Audit of Elementary and Secondary Education and Education Facilities

Internal Audit Report
Prepared by: Audit and Assurance Services Branch

November 2025

PDF Version (1,07 MB, 29 pages)

Table of contents

Acronyms

CIB
Community Infrastructure Branch
CFMP
Capital Facilities and Maintenance Program
DCI
Data Collection Instrument
ESDPP
Education and Social Development Programs and Partnerships
EIS
Education Information System
ESE
Elementary and Secondary Education
EF
Education Facilities
FNIIP
First Nations Infrastructure Investment Plans
HQ
Headquarters
ISC
Indigenous Services Canada
KPI
Key Performance Indicators
NFR
New Fiscal Relationship
O&M
Operations and Maintenance
PCF
Program Control Framework
REA
Regional Education Agreements
RIDB
Regional Infrastructure Delivery Branch
RO
Regional Operations
SPRF
School Ranking Priority Framework

Executive Summary

Education is part of a suite of multi-sectoral and multi-departmental programming supporting First Nation students on reserve, including infrastructure, Jordan’s Principle, health, mental health, and Indigenous early learning and childcare. Elementary and secondary education is delivered through the Elementary and Secondary Education (ESE) Program within the Education and Social Development Programs and Partnerships (ESDPP) Sector, while infrastructure programming is provided through the Education Facilities (EF) Program, which is part of the Community Infrastructure Program/Capital Facilities and Maintenance Program (CFMP), and delivered by the Regional Operations (RO) Sector.

Access to adequate education facilities can support First Nation students in achieving secondary education outcomes comparable to non-Indigenous students. To build and maintain facilities that meet evolving needs, changes in educational programming and enrolment trends must inform investment decisions.

From FY 2020-21 to FY 2023-24, the ESE Program spending averaged $2.6 billion annually, supporting approximately 118,000 students (about $22,000 per student), while the EF Program averaged $400 million annually (see Table 3). Additional funding is also provided through other departmental programs such as Jordan’s Principle and the New Fiscal Relationship (NFR) Grants.

The objective of the audit was to assess the adequacy of the management control frameworks supporting the delivery of the ESE and EF Programs.

The audit found elements of a management control framework were in place, including documented roles and responsibilities, national and regional communication channels, funding allocation processes, and performance frameworks. While these foundational elements were in place, several areas where management control practices and processes could be improved were identified, resulting in the following recommendations:

  1. The Assistant Deputy Minister of ESDPP and the Senior Assistant Deputy Minister of RO should review and document coordination processes between the ESE and EF Programs, including regional offices. This should include clearly defined roles and responsibilities for headquarters (HQ) and regional offices in implementing decisions that affect both programs, as well as consideration of formal governance or oversight mechanisms to support ongoing collaboration, decision-making, and information sharing across both programs.
  2. The Assistant Deputy Minister of ESDPP should formalize the model risk and control framework, including policies and procedures, documentation standards, approval authorities, validation, review, and change control processes for the ESE Program Interim Regional Funding Formulas. The framework should also include a periodic independent review or challenge function to assess model accuracy, assumptions, and performance.
  3. The Senior Assistant Deputy Minister of RO should review and, as appropriate, update the Program Control Framework and School Prioritization Ranking Frameworks to ensure that they are based on relevant and complete data. Where applicable, input from the Assistant Deputy Minister of ESDPP should be considered. Ensure documentation of project selection rationale, and explore opportunities to improve data access and integration between the EF and ESE Programs to support prioritization decisions.
  4. The Assistant Deputy Minister of ESDPP, with input from the Senior Assistant Deputy Minister of RO, where applicable, should develop materials that explain how O&M (Operations and Maintenance) funding for education infrastructure is calculated through the Interim Regional Funding Formulas (excluding teacherages, federal schools, and student residences), and review oversight responsibilities for Maintenance Management Plans.
  5. The Assistant Deputy Minister of ESDPP should consult with stakeholders within other Indigenous Services Canada (ISC) programs that deliver funding related to elementary and secondary education programming to review their Program Information Profiles (PIPs), to consider how the work of these related programs impacts, directly or indirectly, the education performance measurement framework, and to identify a horizontal approach to capture all the variables impacting education results.
  6. The Senior Assistant Deputy Minister of RO should establish or enhance, where applicable, program indicators that demonstrate the impact of investments in education infrastructure on education outcomes, using relevant and available data. Where appropriate, this work should be coordinated with the Assistant Deputy Minister of ESDPP to support alignment across related performance frameworks.

Statement of Conformance

The audit conforms with the Institute of Internal Auditors' Global Internal Audit Standards and the Government of Canada's Policy on Internal Audit, as supported by the results of the Quality Assurance and Improvement Program.

Management’s Response

Management is in agreement with the findings, has accepted the recommendations included in the report, and has developed a management action plan to address them. The management action plan has been integrated into this report.

1. Context

Elementary and secondary education is under the jurisdiction of provinces and territories, with the exception of education for First Nations students ordinarily resident on reserve. The Government of Canada has a federal role in supporting First Nations education and related programming. For First Nations students in the North (Yukon / Northwest Territories) and First Nations students ordinarily resident off reserve, as well as Inuit and Métis students, education is provided by their respective province or territory. There are no reserves established in Nunavut and as such is not covered by these programs.

Education is part of a suite of multi-sectoral and multi-departmental programming to support First Nations on reserve including infrastructure, Jordan’s Principle, health and mental health programming, and Indigenous early learning and childcare, amongst others. First Nations elementary and secondary education is delivered through the Elementary and Secondary Education (ESE) Program of Indigenous Services Canada (ISC). Education infrastructure is provided through the Education Facilities (EF) program, which is within the Capital Facilities and Maintenance Program (CFMP) under Regional Operations (RO) of ISC.

Elementary and Secondary Education Program

Overview

The ESE Program supports elementary and secondary education for First Nations students, schools, and communities by working in partnership with First Nations on a nation-to-nation basis, to support First Nations and First Nations-mandated organizations to establish education systems over which First Nations will exercise control. The broader Education Program also includes the Post-Secondary Education Program. The objective of the ESE Program is to provide funding to support First Nations’ control of First Nations education including the delivery of kindergarten (starting at age 4) to grade 12 educational services for all eligible students ordinarily resident on reserve. The ESE Program aims to create a financially stable environment for First Nations education, enabling better quality and consistent supports for students, schools, educators, communities, and First Nations education organizations, as well as conditions that help improve student outcomes. The program strives to achieve the following outcomes:

  • Education services and resources better reflect students’ needs, culture and language.
  • First Nations have increased education system capacity to meet their needs and priorities.
  • First Nations students participate and progress in their elementary and secondary education.
  • First Nations students on reserve achieve levels of secondary education comparable to non-indigenous students in Canada.

Consistent with First Nations control of First Nations education, the ESE Program provides funding for service delivery models adaptable to local context and priorities. Education programming for First Nations students may be delivered through First Nations administered/operated schools, Private schools, Provincial schools and Federal schools.

The ESE Program funds the design and delivery of education to support culturally appropriate education with respect to First Nations’ methods of teaching and learning, as well as Regional Education Agreements (REAs) responding to First Nations education goals and priorities.

In addition to the core ESE Program, ISC also offers six targeted proposal-based programs providing specific components for student success (see Table 1). Each targeted proposal-based program has their own respective National Program Guidelines. Targeted proposal-based programs are where ISC solicits and receives funding requests via proposals from recipients. Funding for these programs is based on the proposal approvals by ISC in accordance with the criteria outlined in their own National Program Guidelines.

Table 1: Targeted Proposal-Based Education Programs
Reference 1

Program Name

Education Partnerships Program

Summary

Designed to promote collaboration among First Nations, provinces, ISC, and other stakeholders. It aims to advance First Nations student achievement in First Nations and provincial schools.

Reference 2

Program Name

High-Cost Special Education Program

Summary

Provides additional investments to recipients who provide services for students who ordinarily live on reserve and whose high-cost special education needs cannot be met within the current resources that are made available for the general student population.

Reference 3

Program Name

Cultural Education Centres ProgramFootnote 1

Summary

Provides funding to First Nations and Inuit cultural education centers on reserves or Inuit settlement regions to support the development and promotion of First Nations and Inuit cultural heritage.

Reference 4

Program Name

Inuit Cultural Education Centres Grant

Summary

Provides grants to Inuit individuals as well as community- based Inuit cultural education centres to support the development and promotion of Inuit cultural heritage.

Reference 5

Program Name

Research and Learning Program

Summary

Supports research projects that contribute to the growing body of evidence on educational initiatives across Canada that are positively impacting First Nations students and their educational outcomes.

Reference 6

Program Name

Innovation in Education Program

Summary

Supports innovative projects that allow First Nations to try new academic programs, strategies, and technologies, and develop evidence-based solutions that can be shared with other schools.

Departmental Roles and Responsibilities for Delivering the ESE Program

ISC’s ESE Program is managed and coordinated at the national level by Headquarters (HQ) Education Branch (HQ Education Program) within the Education and Social Development Programs and Partnerships (ESDPP) Sector and is supported by regional offices within the RO Sector.

Overview of ESE Program Funding

Following extensive engagements with First Nations in 2016 and 2017, on April 1, 2019, ISC implemented a co-developed funding and policy approach for First Nations education on reserve resulting in the transformation of First Nations education. The transformation consolidated many older targeted programs into the core formulas; there was no longer a national formula, rather a series of provincially comparable regional funding formulas. Additional investments were announced in Budget 2021 for before- and after-school programming and further refinements to the funding formulas. The transformation approach to funding is comprised of interim regional funding formulas and REAs based on the guiding principles of provincial comparability, predictability, stability, transparency, flexibility in how funding is spent, and locally and regionally specific. REAs are tailored to the local or regional context and needs of First Nations and formalize Canada’s commitment to support First Nations to design, implement, and manage their own education systems. REAs may include additional funding beyond the interim regional funding formulas to support the achievement of the education system outcomes.

As noted in documentation provided by the ESE Program, since fiscal year 2015-16, funding for the ESE Program has increased by approximately 98% in the transformation of First Nations education. In addition to ESE Program funding, education funding is also delivered through the New Fiscal Relationship (NFR) Grant. The table below presents a summary of funding provided for the core ESE Program over the last four fiscal years (Vote 10 and Grant).

Table 2: Core ESE Program and NFR Funding
Type 2020-21 2021-22 2022-23 2023-24Table note 1 Grand Total
ContributionTable note 2 $1,956,704,730 $2,265,334,284Table note 3 $2,283,690,658 $2,428,243,689 $8,933,973,361
NFR Grant $305,274,608 $359,061,572 $408,360,258 $495,422,508 $1,568,118,946
Grand Total $2,261,979,338 $2,624,395,856 $2,692,050,916 $2,923,666,197 $10,502,092,307
Table note 1

Data provided through written representation by ESDPP on September 24, 2024.

Return to table note 1 referrer

Table note 2

Includes the funding provided through Regional Education Agreements.

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Table note 3

Includes COVID-19 safe school reopening funding.

Return to table note 3 referrer

Education Facilities Program

Overview

First Nations own and operate education facilities on reserve and are responsible for managing projects to renovate or build new facilities. ISC provides funding to First Nations to build new education infrastructure, renovate and expand existing facilities, and operate and maintain teacherages, student residencies and federal schools. Education infrastructure can include schools, storage buildings, teacherages, and the school site (for example, sports fields, outdoor learning spaces, play structures).

EF Program funding is provided to First Nations on-reserve and to First Nations and other eligible recipients on Crown land or First Nations land to:

  • Plan, design, construct/acquire, renovate, repair, and replace federally or band- operated elementary and secondary education facilities (including school buildings, teacherages, and student residences), and related facility services.
  • Acquire furniture, equipment, and furnishing for schools being constructed, expanded, or renovated.
  • Acquire replace, and repair furniture, equipment, and furnishing for teacherages, federal schools and student residences.
  • Acquire buses for the transportation of students to supported school facilities.
  • Identify education facility needs and develop education facility plans; and
  • Design maintenance management practices.

Departmental Roles and Responsibilities for Delivering the EF Program

The EF Program is managed at ISC’s HQ through the Regional Infrastructure Delivery Branch (RIDB), and implemented through regional offices, all within the RO Sector. The Community Infrastructure Branch (CIB) is lead on the Education Infrastructure policy suite with RIDB being the technical lead.

Overview of EF Funding

Funding is provided for education facilities through A-based funding (Annual Based) and B-based funding (targeted, time limited, not guaranteed) sources. A-based funds for school infrastructure are mainly used to support: minor capital projects of existing education facilities and smaller scale renovations and replacements; program continuation, by funding feasibility studies and at times designs; and Operations and Maintenance (O&M) funding for teacherages, student residences and federal schools. A-based funds may also be used to fund construction and renovation projects but are typically not sufficient to support these projects independently.

B-Base funding is targeted and designed to fund priority health and safety projects and initiatives. It is provided under individual budget authorities and is by nature "sun-setting", that is it expires at a pre-determined budget end date. While not guaranteed, this funding can be renewed through the federal budget process. In addition to EF Program funding, limited education facilities funding may also be provided through the NFR Grant for NFR recipients. The table below presents a summary of funding provided for the EF Program in the last four fiscal years (Vote 10 and NFR Grant).

Table 3: EF Program and NFR Funding
Type 2020-21 2021-22 2022-23 2023-24 Grand Total
A-Base (ongoing funds) $89,163,208 $68,851,127 $99,214,129 $144,884,187 $402,112,651
B-Base (sun- setting funds)Table note * $242,201,188 $300,352,801 $434,816,500 $214,173,197 $1,191,543,686
NFR Grant $3,800,320 $4,240,533 $4,561,998 $2,471,655 $15,074,506
Grand Total $335,164,716 $373,444,461 $538,592,627 $361,529,039 $1,608,730,843
Table note *

B-base funding included funding for COVID-19 school reopening and school ventilation initiatives. B-base funding during the noted four fiscal years included funding from Budget 2014 (sun-setted), Budget 2016 (sun-setted), and Budget 2021 which will sun-set in March 2025.

Return to table note * referrer

2. About the Audit

The Audit of Elementary and Secondary Education and Education Facilities was included in the Indigenous Services Canada Risk-Based Audit Plan for 2022-23 to 2023-24, which was presented to the Departmental Audit Committee and approved by the Deputy Minister in June 2022.

2.1 Why it is important

The audit was identified as a priority because the Department identified several risks for education services related to the following:

  • The importance of governance and coordination of the various sectors involved in delivering education;
  • The processes to allocate funding given the high dollar value of education funding; and
  • The importance of performance in being able to understand how progress towards education is being achieved and demonstrating progress to Canadians and Departmental stakeholders.

Given that access to adequate education facilities can contribute to on-reserve First Nation student achievement of levels of education comparable to non-Indigenous students in Canada, it is important that the Elementary and Secondary Education (ESE) and Education Facilities (EF) Programs are coordinating to ensure that there is appropriate space for First Nations to deliver their education programs, and that funding allocation processes, as well as processes to measure outcomes for ESE and EF Programs are designed and implemented.

2.2 Audit Objective

The objective of the audit was to assess the adequacy of the management control frameworks for delivering the ESE and the EF Programs. Specifically, the audit provided assurance that:

  • Appropriate roles, responsibilities and accountabilities are in place to direct, and oversee the management of the ESE Program and the EF Program;
  • Effective processes are in place to support collaboration and coordination between the ESE Program and the EF Program; and
  • Adequate processes are in place for determining education funding allocations and for measuring progress towards education objectives and commitments.

2.3 Audit Scope

The scope of the audit covered Indigenous Services Canada (ISC)’s processes and activities within the ESE Program and the EF Program, both at Headquarters (HQ) and in the regions, that support the delivery of the ESE Program and the collaboration and coordination between the ESE and the EF Programs. More specifically, the audit looked at the assignment of the roles, responsibilities, accountabilities and oversight mechanisms of the programs, and the processes that support the collaboration and coordination of the ESE Program and the EF Program. The audit examined the management control frameworks, including the processes and procedures in place to measure the achievement of the ESE Program objectives and the education facilities infrastructure commitments as well as in the determination and allocation of ESE and EF funding. The audit focused on funding activity covering the period from April 1, 2020, to March 31, 2023. Audit fieldwork was completed from January 2024 to July 2024, and considered elements of the management control framework in place at the time the fieldwork was completed.

Regional offices included in scope were Ontario, Manitoba, Saskatchewan, and Alberta. These four regions represent over 70% of the funding allocations and expenditures for both the core ESE Program and the EF Program between the 2020-2021 and the 2022- 2023 fiscal years. The four regions fund the highest number of students under ESE Program funding. The four regions selected also provide coverage on the different types of schools that are attended by students funded through the ESE Program.

The audit did not cover processes and activities in place within funding recipient organizations, including First Nations, First Nations organizations, Tribal Councils, provincial, territorial, and municipal governments, non-governmental organizations and businesses. The six targeted proposal-based education programs were excluded from the scope of the audit as these programs constitute 7% of total ESE Program expenditures for the 2022-23 fiscal year. Other infrastructure sub-programs (i.e. water and wastewater, housing, etc.) under the Capital Facilities and Maintenance Program (CFMP) were not in-scope.

2.4 Audit Approach and Methodology

The audit was conducted in accordance with the requirements of the Treasury Board Policy on Internal Audit and followed the Institute of Internal Auditors' Global Internal Audit Standards. Additionally, the audit considered the requirements stated within the Treasury Board Policy on Transfer Payments as well as the Directive on Transfer Payments. The audit examined sufficient, relevant evidence and obtained sufficient information to provide a reasonable level of assurance in support of the audit conclusion. The probability of significant errors, fraud, non-compliance, and other exposures was assessed and documented during the planning phase.

The audit was performed from June 2023 to October 2024 and consisted of three phases: planning, conduct and reporting. The audit procedures included interviews with program officials involved in the design and delivery of the ESE and EF Programs, walkthrough of processes and procedures used to determine funding allocations, inspection of relevant documentation and artifacts, and testing.

3. Key Findings and Recommendations

3.1 Elementary and Secondary Education Governance

Background

A program governance framework provides the structures, policies, and processes used to assign roles and decision-making authorities, oversee program implementation, and report on performance.

Although the Elementary and Secondary Education (ESE) and Education Facilities (EF) Programs operate under separate sectors and authorities, there is intersection between the programs. For example, education infrastructure funding supports the delivery of broader social and economic services. In education specifically, adequate facilities can help First Nation students achieve outcomes comparable to non-Indigenous students in Canada. Likewise, planning education infrastructure requires current data on programming and enrolment. Decisions made in one program, such as funding changes or policy reforms, can significantly impact the other.

As education funding is delivered through multiple departmental areas, clearly defined roles, responsibilities, and communication processes are essential. They ensure oversight of education funding streams and their impact on outcomes. Without proper coordination and information-sharing, actions like changing education programs without matching space, budget or building schools without resources to operate them can have unintended consequences.

The audit expected to find a governance framework with clearly defined roles and accountabilities for both programs, along with processes to support coordination between them. Given the funding involved and the operational overlap, the audit also expected:

  • Organizational structures with documented and implemented roles and responsibilities; and
  • Oversight bodies and communication channels to coordinate major decisions and new initiatives across the two programs.

Risks

There is a risk that roles, responsibilities, and accountabilities for the ESE and EF Programs may not be clearly defined or communicated, which could affect program delivery and the Department’s ability to achieve desired education outcomes.

There is also a risk that there may not be sufficient alignment and coordination between the ESE and EF Programs, both regionally and nationally, limiting their ability to address interconnected education needs in Indigenous communities.

Finding

Organizational Structure

An effective organizational structure establishes clear responsibilities, delegated authorities, and communication lines to support coordination across sectors. For the ESE and EF Programs, this is critical to align policy development, funding, stakeholder engagement, and performance monitoring.

ESE Program

The ESE Program is coordinated nationally by the Headquarters (HQ) Education Program in the Education and Social Development Programs and Partnerships (ESDPP) Sector and implemented regionally by the Regional Education Program under the Regional Operations (RO) Sector. Roles and responsibilities are partially documented through policy instruments such as the Budget Management Regime (BMR), Funding Approach Management Regime (FAMR), National Program Guidelines, and the ESDPP Sector Business Plan. For example, the BMR outlines roles for determining annual funding allocations and sets expectations for performance, delivery, and recipient reporting.

However, there does not exist a formal governance framework clarifying authorities between HQ and regions, and setting program direction. While regional structures exist with assigned responsibilities and established reporting relationships to RO Sector at HQ, the audit found no formal reporting relationship or documented accountabilities between ESDPP and RO. A governance structure created in response to the 2017 ESE internal audit existed pre-education transformation and has not been updated. Since the transformation, HQ has taken the lead in funding allocations via interim regional funding formulas, reducing regional flexibility. No updated program control framework has been established to reflect these changes.

The shift has created challenges. For instance, HQ noted cases where regional offices did not follow funding coding directions or did not allocate funds in ways consistent with HQ workbooks. HQ has implemented oversight processes to detect and correct these issues. Regional staff also expressed concern that centralized funding decisions may affect their relationships with First Nations partners. In this context, a clear governance framework with defined roles, authorities, and accountabilities would help mitigate confusion, avoid conflicting priorities, and strengthen program delivery and relationships with First Nations.

EF Program

The EF Program is managed nationally by Regional Infrastructure Delivery Branch (RIDB) and implemented regionally, all within the RO Sector. It operates under the Capital Facilities and Maintenance Program (CFMP) umbrella and is guided by the CFMP Program Manual and Program Control Framework (PCF), last updated January 1, 2024. The PCF defines roles for RIDB, Community Infrastructure Branch (CIB), and regional offices. RIDB manages national EF funding and leads technical guidance on education infrastructure. CIB is responsible for policy tools and updates. Regional offices manage day-to-day delivery, including planning and executing First Nations Infrastructure Investment Plans (FNIIPs). The PCF also defines oversight committees and mandates collaboration across sectors and with other departments.

However, the PCF does not define how EF and ESE should coordinate. While some collaboration is documented, responsibilities for coordination between the programs are not formalized. Defining these roles explicitly would support stronger alignment, oversight, and decision-making across the two programs.

Oversight Bodies and Communication Channels

Oversight is essential to monitor program results, ensure alignment with policies, and support informed decision-making. Given the structural and operational interdependencies between ESE and EF, coordinated oversight ensures that data, plans, and decisions are shared appropriately and not developed in isolation.

The audit found multiple oversight bodies related to CFMP and EF, such as the Education Facilities National Technical Review Committee, National Infrastructure Directors Committee, and others. However, no formal oversight body exists at the national level to coordinate ESE and EF. Some coordination takes place through monthly meetings between HQ Education and RO Infrastructure DGs, and quarterly national meetings that include updates on infrastructure projects and shared data. ESE officials also attend biweekly EF Program policy meetings with the Assembly of First Nations (AFN), and monthly DG-level meetings are held between RO, CIB, and ESE with AFN participation.

At the regional level, some offices have defined governance structures for collaboration, and the audit found examples of information-sharing between ESE and EF, such as on enrolment data and infrastructure projects. However, in the absence of a formal national governance mechanism, information is shared inconsistently and often manually, increasing the risk of error or outdated data being used. The audit also found limited direct access to relevant education data across programs and inconsistent communication and use of performance information to inform funding decisions and program improvements.

These gaps raise the risk of siloed decisions, such as introducing programming that requires new infrastructure (e.g., full-day kindergarten) or capital (e.g., school buses) – without coordinated planning. A formal framework with clear guidance, defined expectations, and oversight bodies would strengthen decision-making and communication across both programs.

Recommendation:

  1. The Assistant Deputy Minister of ESDPP and the Senior Assistant Deputy Minister of RO should review and document coordination processes between the ESE and EF Programs, including regional offices. This should include clearly defined roles and responsibilities for HQ and regional offices in implementing decisions that affect both programs, as well as consideration of formal governance or oversight mechanisms to support ongoing collaboration, decision-making, and information sharing across both programs.

3.2 Funding Determinations

Background

To achieve its intended results, the Department requires sound investment decisions and appropriate funding allocations.

ESE Program core funding averages approximately $2.6 billion annually and supports about 118,000Footnote 2 students. Most of this funding is allocated through interim regional funding formulas, which are based on provincial comparability principles. The goal is to provide predictable base funding comparable to what students in provincial education systems receive. Funding may also be delivered through regional education agreements (REAs), which address First Nations priorities and often include additional resources beyond formula-based amounts. REAs support progress toward First Nations-designed education systems and, ultimately, service transfer and self-government.

The ESE Program aims to expand the use of transformative funding models like REAs or school boards, which will eventually replace the Interim Regional Funding Formulas. As of 2022-23, 206Footnote 3 First Nations received funding through a transformative model, though the Interim Regional Funding Formulas remain the primary mechanism.

EF Program funding averages about $400 million annually and comes from:

  • A-base (annual): Minor capital projects (e.g., small renovations, school buses), allocated through formulas for all capital assets under CFMP; and
  • B-base (targeted/needs-based): Major capital projects (e.g., new school construction or large-scale renovations).

To ensure that funding decisions are reliable, both ESE and EF models require accurate data inputs, sound assumptions, and reliable calculation methods. Additionally, many data sources, such as school size and enrolment, are relevant to both programs. Funding allocations are therefore more effective when data is integrated across ESE and EF.

Accordingly, the audit expected:

  • Accuracy and completeness of data: Processes in place to validate the accuracy and completeness of data used in funding allocations; and
  • Integration of relevant data across ESE and EF: Processes to support the use of shared or complementary data in allocation decisions.

Risks

There is a risk that ESE and EF funding decisions may rely on inaccurate or incomplete data, such as nominal roll figures, resulting in over- or under-funding to recipients.

Additionally, there is a risk that the ESE Program may not provide sufficient visibility into areas (e.g., funding) relevant to facility upkeep, which could impact the EF Program’s decisions.

Findings

Interim Regional Funding Models – Complexity and Risk

Interim regional funding formulas are based on provincial education comparators and are developed and maintained by the HQ Education Program. HQ analysts perform annual updates using inputs such as nominal rollFootnote 4 data, provincial funding rates, and school size. These models are implemented in Excel workbooks, often supported by narrative documents outlining data sources, assumptions, and methodology. Relevant policy instruments include the Budget Management Regime, National Program Guidelines, and the program’s terms and conditions.

The audit found these funding models to be highly complex, with some containing up to 50 interlinked worksheets. Inputs were sourced from a variety of platforms – including Excel files, PDF documents, and public websites – and were manually re-entered each year. Manual updates, combined with assumptions and proxies used to address data gaps, introduced significant risk of data entry and calculation errors.

There was no standardized approach across regional models. While differences are expected due to provincial comparability objectives, the structure, functionality, and output formatting of the workbooks varied. At the time of audit, a standardization initiative had been launched but remained in draft.

ESE analysts are responsible for operating these workbooks and calculating funding amounts. However, the high degree of customization and complexity requires specialized regional knowledge, which has created dependencies on a small number of staff. Interviewees from both HQ and regional offices noted that staff turnover has exacerbated these challenges and raised concerns about knowledge retention and risk of undetected errors.

Controls and Governance Over Funding Models

The audit expected model governance controls to be in place, including those related to data input, calculations, results validation, and access management.

Some controls were observed. Each region’s funding model is accompanied by a narrative document that outlines key data elements, proxies, and assumptions. Input data is reviewed by the HQ data team and regional staff prior to use, and a secondary review by another HQ analyst includes reasonability checks, year-over-year comparisons, and confirmation that updates were correctly applied.

However, gaps remain in model governance. While changes to formulas require Director- level approval, there is no formal change control process. Evidence of testing or documentation confirming changes were implemented as intended was not consistently retained. There were also no protections such as password restrictions, version control, and audit trails.

Assumptions and proxies were listed in model documentation, but the rationale behind their use and assessments of their reasonableness were limited. Sensitivity analyses, which can evaluate how assumptions affect funding outcomes, were not observed.

Additionally, there is no independent challenge or validation function to assess model performance, test assumptions, or verify the soundness of the calculation logic. The absence of such a function increases the risk of flawed formulas going undetected.

These risks are not theoretical. The audit noted that over $61.4 million in errors were identified through the Department’s verification process over three years – $33.7 million of which were linked directly to calculation errors. Strengthening model governance would reduce the likelihood of such financial and reputational risks.

Funding Errors and Corrective Measures

The audit also expected to see mechanisms to detect and correct errors in addition to preventing them. A verification step is conducted by HQ’s data team on nominal roll data uploaded to the Education Information System (EIS). In 2019, the Department implemented a formal errors and omissions process, which allows HQ, regional staff, and First Nations recipients to report technical funding errors, such as coding issues, data gaps, or incorrect calculations, at any point during the annual funding cycle. The table below summarizes the type and value of errors and omissions detected across all regions over the past three fiscal years.

Table 4: Reported Errors and Omissions in Education Funding: Types, Values, and Frequency
Errors and omission type FY 2021-22 to FY2023-24Table note * Number of Errors Identified
ESE – Miscalculation $33,782,630 40
Other – Missing Data $13,586,047 9
FAU – Transfer Error $6,447,484 1
Regional data error $3,476,837 8
NR was submitted late $1,300,000 1
ODT – Missing Data $1,216,858 5
ICMS – Data Update Delay $622,678 3
Exceptional Circumstance $521,831 7
EIS Error $498,930 1
NR information was submitted late $10,135 1
Total $61,463,430 76
Table note *

It was noted that no errors or omissions were detected by the HQ Education Program in 2020–21.

Return to table note * referrer

The audit observed that this process is working and that identified errors are tracked and linked to corrective actions, including funding reallocations and, where applicable, formal decision notes. The majority of errors resulted in allocation issues. Over the audit period, $59.8 million (0.6% of annual formula funding) in errors were tied to under-funding and $1.6 million (0.02% of annual formula funding) to over- funding.

Although this represents a small portion of total funding, it underscores the value of strong preventative controls. Post-allocation corrections are resource-intensive, and the audit team was informed that some errors may go undetected despite the process being in place.

Funding Determinations – EF Program and Data Integration Challenges

EF Program funding decisions are governed by the CFMP Program Control Framework and Program Manual. Most allocations come from B-base targeted funding, based on project prioritization using the School Ranking Priority Framework (SPRF) and the FNIIP. The SPRF uses various data sources, including self-reported school conditions (via Data Collection Instrument (DCI)), enrolment figures, and proximity to off-reserve schools.

However, the audit observed that the SPRF may not capture all relevant factors. It prioritizes communities with existing schools and does not consider special education students. While it rewards low-condition schools, it does not account for how much Operations and Maintenance (O&M) funding has been invested in maintaining the facility. This may unintentionally disincentivize good maintenance practices. Consultations with First Nations to reform the SPRF were ongoing at the time of audit.

Although the prioritization process is formally documented, it was observed that decisions are sometimes driven by B-base timelines, with regions instructed to focus on shovel-ready projects. Regardless of timing pressures, prioritization decisions should be clearly documented with rationale to demonstrate due diligence, particularly in the event of scrutiny.

The audit also assessed how data is shared and integrated between the ESE and EF Programs. Data such as nominal roll figures and school size are used by both programs in their respective funding decisions. However, key systems are not integrated. ESE Program data resides in the EIS, while EF Program data is housed in the Integrated Capital Management System (ICMS). Access to these systems is restricted to each program’s staff. As a result, data must be manually extracted and shared across programs, increasing the risk of delays, errors, and inefficiencies.

The audit also noted that quality issues with nominal roll data (as outlined earlier in this section) may impact EF Program calculations when they use this data for school size estimates.

One additional area of concern relates to O&M funding. Since 2019, O&M for First Nations–owned schools has been delivered by the ESE Program through its interim regional funding formulas. The National Program Guidelines require recipients to maintain education infrastructure in line with Indigenous Services Canada (ISC)'s infrastructure directives including the O&M Directive and the Protocol for ISC-funded Infrastructure and to have maintenance management plans. However, there are no requirements specifying how much O&M funding must be spent on maintenance, and the ESE Program does not collect or track how the funds are used.

This lack of visibility limits the EF Program’s ability to assess how well facilities are maintained or to provide guidance to recipients. Inadequate maintenance investment may reduce the useful life of education facilities and increase reliance on capital funding for major repairs or replacements.

Recommendations

  1. The Assistant Deputy Minister of ESDPP should formalize the model risk and control framework, including policies and procedures, documentation standards, approval authorities, validation, review, and change control processes for the ESE Program Interim Regional Funding Formulas. The framework should also include a periodic independent review or challenge function to assess model accuracy, assumptions and performance.
  2. The Senior Assistant Deputy Minister of Regional Operations should review and, as appropriate, update the Program Control Framework and School Prioritization Ranking Frameworks to ensure that they are based on relevant and complete data. Where applicable, input from the Assistant Deputy Minister of ESDPP should be considered. This should include ensuring documentation of project selection rationale, and exploring opportunities to improve data access and integration between the EF and ESE Programs to support prioritization decisions.
  3. The Assistant Deputy Minister of ESDPP, with input from the Senior Assistant Deputy Minister of Regional Operations where applicable, should develop materials that explain how O&M funding for education infrastructure is calculated through the Interim Regional Funding Formulas for education infrastructure (excluding teacherages, federal schools, and student residences), and review oversight responsibilities for Maintenance Management Plans.

3.3 Measuring Progress Towards Educations Targets and Commitments

Background

In 2019, ISC established a new policy framework for First Nations elementary and secondary education aimed at fundamentally improving how education funding is delivered. Consistent with the Treasury Board Policy on Results, reliable, relevant, and up-to-date data, informing valid indicators, is essential for evidence-based decision- making. This includes improving education outcomes for First Nations, assessing the effectiveness of departmental interventions, and informing sound infrastructure investment decisions.

The performance of other ISC programs can also influence education outcomes. For example, inadequate education infrastructure can negatively impact student achievement by limiting quality learning environments. Other departmental initiatives, such as those related to health, housing, and social services, also contribute to education outcomes. Notably, education supports through Jordan’s Principle have steadily increased and now represent a significant portion of education-related funding to First Nations.

Given these intersecting influences, the audit expected the Department to have processes in place to collect relevant and reliable data that supports valid indicators and measurable targets, enabling the monitoring and reporting of progress toward education outcomes.

Specifically, the audit expected to see:

  • A performance measurement framework to assess whether ESE and EF Program interventions are meeting education objectives;
  • Processes to ensure the accuracy and completeness of data used in measuring outcomes; and
  • A formal approach to using performance results to support program improvements.

Risks

There is a risk that performance measurement metrics may not fully reflect whether the ESE and EF Programs’ grants and contributions interventions are achieving their intended education outcomes. There is also a risk that misalignment between indicators and data requirements, as well as data quality or completeness issues, may limit the usability of performance results. In addition, there is a risk that performance information may not be used effectively to inform improvements to the ESE and EF Programs.

Findings

Performance Measurement Framework

The audit observed that both the ESE and EF Programs have documented performance measurement frameworks, including PIPs that outline logic models, expected outcomes, and inventories of key performance indicators (KPIs). The ESE Program’s PIP was last updated in FY2023-24. The EF Program’s performance measurement is embedded within the broader Community Infrastructure Program PIP, also updated in FY2023-24.

While each program has its own framework, the audit did not observe coordination between ESE and EF performance results. This limits the Department’s ability to assess how infrastructure supports – such as safe and healthy schools – contribute to educational outcomes. Management acknowledged this disconnect and indicated that the ESE Program is in early exploratory discussions with other programs on improving alignment between performance indicators.

The audit also found that other departmental initiatives – including Jordan’s Principle and the New Fiscal Relationship (NFR) 10-year grant – deliver significant education-related funding but are not integrated into ESE Program performance reporting. Between 2021–22 and 2023–24, education-related funding under Jordan’s Principle totaled $566.8M, while NFR education-related funding amounted to $1.07B. Combined, these streams represented 25% of ESE Program funding during that period. The impact of this funding on education outcomes was not captured within current performance frameworks, limiting the Department’s ability to isolate the effectiveness of ESE interventions.

Accuracy and Completeness of Performance Data

The ESE Program currently uses 19 KPIs to measure immediate, intermediate, and ultimate outcomes. Data sources include Statistics Canada census data and self-reported First Nation data collected through Departmental Collection Instruments (DCIs), such as the Nominal Roll Student and Education Staff Census Report and the First Nation Elementary and Secondary Education Advancement Report.

The audit observed that some data quality controls are in place. For instance, data uploaded into the EIS is subject to business rules that flag errors for correction. Regional staff review submitted data before accepting reports, and HQ Education Program’s Operational Data team performs further validation, particularly for data used in funding allocations. Additionally, recipient audits conducted by the Chief Finances, Results and Delivery Officer may also assess reported data.

Despite these measures, the reliability of education data is largely dependent on the quality of self-reported information. Over the audit period, the Nominal Roll DCI was received and accepted in 94% of cases. However, significant completeness gaps were observed for the First Nation Elementary and Secondary Education Advancement Report, which is a key input for 10 of the 19 KPIs.

Table 5: Compliance Rates for Key Departmental Collection Instruments
Data Collection Instrument Average compliance rate based on accepted reports
(FY20-21 to FY22-23)Table note *
Nominal Roll Student and Education Staff Census Report 94%
First Nation Elementary and Secondary Education Advancement Report 38.5%
Table note *

Data only for the four in-scope regions

Return to table note * referrer

These gaps impact the Program’s ability to calculate and report valid performance indicators. In cases where reporting compliance is low, the Program may include narrative qualifiers (e.g., % of reports accepted) or omit results entirely due to reporting cycle misalignment between the school and fiscal year.

Use of Performance Measurement Results

KPI results are used in multiple ways. Seven of the 19 KPIs are publicly reported through the Departmental Results Report and GC InfoBase. Other KPIs are used internally to support policy development, budget proposals, and Cabinet submissions.

The Program indicated that performance data is used to track progress toward objectives such as closing the education attainment gap. However, low reporting compliance reduces the usefulness of this data – particularly for communicating with Indigenous partners, government stakeholders, and the Canadian public. It also limits the Department’s ability to make evidence-informed improvements.

The audit was informed that KPIs are reviewed to ensure continued relevance. In 2024-25, the ESE Program launched an initiative to review its KPIs and associated DCIs. The initiative includes regional engagement and may involve consultation with First Nations partners. This presents an opportunity to improve data quality and reporting alignment by reinforcing shared benefits of performance reporting on education programs delivered on reserve.

Recommendations

  1. The Assistant Deputy Minister of ESDPP should consult with stakeholders within other ISC programs that deliver funding related to elementary and secondary education programming to review their PIPs, to consider how the work of these related programs impacts, directly or indirectly, the education performance measurement framework, and to identify a horizontal approach to capture all the variables impacting education results.
  2. The Senior Assistant Deputy Minister of RO should establish, or enhance where applicable, program indicators that demonstrate the impact of investments in education infrastructure on education outcomes, using relevant and available data. Where appropriate, this work should be coordinated with the Assistant Deputy Minister of ESDPP to support alignment across related performance frameworks.

4. Conclusion

The Department is accountable for demonstrating progress in First Nations education outcomes. Supporting the education of students on-reserve requires a coordinated approach across the Elementary and Secondary Education (ESE) and Education Facilities (EF) Programs, and collaboration with other internal stakeholders at Indigenous Services Canada (ISC) whose activities influence education and education outcomes. While foundational structures and processes exist within the ESE and EF Programs, the audit found that roles and responsibilities require clearer alignment, coordination between programs needs to be strengthened, and key elements of governance, funding design, and performance measurement should be better integrated. Enhancing the coherence of these internal systems will improve the Department’s ability to manage education programming effectively and demonstrate meaningful results.

5. Management and Action Plan

Recommendation 1

The Assistant Deputy Minister of Education and Social Development Programs and Partnerships (ESDPP)Footnote 5 and the Senior Assistant Deputy Minister of Regional Operations (RO)Footnote 6 should review and document coordination processes between the Elementary and Secondary Education and Education Facilities Programs, including regional offices. This should include clearly defined roles and responsibilities for Headquarters and regional offices in implementing decisions that affect both programs, as well as consideration of formal governance or oversight mechanisms to support ongoing collaboration, decision- making, and information sharing across both programs.

Management Response / Actions

The Education Branch, Regional Infrastructure Delivery Branch (RIDB), Community Infrastructure Branch (CIB) and where applicable, Regional Education Programs, to formalize and document the coordination taking place between the Elementary and Secondary Education (ESE) and Education Facilities (EF) Programs. This will include:

  1. Monthly Directors General (RIDB, ESDPP, CIB) and AFN meeting.
  2. Quarterly Directors General meetings (RIDB, ESDPP, CIB) where program decisions that would impact both the ESE and EF programs will be discussed.
  3. Quarterly data validation meetings between Education Branch and RIDB
  4. Establishment of a Program Governance Framework for the relationship between Education Branch, Regional Education Programs, RIDB and CIB, which will:
    1. Outline roles and responsibilities between Education Branch and Regional Education Programs.
    2. Outline mechanisms to support collaboration, decision-making and information sharing across the ESE and EF Programs.

Responsible Manager (Title)

Assistant Deputy Minister of ESDPP, in collaboration with the Senior Assistant Deputy Minister of Regional Operations

Director General - Education and Social Development Programs and Partnerships

Director General - Regional Infrastructure Delivery Branch

Director General – Community Infrastructure Branch

Planned Implementation Date

  1. March 2026
  2. March 2026
  3. March 2026
  4. March 2027

Recommendation 2

The Assistant Deputy Minister of ESDPP should formalize the model risk and control framework, including policies and procedures, documentation standards, approval authorities, validation, review, and change control processes for the ESE Program Interim Regional Funding Formulas. The framework should also include a periodic independent review or challenge function to assess model accuracy, assumptions and performance.

Management Response / Actions

Education Branch will formalize a model risk and control framework, in consultation with Regional Education Programs, for the Interim Regional Funding Formulas, including:

  • Formalizing the risk and control framework, including adding risk tiering by level (low, medium, high)
  • Drafting narrative overviews including: assumptions, limitations, decisions, proxies.
  • Documentation and communication of procedures and timelines for change control processes
  • Roles and responsibilities (Headquarters and Regional Education Programs)
  • Standardization of models
  • Communication with Regional Education Programs and partners
  • Internal validation of IRFFs
  • Errors and omissions
  • Model validation: Periodic review of the existing funding models’ assumptions and accuracy of methodology.

Responsible Manager (Title)

Assistant Deputy Minister of ESDPP

Director General - Education and Social Development Programs and Partnerships

Planned Implementation Date

  1. March 2026
  2. March 2026
  3. March 2027
  4. March 2027

Recommendation 3

The Senior Assistant Deputy Minister of RO should review and, as appropriate, update the Program Control Framework and School Prioritization Ranking Frameworks to ensure that they are based on relevant and complete data. Where applicable, input from the Assistant Deputy Minister of ESDPP should be considered. Ensure documentation of project selection rationale, and explore opportunities to improve data access and integration between the EF and ESE Programs to support prioritization decisions.

Management Response / Actions

RIDB, in collaboration with CIB, is currently working on the updates required for inclusion in the Program Control Framework to ensure processes and content are relevant in relation to the delivery of the EF Program.

An interim update to the School Priority Ranking Framework was completed in co-development between Indigenous Services Canada and the Assembly of First Nations, effective December 1, 2024. The interim update focused the criteria of the framework on health and safety and overcrowding and removed criteria that were not based on relevant data.

RIDB is currently conducting a stage 2 update to the School Priority Ranking Framework in co-development with the Community Infrastructure Branch, the Assembly of First Nations, the Chiefs of Ontario’s Ontario Bilateral Education Learning Table, with input from ESDPP, and national engagement with First Nations. This update aims to ensure that:

  • Education infrastructure assets with the highest health and safety and overcrowding concerns are prioritized.
  • Relevant data on asset condition and overcrowding is considered.

Responsible Manager (Title)

Senior Assistant Deputy Minister of Regional Operations

Director General - Regional Infrastructure Delivery Branch

Director General – Community Infrastructure Branch

Planned Implementation Date

Program Control Framework Review and updates – March 2026

School Ranking Priority Framework Stage 2 Update – December 2026

Recommendation 4

The Assistant Deputy Minister of ESDPP, with input from the Senior Assistant Deputy Minister of RO, where applicable, should develop materials that explain how Operations and Maintenance funding for education infrastructure is calculated through the Interim Regional Funding Formulas (excluding teacherages, federal schools, and student residences), and review oversight responsibilities for Maintenance Management Plans.

Management Response / Actions

Education Branch with consultation from the Regional Infrastructure Delivery Branch, will develop a clear and transparent governance structure for the delivery and oversight of Operations and Maintenance (O&M), including:

  1. The establishment of roles and responsibilities for the sharing of up to date infrastructure asset data, which is necessary for the determination of O&M funding through the Interim Regional Funding Formulas.
  2. Development of reference materials by Education Branch to explain how O&M is calculated through each Interim Regional Funding Formula.
  3. Internal data sharing between Education Branch and RIDB on the delineation of O&M funding to support informed infrastructure decisions under the EF Program.
  4. Update Indigenous Services Canada (ISC)'s Capital Facilities and Maintenance Program Cost Reference Manual for Operations and Maintenance to include specific references to Education Facilities and align with Operations and Maintenance references in the ESE Program guidelines. (RIDB/CIB)
  5. Establish roles and responsibilities for the review and oversight of Maintenance Management Plans including, RIDB review of the plans through the Asset Condition Reporting System Program (ACRS) report and process, which is linked to the ESE Program Guidelines (linked above).

Responsible Manager (Title)

Assistant Deputy Minister of ESDPP, in consultation with the Senior Assistant Deputy Minister of Regional Operations

Director General - Education and Social Development Programs and Partnerships

Director General - Regional Infrastructure Delivery Branch

Director General – Community Infrastructure Branch (to support)

Planned Implementation Date

November 2025

Recommendation 5

The Assistant Deputy Minister of ESDPP should consult with stakeholders within other ISC programs that deliver funding related to elementary and secondary education programming to review their PIPs, to consider how the work of these related programs impacts, directly or indirectly, the education performance measurement framework, and to identify a horizontal approach to capture all the variables impacting education results.

Management Response / Actions

Education Branch will:

  1. Consult stakeholders within ISC that deliver funding related to elementary and secondary education programming to review their program logic models and PIPs and consider how these other programs may impact education results. This consultation will occur on a three-year cycle in alignment with logic model and PIP cycle updates.
  2. Draft a horizontal crosswalk of indicators to capture the relevant program indicators identified through the above noted process. Relevant sectors will be consulted at least twice during the development process and ESDPP will seek approval from implicated Directors General confirming the accuracy of the crosswalk upon completion.
  3. Review Education Date Collection Is and determine where updates could reduce complexity and reporting burden and explore how reporting submission rates can be improved. Success regarding reduced complexity and reporting burden will be measured through feedback gathered from Regional Program Managers through existing mechanisms.
  4. Seek funding to explore improvements to Education Information System (EIS) for changes or other systems now available: to enable more flexible processes and timelines for Data Collection Instrument (DCI) updates.

Responsible Manager (Title)

The Assistant Deputy Minister of ESDPP

Director General - Education and Social Development Programs and Partnerships

Planned Implementation Date

  1. March 2026
  2. March 2026/27

Recommendation 6

The Senior Assistant Deputy Minister of RO should establish or enhance where applicable, program indicators that demonstrate the impact of investments in education infrastructure on education outcomes, using relevant and available data. Where appropriate, this work should be coordinated with the Assistant Deputy Minister of ESDPP to support alignment across related performance frameworks.

Management Response / Actions

RIDB will review its existing program indicators to consider inclusion of additional indicators that demonstrate the impact of investments in education infrastructure on education outcomes. For example, RIDB is currently analyzing available data (provided by ESDPP) on graduation rates to determine if there is any correlation with new schools that have been built and/or school expansions. Additional reviews will be completed as necessary.

Responsible Manager (Title)

Senior Assistant Deputy Minister of Regional Operations

Director General - Regional Infrastructure Delivery Branch

Planned Implementation Date

Winter 2026

Annex A: Audit Criteria

To ensure an appropriate level of assurance to meet the audit objectives, the following audit criteria were developed to address the objectives.

Audit Criteria

Audit Criteria 1

Accountabilities, roles, and responsibilities for managing and overseeing the Elementary and Secondary Education Program and the Education Facilities Program as well as the processes to support the collaboration and integration between the programs are clearly defined and implemented.

  • 1.1 A clear and effective organizational structure with defined accountabilities, roles and responsibilities for managing the Elementary and Secondary Education (ESE) Program and the Education Facilities (EF) Program have been documented, communicated and effectively carried out.
  • 1.2 Oversight bodies and communication channels have been established and implemented to coordinate and oversee the collaboration and integration between the ESE Program and the EF Program.

Audit Criteria 2

Adequate processes are in place for determining education funding allocations.

  • 2.1 Processes and procedures to validate the accuracy and completeness of data used in funding allocation determinations are implemented.
  • 2.2 Processes and procedures to integrate relevant ESE and EF Programs data to inform funding allocation determinations are implemented.

Audit Criteria 3

Adequate processes are in place for measuring progress towards education objectives and commitments.

  • 3.1 Mechanisms to measure whether ESE Program and EF Program G&C interventions are meeting education objectives and results are implemented.
  • 3.2 Processes and procedures to validate the accuracy and completeness of data used in measuring education outcomes and results are implemented.
  • 3.3 A formal approach is implemented to use performance measurement results to support the ESE and the EF Programs’ improvements

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