Public Accounts Committee on Oct. 17th, 2011

[Bill Matthews]

Thank you, Mr. Chair.

Thank you for inviting me here today to speak about the process of supply. What we mean by “supply” is the process used to actually resource departments. In this case, we're talking about estimates and all that goes on behind them.

You should be looking at a deck entitled “An Overview of the Supply Process and Public Accounts”. I will be walking you through the first part of this deck that covers supply, and then I will turn it over to the Comptroller General to wrap up the story, which ends with the presentation of the public accounts.

First, when you're dealing with supply, understand that it starts with the law. Both the Financial Administration Act and the Constitution Act state that no money can be spent out of the consolidated revenue fund without the authority of Parliament. That's our starting point.

I'll provide some background on how we get there. We have something called the expenditure management system. It governs how things actually make it into the estimates, which turn into appropriation acts approved by Parliament, which then resources departments.

Departments can get authority to spend money in one of two ways: either Parliament approves an appropriation act, or there's specific legislation that gives departments the authority to spend money. In most cases, you'll see us refer to voted appropriations. That is what an appropriation act is.

If a department has specific legislation that allows it to spend money, it's called a statutory spending authority. You'll see an “S” next to it in the main estimates or in the supplementary estimates. That basically tells you that the department has the legal authority to spend money without the appropriation act. Parliament does not vote on those dollars; it's for information purposes only. I'll expand on that a little bit later on.

Before something can get into the estimates and into an appropriation act for Parliament's approval, it has to go through a process inside government. That starts with departments making proposals to cabinet. Cabinet will assess spending proposals against the direction of the government, the Speech from the Throne. If they get endorsement there, when you are accumulating items for the next budget, there'll be a decision made by the Minister of Finance and the Prime Minister on whether to include something in the budget. That's then tabled in Parliament by the Minister of Finance.

Once there is a hook to the budget, departments can go away and develop detailed proposals on new programs. That's where Treasury Board comes in. If there is a new program, one has to put some thought into the resources required for the program, how one will evaluate the results, and the timing of the expenses. That results in a Treasury Board submission.

Once you get Treasury Board approval, that's when you can get into the estimates for approval by Parliament, either through the supplementary estimates or through the main estimates. But you need to understand that when we're talking about estimates, this is not just a case of departments thinking that they need some more money. There's a very complex, rigorous process, which we call the expenditure management system, that occurs before an item can be included in an appropriation act for approval by Parliament.

What are the main estimates? Estimates are provided to Parliament to enable its study of the appropriation act. This is a key point. Parliament does not approve the estimates; the estimates are provided to Parliament to assist in its study and ultimate approval of the appropriation act. When we're talking about what Parliament approves, it's the appropriation act itself. These estimates documents are provided to assist in the study of that legislation.

Estimates, both the main and supplementary estimates, are tabled in the House of Commons by the President of the Treasury Board and referred to the appropriate committee. From a House of Commons perspective, the committee on operations and estimates as well as the Senate finance committee will spend some time studying these things.

Another key point on estimates that I would leave with you is that these are not expenses; these are authorities to spend up to an amount. Departments make their best estimates as to what they'll spend. There is no requirement to spend it all; it's an up-to amount. It's a largely cash-based number based on actual expenditures. There is no requirement that you spend the entire appropriation. One should really read what's being asked for in the main and supplementary estimates, along with the departmental reports on plans and priorities, to see what the plans are for those moneys.

Why are we providing this? There are two bits to elaborate on here. First is information items. Where we have a statutory expense that has been provided for the information of Parliament, we will use both the main and supplementary estimates to update parliamentarians on what the latest forecasts for those items are. If you're wondering what an example of a statutory payment might be, think of the interest on the public debt. We just pay that. We pay what is due. There is no voted amount from Parliament.

You could also think about EI payments. If someone qualifies for employment insurance and meets the requirements, there are no checks made to ensure that there's enough money left in the vote. The person either meets the eligibility requirements or doesn't. We're just providing parliamentarians with an estimate of what we think will be spent on that front, but Parliament does not vote on that type of expense.

If you're looking for rough estimates, generally speaking on an annual basis one-third of the total spending of the government is voted; two-thirds is statutory. So it's one-third voted and two-thirds statutory.

Turning to slide 4, I will speak a little bit about what's actually in the estimates. There are three parts that we should speak about when it comes to the main estimates. Part I of the main estimates is the overall government expenditure plan. That will provide you with an analysis at a very high level of key changes between the main estimates of the current year and the main estimates of the previous year.

We then get into part II of the main estimates, and that is where you see the information that directly supports the appropriation acts that Parliament will ultimately approve. What you will see in there is information by department on what they're planning to spend. Both part I and part II must be tabled in Parliament by or before March 1. If you think about that, it makes perfectly good sense because the fiscal year starts April 1. It's important that departments have authority to spend money when the new fiscal year begins, so the requirement is that those documents get tabled on or before March 1.

Part III is the departmental expenditure plans. There are two pieces there. One is the report on plans and priorities, which outlines what the department is planning on accomplishing for the upcoming year. Typically these plans are tabled by March 31. If you think about last year, they were tabled in June because of the election and the House was not in session, but generally speaking they are tabled by March 31.

Typically in the November timeframe, departments table their departmental performance reports, which outline what was actually accomplished against their report on plans and priorities.

I'll speak about the supplementary estimates later, but they are tabled as required through the year. There are three supply periods that are possible. The government can table up to three sets of supplementary estimates (A), (B), and (C). In the last few years the government has attempted to do supplementary estimates for (A), (B), and (C). Last year supplementary estimates (C) were not approved. The appropriation act was not approved by Parliament—again because of the election—but the estimates were actually tabled.

Slide 5 gives a little bit about the cycle. This will show the linkages between the estimates and the public accounts, with which this committee is more familiar. If you think of the start of the fiscal year being April 1, the budget typically comes before that, usually in the February-March timeframe, and main estimates will get tabled and discussed before the fiscal year starts. We want to give sufficient time to committees and Parliament to study the main estimates and the appropriation act that goes with them. The process that is actually in place is what's called interim supply. Essentially, to provide adequate time for the committees to study the main estimates, Parliament typically approves an appropriation act that covers departments for the first three months of the fiscal year, and that's interim supply. Once parliament has completed its studies--typically before the end of June--we will get full supply for the following year or the entire year. When you're into the June timeframe, we are typically tabling supplementary estimates (A). They typically come not too far behind the main estimates.

You might wonder why we are tabling supplementary estimates right after the main estimates. The reason is the tight timeframe between the budget and the main estimates; there's not enough time to include new budget items in the main estimates. If there's an urgent item that was included in the budget and that's read to go, we typically include it in supplementary estimates (A). More often than not, you'll see another group of items coming in supplementary estimates (B) in the fall timeframe.

So there is a well-established calendar in the House of Commons that establishes the supply period and what has to happen. Supply gets voted on the last opposition day of each of the three supply periods. The final period of the year is when the public accounts are tabled, the current time period, when you'll get the results from the previous fiscal year. The Comptroller General will speak more to that. You will also see Canada's performance as well as the departmental performance reports, so you will have knowledge of what happens there.

Next, I'll discuss a little bit about what Parliament can actually do with estimates. When both the main and supplementary estimates are tabled, they are referred to committee for study. What committees can actually do is to decide whether to approve the votes. They can decide not to approve, or negative, the votes, so that the amount will be zero. Or they can decide to reduce an amount. A committee cannot recommend an increase in a vote. A committee cannot recommend that an amount be transferred from one vote to another. So there are limits on what the committee can actually recommend. There is a vote to concur with main or supplementary estimates on the last opposition day in the supply period. Once that vote occurs the appropriation act must be passed. That then turns into royal assent. Once we have royal assent, departments can go ahead and start spending money.

If you're wondering what happens when Parliament is not in session, there is a process called the Governor General's special warrants, allowing the proper approval of spending if Parliament is not in session due to an election. I'm happy to take questions about just how that process works, because departments did start this fiscal year operating on Governor General's special warrants.

I will flip ahead to slide 8. I've already touched on this, but interim supply is the first appropriation act of the year, and generally gives departments 3/12 of their requests in the main estimates, just to allow them to get the year going while Parliament complete its study of the appropriation acts. If an organization has an uneven spending pattern, i.e., they have to make a lot of contribution payments early in the year, there is a process whereby they can request more than 3/12. But our approach going in is that we give them 3/12. If they have a justified request for more than 3/12 to get them through the first three months of the year, we include that where warranted.

We have to have full supply approved as it relates to the main estimates, typically before the House rises for the summer to allow spending to occur beyond that period.

Turning to slide 9, the supplementary estimates are largely misunderstood. People tend to assume they're the result of inaccurate estimates by the government in the main estimates because they are tabled in addition to the latter. This is all about when the appropriate approvals have been received. So if you're not ready for main estimates because, although something was in the budget, there was insufficient time, it's perfectly fine to come forward in the supplementary estimates to get approval. So it's all about when a certain initiative has received the requisite cabinet and Treasury Board approvals, and it is then included in the next available set of estimates. So that could be supplementary estimates (A), (B), or (C), or it could be main estimates in a following year.

You will see things in the main estimates from this year that were part of Budget 2010, but it just took that time to go through the requisite approvals, to do the due diligence, and to make sure that all was ready to go for inclusion in the next set of supplementary estimates.

Just for a frame of reference, supplementary estimates (A) for the current fiscal year were tabled in Parliament in June. Supplementary estimates (B) will be tabled at some point in early November, with supply granted in mid-December.

Slide 10 makes the point about the link between the main estimates and budgets. If there is insufficient time to get the requisite cabinet and Treasury Board approval for items in the budget, then they are included in the main estimates.

In the 2011-12 main estimates, you will see items that were part of Budget 2010, as an example, the extension of the first nations water and wastewater action plan. You'll also see funding for the Canadian Space Agency to develop RADARSAT. Those items were in this year's main estimates as part of Budget 2010. You may see items from Budget 2011 coming in supplementary estimates (B), or even in subsequent main estimates.

Before I pass the mike over to my colleague, the Comptroller General, I will summarize the key points. One, items within the main and supplementary estimates are not just a matter of departments having made requests. There is a process called the expenditure management system to make sure the requisite cabinet, budgetary, and Treasury Board approvals are in place. Two, appropriations are an up-to amount. It is not a must that you spend that amount, but the authority to spend up to a certain amount on a cash basis. Three, Parliament does not approve estimates. Parliament approves legislation, which in this case is the appropriation acts. The estimates are tabled to assist Parliament and committee study of the appropriation acts. Finally, no money can be spent from the CRF without the approval of Parliament. That's a key point in both the Financial Administration Act and the Constitution Act.

With that I will turn to the Comptroller General to speak about how estimates then flow into public accounts.

[James Ralston]

As Bill pointed out, the estimates aren't about spending, but about authority. So they are prospective. By contrast, the public accounts are about spending and are retrospective. Once we've been through the supply process and the money has been spent, it comes time for the government to account for how that money was spent and to make it transparent to Parliament and Canadians. That's where the public accounts kick in.

On page 11 of the deck, the public accounts are defined as the annual report of the Government of Canada for the fiscal year ending March 31. They gets presented in three volumes. The financial statements are contained in volume 1, and continued in volumes 2 and 3 are many other disclosures required by law, policy, or convention. All of these are tabled in the House of Commons.

On page 12, the source of the authority is the Financial Administration Act, sections 64.(1) and 64(2). It is basically there. The authority goes to the Receiver General of Canada for the preparation of the public accounts, and to the President of the Treasury Board for tabling it. It is for the President of the Treasury Board and Minister of Finance jointly to determine the form and content.

On page 13 of the deck, there is a little more detail. Volume 1, as I mentioned, contains the financial statements of the Government of Canada, the report and observations of the Auditor General, financial statements discussion and analysis, and then details on certain financial statement components.

The financial statements are prepared in accordance with the public sector accounting standards, which are promulgated by the Public Sector Accounting Board in Canada. Essentially that's what the Auditor General is talking about when he issues an opinion, whether the financial statements are fairly presented, as the term “fairly presented” would be defined or implied through the application of the public sector accounting standards.

The financial statement, discussion, and analysis, as anyone who has looked at any set of financial statements, corporate or public sector, would know, is fairly dense and technical. The financial statement discussion and analysis is very helpful, because it tries to comment on the financial statements and interpret them and make them a little more accessible to those who are not qualified accountants as such. That is its purpose.

Volume 2, as I mentioned, has more details. It includes comparisons of actual spending, by ministry, to that in the estimates. This raises another point. The estimates documents that Bill was talking about are done ministry by ministry. The public accounts do provide a consolidated view of government in volume 1, and detailed views, ministry by ministry, in volume 2. Volume 3 contains financial statements of revolving funds and other information required by the Financial Administration Act, treasury board policies, or various sources.

All of the public accounts are available in their entirety on the web, and most of the public accounts are also printed. There is an exception, in that a portion of volume 3 is not printed because of its voluminous nature. Nevertheless, it remains part of volume 3 and is available on the web.

On page 14, there is a bit of a discussion about the actual process for producing the public accounts. It's a huge coordinated effort that involves the Treasury Board Secretariat, the Receiver General of Canada, all departments and agencies, and the Office of the Auditor General. We really do have to plan and coordinate together to make all of the pieces come together in accordance with the tight timeframes dictated by tabling and whatnot.

The OCG's role, my role, is the determination of the application of public sector accounting standards and comes into play largely with the treatment of new or unusual transactions. Much of what goes on is routine, but we'll get involved in those kinds of things also.

The Receiver General performs the physical consolidation of all of the material that individual departments produce. All of that material is done in prescribed format. There are many entities, something like 165 entities, if you added them all up. So there is a need for a certain amount of standardization to be able to pull the accounts together, and that's the job of the Receiver General.

Moving to page 15, the Department of Finance is the author of the financial statement discussion and analysis piece that appears in volume 1. They also prepare an annual financial report, which is a summarized version of what goes in the public accounts.

We've already heard from John about the Auditor General's role, and of course this committee's role, in reviewing the public accounts once they're ready.

In terms of the whole process, Bill and I have mentioned part of it. On page 16 you will see it all laid out. The interesting thing is that just because of its duration, it ends up spanning a number of calendar years, and even fiscal years.

If you see a particular cycle, starting with the budget.... Here we used Budget 2010 to illustrate this, a budget that appeared in March 2010. The main estimates appeared in March 2010 and the supplementary estimates in May and November of 2010. When Budget 2011 rolls around, a portion will be an update or a forecast of how the 2011 year is appearing, because that will inform the setting of next year's budget. Then in the fall, the annual financial report and the public accounts come out. So as you can see, the whole process, from when granting authority is provided to when final accountability is rendered, is a fairly lengthy cycle.

From page 17, I just want to mention that something new has occurred this year. It's not strictly speaking part of public accounts, but it's certainly part of the same family. Here I refer to the production of quarterly financial reports. In the past, as I have said, there's been annual information at the consolidated level, and at the individual department level for year ends. For interim or in-year financial information, the Department of Finance did produce, on a consolidated basis, information about how the year was progressing. What was missing was the ability to look at individual departments in-year to see how the year was progressing.

The innovation we now have is quarterly financial reports, which requires departments and crown corporations, for the first three quarters of the year, to produce a quarterly financial statement. Then in the fourth quarter, of course, we have the appearance of the public accounts, which wraps up the year.

Treasury Board policy instruments were used to prescribe the form and content of the reports, and the first publication of QFRs came this past August.

That concludes our discussion of the supply and accountability process. I also have a deck, which you should have, on internal audit.

Do I have permission to pass to that topic?

[The Chair, NDP, David Christopherson]

No. I'm sorry, but we're just out of time. Otherwise, there is going to be no time for the committee. I'm sorry. Maybe in some of your answers, if it's relevant to the questions you're getting, you can tie it in. I would draw members' attention to the report. They can see it there, but I do think we need to get to questions.

So thank you all very much.

Colleagues, bear in mind that this is just for information, so if you don't have a question or you're not going to use all your time, please pass it along, because quite frankly, as it stands now, we're not going to get everyone in. So if you're done, please be done.

Okay. I'll start with the rotation.

Mr. Saxton, you have the floor.

[Andrew Saxton, Conservative, North Vancouver, BC]

Thank you, Mr. Chair.

Thanks to our witnesses for being here today. Thank you also for your very detailed and informative presentations. It is reassuring to know that we have the necessary procedures and controls in place here in Canada.

My first two questions are for the Auditor General. Can you highlight for the committee what one thing stands out as the biggest improvement in the last five years in the overall fiscal reporting process by the Government of Canada?

[John Wiersema]

Mr. Saxton never asks easy questions.

In the last how many years?

[Andrew Saxton, Conservative, North Vancouver, BC]

You could highlight more than one, if you can find more than one.

[John Wiersema]

In the last how many years, Mr. Saxton?

[Andrew Saxton, Conservative, North Vancouver, BC]

The last five years, maybe six if you extend it.

[John Wiersema]

I have frequently indicated to this committee, Mr. Chairman, that at the level of summary reporting to Parliament and to Canadians, I believe the Government of Canada is a world leader. I believe that is the case for a number of reasons.

First, the Government of Canada adopted full accrual accounting in its financial reporting in, I guess it was, early 2000. That was an important development.

Another reason, as Mr. Ralston has indicated, is that the government follows independently set accounting standards, the standards set by the Public Sector Accounting Board, in preparing those financial reports.

So one huge step forward was made with the introduction of full accrual accounting. And at the risk of having my name removed from Michelle's Christmas card list, we have frequently and constantly been encouraging government to take the next step of moving towards full accrual accounting in the budgeting and estimates and supply process. The government has indicated how that works. It starts with the Minister of Finance's budget, then goes to the estimates process, and ends up with the public accounts of Canada. Well, the start of the process, the budget, is full accrual accounting. The end of the process, the public accounts, is full accrual accounting. Everything in-between is a bit of a hodgepodge of cash accounting and modified cash accounting. So we'd like to see the benefits of full accrual accounting extended right throughout the supply process. That would be one major improvement.

The other improvement I would talk about—and I believe I have mentioned this previously, Mr. Chairman—is as a result of the introduction of the Federal Accountability Act. The requirement relating to accounting officers for the heads of organizations, I believe, was a significant step forward. That same legislation, as Mr. Ralston has indicated, also put in place the requirement for internal audit functions in government departments and the establishment of departmental audit committees with outside membership.

So those were some milestones in public financial administration that I think have significantly moved the yardsticks forward.

[Andrew Saxton, Conservative, North Vancouver, BC]

Thank you.

Given those milestones—the introduction of the Federal Accountability Act, and other legislation—would you say that the government is more transparent today as a result than it was, say, six years ago, before the introduction of that legislation?

[John Wiersema]

Yes, Mr. Chairman, the Government of Canada is quite transparent in its financial reporting. Yes.

[Andrew Saxton, Conservative, North Vancouver, BC]

Thank you very much.

My next question is for the secretary. How did the Federal Accountability Act change the way your office works, and what improvements did it make to the overall operations of government, in your opinion?

[Michelle d'Auray]

Thank you.

John picked up on a couple of those elements. I would say one of the primary elements has been to codify in legislation the traditional approach, or an understood approach, to the role of accounting officers, the role of deputy heads of organizations, their responsibilities, their span of control, and management responsibilities. The FAA literally codified those things and put them in legislation.

The big change has allowed us, as I indicated in my remarks, to move away from prescription and from a secretariat directive having to go into the gory details and telling everybody exactly how they should be doing everything. That has been a big shift, because the responsibilities and accountabilities are now with the deputy heads of the organizations on a full range of elements. So we can look to principals, results-based approaches.

The other core elements were mentioned in regard to the departmental audit committees: internal audit executives and their functions within organizations; and the requirement to have chief financial officers, and the accreditation of those chief financial officers or senior financial officers within organizations. So it involves the whole rigour around financial management and financial management processes.

Finally, I would add the management accountability framework and the rigour of reporting requirements that have come about as a result of that. I would say the cumulative impact of that has been a significantly more rigorous and stronger management regime.

[The Chair, NDP, David Christopherson]

Thank you.

Monsieur Caron.

[Guy Caron, NDP, Rimouski-Neigette—Témiscouata—Les Basques, QC]

Thank you very much, Mr. Chair. Thank you very much for the very thorough and informative presentations. I have two main questions and maybe a third, if I have time. The first question is for Mr. Ralston.

In your presentation, you said that the 2011 Public Accounts report will probably be tabled in November. Is that right? I checked to see when reports have usually been tabled since 1995. In general, they are tabled between the second week of September and the third week of October. Could you tell me why it is taking longer this year?

[James Ralston]

In point of fact, this year we're expecting the tabling on November 3. Last year it was October 28; the year before that it was November 4; and the year before that it was December 1. So I don't perceive the timing this year to be unusual in any way.

[Guy Caron, NDP, Rimouski-Neigette—Témiscouata—Les Basques, QC]

What affects the date of when a report is tabled? What determines whether a report will be tabled in September or in the third week of October?

[James Ralston]

As I mentioned, the biggest factor determining the tabling is the production process, which is quite challenging and involves a lot of people. There are certain aspects of the financial statement, certain results, that cannot be determined until August. Even though much might be ready, a lot is left until that time, simply because it can't be done any earlier. Then there are certain audit requirements that also have to be scheduled in there, including protocols around when things can be signed off and when field work is considered to be done. John would be better able to explain that.

The simple fact is that when you work out all of the steps and milestones, the size of the task primarily determines the timing.

[Guy Caron, NDP, Rimouski-Neigette—Témiscouata—Les Basques, QC]

Thank you. My next question is for Mr. Wiersema.

We had the good fortune to meet at the Conference of the Canadian Council of Public Accounts Committees in Halifax. We were able to chat and we also heard some rather interesting presentations.

One of them in particular got my attention. It was the presentation given by the chair of the UK Public Accounts Committee. One aspect of her presentation was very interesting. It is something that differs specifically from what happens in Canada. In the UK, the chair of the committee works closely with the auditor general.

Do you think this would be a positive improvement? What would the pros and cons be of a more complementary or closer co-operation between this committee, more specifically, the chair, and your office?

[John Wiersema]

Thank you for the question, Mr. Chairman.

The member is referring to a meeting that takes place once a year by the Canadian Council of Public Accounts Committees and the Canadian Council of Legislative Auditors. All the auditors general of Canada and the provinces get together once a year and meet jointly with the members of the PACs from across Canada to talk about best practices, and so on.

This year we received a presentation from the chair of the public accounts committee in the U.K., who talked about the best practices there. The national audit office, comptroller, and auditor general of the U.K. work very closely with their public accounts committee equivalent, and perhaps even a little bit more so than we do here in Canada. You'll find that practices vary across different jurisdictions. For example, the Auditor General of Ontario basically provides the type of research assistance that your analysts provide to the federal PACP.

As for my experience working with the federal public accounts committee, I believe we've struck the right balance for the federal environment. I have been quite happy with the working relationship that the Office of the Auditor General has enjoyed with this committee in the past. You are well supported by your clerk and your researchers. Your researchers will meet with staff from the Office of the Auditor General to prepare for a hearing. They might meet with staff from the affected departments. They provide effective support to the committee's work.

I meet periodically with your chair to talk about upcoming business. I think that relationship has worked in the past. I'm open to meeting with individual members of the PACP at any time to talk about the work of the committee and how we might work more effectively.

So I believe the relationship we enjoy with the public accounts committee works well in the federal context. I'm comfortable that we don't need to go further along the lines provided by other jurisdictions, because you're well supported by your researchers and our individual relationships.

[The Chair, NDP, David Christopherson]

Thank you, Mr. Wiersema.

Mr. Kramp, you have the floor.

[Daryl Kramp, Conservative, Prince Edward—Hastings, ON]

Thank you, Chair.

After spending over three years discussing accrual accounting and accrual implementation, I can assure both the chair and our guests here today that I will not be commenting any further at this meeting on that topic.

[Voices]

Oh, oh!

[Daryl Kramp, Conservative, Prince Edward—Hastings, ON]

But I am assured that we have a great set of checks and balances in this country. When we shop and compare around the world, as Mr. Wiersema has mentioned, I think we can be tremendously proud of our collective accomplishments as a nation, thanks in no small part to our tremendous staff and civil service, as well as our executive and administrative branches of government. So I thank you all for your work on this.

In public accounts, for a number of years now we've recognized the necessity of moving and implementing IT into our entire process. Of course, it's not without its problems. One of the concerns that has been registered to both me and others is that if we move away from the actual paper trail to electronic and virtual tabling, will we not lose transparency or accessibility?

Madame d'Auray?

[Michelle d'Auray]

I actually believe it will be the opposite. A web-based approach allows for a greater degree of information and greater flexibility in the use or manipulation, in the good sense of the term, of the information and data. I think that is indeed where governments are increasingly going. The print versions, while interesting, also have limitations in their format and what you can do with the information, whereas an electronic version allows you to add, change, and update on a regular basis.

For example, as Jim and I mentioned, we did the quarterly financial reporting electronically on organizations' websites. It's easily updated. If we had to go to a printing cycle, the delays in producing this would far outweigh the timeliness of the production of the information. So going to an electronic format actually speeds up a lot of the process. We wouldn't have been able to meet the deadlines on a quarterly reporting basis if we had not gone electronically.