Yes, we are indicating that, because it's too cozy, too in-house. We don't consider it an independent third-party review process, and it's not used consistently.
I would just like to add one thing that reaches out to a question asked previously. The CRA pride themselves on being trendsetters because they brought forward a new staffing regime, a new recourse regime, a new entity distinct from Treasury Board, although the financial tie is still very strong. They did make strides in establishing forums for consultation for employee representatives. They have tried to make the staffing more efficient, and it doesn't work.
If they want to continue with that impression of themselves--that they are trendsetters--they could go a step further and say, “Yes, we are a separate employer; why don't we establish a process by which we could bargain staffing and recourse?” They could be even more distinct from the rest of the public service.