtrainingsessionfacilitatedbyShellyFifesheindicatedtothegroupthatthereportswereonlytoreflectfrom September2012April2013,whichwillnotgiveanaccuratepictureofwhatwasactuallyspentbecauseitdoesnottakeinto accountthosestudentswhowerefundedfromApril2012toSeptember2012. Someoftherecommendationsthathavebeenputforwardtorectifytheproblemsincludethefollowing: 1. PriortoreportingtheFirstNationsmustbeassuredthattheinformationbeingprovidedtoAANDCdoesnotimpedeonstudents rightsandtheprivacyact. 2. Theinformationgatheredwillnotbeusedorsharedwithothergovernmentagenciesorotherorganizations. 3. Thatthesystembereviewedandthattherecommendationssetforwardbytheparticipantsoftheonlinemeetingsbe implementedandconcernsbeaddressedpriortoimplementationofthesystem. 4. ThatthedeadlinebeextendeduntilOctobertoallowFirstNationstheopportunitytopreparetherequiredreports.

July 2013-Ltr to Joanne Wilkinson. RDG-AANDC