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Deloitte Report - File Review


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Portable Document Format(Portable Document Format Version - 1130 K)


Review of Closed Operational Files

Office of the Public Sector Integrity Commissioner

March 31, 2011
Confidential

Table of contents

1 Introduction and Background
1.1 Introduction and Objective
1.2 Background
1.3 Mandate
2 Executive Summary
2.1 Overall results of file review
2.2 Overall summary of issues identified
3 Scope of Review
4 Our understanding of the types of complaints and the OPSIC process for handling complaints
4.1 Disclosure of alleged wrongdoing by public servants
4.2 Disclosure of alleged wrongdoing pursuant to Section 33 of the PSDPA
4.3 Complaints of alleged reprisal
5 Discussions of Findings
5.1.1 Files covered by our review
5.1.2 Completeness of files
5.2 Distribution of files reviewed
5.3 Approach and methodology
5.3.1 Applicable Act
5.3.2 Other applicable guidelines, rules and regulations
5.4 Overall results of our review
5.4.1 Results by type of file
5.4.2 Result by fiscal year
5.5 Discussion of types of issues identified
5.5.1 Not all issues reported to OPSIC were dealt with
5.5.2 Lack of documentation to support the conclusions
5.5.3 Lack of analysis to support the conclusions
5.5.4 No admissibility analysis
5.5.5 New information provided to OPSIC and file was not re-evaluated
5.5.6 Decision letter signed by Registrar
5.5.7 Other types of issues
Appendix A – List of OPSIC Closed Operational Files Reviewed

Confidential


March 31, 2011

Mr. Mario Dion
Interim Public Sector Integrity Commissioner
Office of Public Sector Integrity Commissioner
60 Queen Street, 7th Floor
Ottawa, ON  K1P 5Y7

Subject: Review of closed operational files

Dear Mr. Dion:

Attached is our draft report setting out the findings from our review.

Our findings are based on procedures undertaken as described in Section 3 of this report and are subject to the restrictions in scope as set out therein.

Should you have any questions or concerns, please do not hesitate to contact me at 613-751-5378.

Yours very truly,


Original report signed

Gary Timm, CA∙IFA, CFE
Partner, Financial Advisory
Deloitte & Touche LLP

Enclosure

 

 

1 Introduction and background


1.1 Introduction and objective

Deloitte & Touche LLP (“Deloitte”) was retained by the Office of the Public Sector Integrity Commissioner of Canada (“OPSIC”) to perform a review of closed disclosure of wrongdoing and reprisal complaints files in order to determine whether they were dealt with in a manner consistent with the requirements of the Public Servants Disclosure Protection Act (“PSDPA”) and with applicable legal , investigative and administrative decision-making standards.  The purpose of the review is to identify any possible issues or errors in process or fact in the files in relation to the criteria as set out in Section 1.3.

1.2 Background

OPSIC has the mandate to establish a safe, confidential and independent mechanism for public servants or members of the public to disclose potential wrongdoing in the federal public sector.  It also protects public servants from reprisal for making such disclosures or cooperating in investigations.  OPSIC’s goal is to enhance public confidence in our public institutions and in the integrity of public servants. In carrying out its mandate, the Commissioner is required to submit an annual report to Parliament.

On October 20, 2010, OPSIC announced that Christiane Ouimet, the Public Sector Integrity Commissioner, retired from Public Service, effective October 18, 2010.
On December 9, 2010, the Auditor General (“AG”) of Canada issued a report related to a performance audit of OPSIC. With regard to the performance of PSIC’s mandated function, the AG reported the following:

In our view, the allegations against the Commissioner concerning the improper performance of her mandated functions are founded. During the period covered by our audit, procedures for conducting investigations were not finalized or implemented. We also found that, in many cases, decisions to refuse to investigate, or to dismiss disclosures of wrongdoing and complaints of reprisal were not supported by either the nature of work performed, the documentation on file, or both. It is also our view that decisions by the Commissioner to refuse to investigate certain complaints of reprisal on the basis that she could not conclude that an act of reprisal had occurred extended beyond her responsibilities under the PSDPA. Again, we considered information gathered from multiple sources in the course of our audit in arriving at this conclusion.

Mr. Mario Dion was appointed Interim Commissioner in December 2010. Mr. Dion initiated a comprehensive third party review of all closed files from the inception of OPSIC in 2007 to December 20, 2010. Following a competitive procurement process, Deloitte was retained to undertake the third party review.

1.3 Mandate

The Deloitte engagement consisted of a review and assessment of all closed disclosure and reprisal complaint files, totalling 221 files. For each file, Deloitte was asked to review and assess the following factors:

  1. Determine the issues and allegations identified (reported to PSIC) in the disclosure or reprisal complaint;
  2. Assess whether the analysis conducted by PSIC addresses all relevant issues and allegations;
  3. Assess whether the analysis conducted by PSIC provides a rationale or reasons for the recommendations in accordance with the requirements of the PSDPA;
  4. Assess whether the decision rendered addresses the relevant issues and allegations;
  5. Assess whether the decision rendered meets the requirements of the PSDPA; and
  6. Assess whether there is sufficient documentation on file to support the analysis, recommendations and the decision of the Commissioner.

OPSIC requested that we conduct a process review and assess closed files in relation to the six specific questions or factors, as noted above. We were not requested by OPSIC to review and assess the specifics of the case analysis work performed and the appropriateness, adequacy and completeness of the investigative steps undertaken by OPSIC personnel. 

We understand that OPSIC has retained the services of a Special Advisor to provide the Interim Commissioner with recommendations regarding possible corrective measures for any file where an issue relating to one or more of the factors above is identified.

Note: Our work and the resulting report do not constitute a legal opinion regarding the PSDPA, nor do they represent such an opinion in any way.

2. Executive Summary

2.1 Overall results of file review

Based on our review of the 221 closed operational files, we identified 70 files that have issues in relation to the factors that were reviewed and assessed as defined in Section 1.3 of this report. We did not identify issues in relation to the factors that were reviewed and assessed with the remaining 151 files.

Table 1: Summary of Files Reviewed, by Fiscal Year

Number of files

FY 2007/2008

FY 2008/2009

FY 2009/2010

FY 2010/2011

Total

Issues identified

34

18

16

2

70

No issues identified

43

47

44

17

151

Total number of files

77

66

60

19

221

Percentage of files where issues were identified

44%

28%

27%

11%

32%

2.2 Overall summary of issues identified

The following chart summarizes the types of issues identified in the files reviewed by fiscal year:

Table 2: Summary of Issues Identified, by Fiscal Year

Number of files where issues were identified

Nature of issue

FY 2007/2008

FY 2008/2009

FY 2009/2010

FY 2010/2011

Total

Not all issues reported to OPSIC were dealt with

14

5

4

2

25

Lack of documentation to support the conclusions

19

4

7

2

32

Lack of analysis to support the conclusions

12

8

10

1

31

No admissibility analysis 4 4 4 12
New information provided to OPSIC and file was not re-evaluated 4 1 5

Decision letter signed by Registrar

2

1

3

Other types of issues 1 4 1 6
Total number of issues identified 56 27 26 5 114
Total number of files where issues were identified (1) 34 18 16 2 70

(1) Due to specific files containing multiple types of issues, the total number of files identified as having issues is less than the total number of issues identified.

3 Scope of review

Our review covered the period from inception of OPSIC in 2007 to December 20, 2010 (the Review Period) and was limited to the issues described in this report. This period was selected based on instructions from OPSIC.

Our review included 221 closed operational files as identified and provided to us by OPSIC. We have presented a list of the specific files reviewed at Appendix A to this report.

Our procedures during the Review Period included a review of the available documentation contained in the OPSIC closed files, as provided to us, along with processes, policies and procedures of OPSIC relevant to the issues. We have not undertaken interviews of the OPSIC personnel or third parties in relation to these files.

In preparing the report, we specifically reviewed and/or relied upon the Public Servants Disclosure Protection Act, S.C.2005, C. 46, current to December 14, 2010, published by the Minister of Justice at http://laws-lois.gc.ca

As previously noted, OPSIC requested that we conduct a process review and assess closed files in relation to the six specific questions or factors, as outlined at Section 1.3 of this report. We were not requested by OPSIC to review and assess the specifics of the case analysis work performed and of the appropriateness, adequacy and completeness of the investigative steps undertaken by OPSIC personnel.

We reserve the right, but will be under no obligation, to review this report, and if we consider it necessary, to revise our report in light of any information, which becomes known to us after the date of this report.

Our work does not constitute an audit as defined by the Canadian Institute of Chartered Accountants. Consequently, said work and the resulting report do not constitute an auditor’s opinion nor do they represent such an opinion in any way.


4 Our understanding of the types of complaints and the OPSIC process for handling complaints


In terms of complaints received by OPSIC, they include three categories:

1. Disclosure of alleged wrongdoing by public servants;
2. Disclosure of alleged wrongdoing pursuant to Section 33 of the PSDPA; and
3. Complaints of alleged reprisal.

Our understanding of each of these categories is described in the following sections.

4.1 Disclosure of alleged wrongdoing by public servants

Public Servants (as defined at Section 2 of the PSDPA) can disclose allegations of wrongdoing to OPSIC. The types of disclosures from public servants that OPSIC can investigate include the following types of alleged wrongdoing (note):

1. A contravention of any Act of Parliament or of the legislature of a province or any regulations made under any such act;

4. A misuse of public funds or a public asset;

5. A gross mismanagement in the federal public sector;

6. An act or omission that creates a substantial and specific danger to the life, health or safety of persons, or to the environment, other than a danger that is inherent in the performance of the duties or functions of a public servant;

7. A serious breach of a code of conduct (established by Treasury Board or by an organization, as required by the PSPDA; and

8. Knowingly directing or counselling a person to commit a wrongdoing as defined in 1 to 5 above.

We understand that OPSIC’s review process for disclosures of alleged wrongdoing by public servants is as depicted in the following diagram.

Note: Public Servant Disclosure Protection Act (S.C. 2005, c. 46), section 8 – wrongdoings

How do we handle a disclosure of wrongdoing?

  • Disclosure of Wrongdoing to the Registrar
  • Admissibility Review / Extended Examination
  • Commissioner's Decision on Grounds for Further Action
    • No Further Action / File Closed (OR)
    • Further Action To Determine if An Investigation Is Warranted
      • No Further Action / File Closed (OR)
      • Launch of an Investigation - Formal Notice to Chief Executive

or

    • Launch of an Investigation - Formal Notice to Chief Executive
      • Allegations Not Substantiated / File Closed (OR)
      • Allegations Substantiated / Report to Parliament Within 60 Days

(source: OPSIC website)

 

Although the state of the review process has evolved since the inception of OPSIC, for the purpose of our review, the key processes reviewed were as follows:

  1. Receipt of the disclosure and initial assessment – All disclosures are received and reviewed by OPSIC's Registrar. The discloser may be contacted for clarification or additional information required to thoroughly review the disclosure. It is possible that the discloser will be advised of another mechanism that might address the issue more appropriately.
  2. Review of the admissibility of the disclosure – An analyst/investigator, with the support of a legal advisor, reviews the information presented to determine if further action is required. This review could include consultation with subject-matter experts and research on relevant issues of policy and law. A detailed admissibility report is submitted to the Commissioner, or to the Deputy Commissioner, with a recommendation to either proceed or to take no further action.
  3. Commissioner's decision – The Commissioner or Deputy Commissioner reviews the disclosure file and admissibility report to determine if further action is needed, including launching an investigation. A decision letter is transmitted to the discloser indicating whether or not OPSIC will proceed with an investigation.

4.2 Disclosure of alleged wrongdoing pursuant to Section 33 of the PSDPA


Section 33(1) of the PSDPA provides additional powers to OPSIC to investigate other alleged wrongdoings related to the Public Service – typically these are allegations of wrongdoing brought to the attention of OPSIC by individuals other than public servants.
The types of alleged wrongdoing that OPSIC can investigate are identical to those listed at Section 4.2.1 of this report (Disclosure of alleged wrongdoing by public servants).

The distinction made at Section 33(1) of the PSDPA is that a two-part test must be met, namely that:

  1. The Commissioner must have reason to believe that a wrongdoing has been committed; and
  2. The Commissioner must believe on reasonable grounds that the public interest requires an investigation.

If the above two-part test is met, we understand that OPSIC’s review process is identical to the process listed at Section 4.2.1 of this report (Disclosure of alleged wrongdoing by public servants).

4.3 Complaints of alleged reprisal

OPSIC has exclusive jurisdiction to investigate complaints of alleged reprisals.  Current and former Public Servants (as defined at Section 2 of the PSDPA) can make a complaint to OPSIC if, because the complainant has made a protected disclosure or has, in good faith, cooperated to disclose allegations of wrongdoing to OPSIC, the complainant has been subjected to alleged reprisal(s). Measures taken against current and former Public Servants which can represent a reprisal include the following:

1. A disciplinary measure,
2. The demotion of a public servant,
3. The termination of employment of a public servant, including, in the case of a member of the Royal Canadian Mounted Police, a discharge or dismissal,
4. Any measure that adversely affects the employment or working conditions of the public servant; and
5. A threat to take any of the measures or directing a person to do so.

We understand that OPSIC’s review process for complaints of alleged reprisal for current and former public servants is as depicted in the following diagram.

 

How do we handle a reprisal complaint?

  • Reprisal Complaint to the Registrar
  • Admissibility Review within 15 days
  • Commissioner's Decision on Grounds for Further Action
    • No Investigation / File closed (OR)
    • Investigation
      • Conciliation and Settlement (OR)
      • Application to the Tribunal (OR)
      • Complaint Dismissed

(Source: OPSIC Website)


Although the state of the review process has evolved since the inception of OPSIC, for the purpose of our review, the key processes reviewed were as follows:

  1. Receipt of the complaints of alleged reprisal and initial assessment – All complaints of alleged reprisal are received and reviewed by OPSIC's Registrar. The complainant may be contacted for clarification or additional information required to thoroughly review the complaint.
  2. Review of the admissibility of the complaint of alleged reprisal – Once OPSIC has sufficient information to review a reprisal complaint, the Commissioner has 15 days to decide whether or not to deal with it.  An analyst/investigator will prepare an admissibility analysis in order to provide a recommendation to the Commissioner or Deputy Commissioner on whether the complaint should be dealt with or not by OPSIC.
  3. Commissioner's decision – The Commissioner or Deputy Commissioner sends a written notice to the complainant to indicate whether they will deal with the complaint and, if not, provide reason(s) for this decision.

5 Discussions of findings

5.1 Files subject to our review

5.1.1 Files covered by our review

Our review was limited to 221 closed operational files, as of December 10, 2010, as identified at Appendix A to this report.  We have been advised by OPSIC that this list includes all files which have been closed since the inception of OPSIC in 2007 to December 20, 2010.

Our review did not include files which had not been closed as of December 20, 2010 (i.e. files that were being assessed as to their admissibility and file for which investigations were being conducted by OPSIC).

5.1.2 Completeness of files

OPSIC was responsible for providing us the files to be reviewed.  In order to ensure that the files were complete, and that we had access to all available information to review and assess the six specific questions or factors, OPSIC representatives performed a review of electronic information contained in the OPSIC Case Management System (“CMS”), as well as other existing electronic information saved on OPSIC’s network.

Any additional information identified from a review of CMS and other electronic information was printed for our review and identified as additional information.

For cases where information appeared to be missing from the file based on the information reviewed, we made further inquiries with OPSIC representatives in order to determine whether the information was available or not before concluding on our review and assessment of the specific file.

5.2 Distribution of files reviewed

The 221 files covered by our review are categorized by file type as follows:

1. Disclosure of alleged wrongdoing by Public Servants 100 files
2. Disclosure of alleged wrongdoing pursuant to Section 33 of the PSDPA 55 files
3. Complaints of alleged reprisal 66 files

This summary of files by category may differ slightly from OPSIC’s categorization of these files as we have reclassified a small number of files as a result of our review.


5.3 Approach and methodology

In order to conclude on each of the six factors to be reviewed and assessed for each of the closed operational files, we completed the following:

1. We requested the documentation for each specific file from OPSIC, which we understand included all information available at OPSIC as outlined at Section 5.1.2. The majority of each of the files comprised a single filing folder. Some of the closed files comprised multiple filing folders, or had additional documents contained in binders, accordion files or boxes.

2. The files were reviewed and key information captured in a template specific to the type of file (i.e., disclosures by public servants, Section 33 disclosures and complaints of reprisal). These templates were based on the relevant sections of the PSDPA. The information captured enabled the review and assessment of the six factors outlined at Section 1.3 for each file reviewed.

3. The overall results of the individual reviews were compiled.  If the review template for a file contains a “no” answer to one or more of the factors #2 to 6 being reviewed, it was identified has having an issue.

4. The issues identified were grouped by their type and nature in order to provide OPSIC with an overall summary of issues identified and their frequency within the population of files reviewed.

5.3.1 Applicable Act

Our work was completed pursuant to the provisions of the PSDPA.  We reviewed the PSDPA and obtained an understanding of specific provisions from OPSIC in order to identify which sections of the PSDPA were applicable to our review of the six specific factors.  Our review of each OPSIC file was based on our understanding of the PSDPA.

Our work and the resulting report do not constitute a legal opinion regarding the PSDPA, nor do they represent such an opinion in any way.

5.3.2 Other applicable guidelines, rules and regulations

Certain of the files reviewed included determination, recommendation and decisions regarding other Acts of Parliament.  As an example, OPSIC may have refused to investigate an allegation of wrongdoing if OPSIC determined that another Act of Parliament was better suited for the subject-matter of the allegations.  In such cases, we have not reviewed the details of these guidelines, rules, regulations and Acts of Parliament.  Rather, we have reviewed the content of the file and assessed if a rationale existed for OPSIC’s determination that these guidelines, rules, regulations and Acts of Parliament were better suited to deal with the subject-matter of the allegations.

5.4 Overall results of our review

Based on our review of the 221 closed operational files, we identified 70 files that have issues in relation to the factors that were reviewed and assessed as defined in Section 1.3 of this report. We did not identify issues in relation to the factors that were reviewed and assessed with the remaining 151 files.

The following chart summarizes the types of issues we have identified in the files reviewed:

Table 3: Summary of Issues Identified

Nature of issue Number of files where issue was identified
Not all issues reported to OPSIC were dealt with  25
Lack of documentation to support the conclusions 32
Lack of analysis to support the conclusions 31
No admissibility analysis 12
New information provided to OPSIC and file was not re-evaluated 5
Decision letter signed by Registrar 3
Other types of issues  6
Total number of issues identified  114
Total number of files where issues were identified (1) 70

(1) Due to specific files containing multiple types of issues, the total number of files identified as having issues is less than the total number of issues identified.

We have provided OPSIC with the specifics of our findings. As previously noted, we understand that OPSIC has retained the services of a Special Advisor to provide the Interim Commissioner with recommendations regarding possible corrective measures for any file where one or more issues have been identified.

5.4.1 Results by type of file

The table below summarizes a breakdown of the results of our review of the 221 closed operational files, by type of file, separating files where issues have been identified from files where no issues were identified in relation to the factors that were reviewed and assessed.

Table 4: Summary of Files Reviewed, by Type of File

Number of files

Disclosure from public servant

Section 33 disclosure

Complaint of reprisal

Total

Issues identifed

27

20

23

70

No issues identified

73

35

43

151

Total

100

55

66

221

The following chart summarizes the types of issues identified in the files reviewed by the three categories of files:

Table 5: Summary of Issues Identified, by Type of File

Number of files where issues were identified

Nature of issue 

Disclosure from public servant

Section 33 disclosure

Complaint of reprisal

Total

Not all issues reported to OPSIC were dealt with

10

8

7

25

Lack of documentation to support the conclusions

13

8

11

32

Lack of analysis to support the conclusions

12

6

13

31

No admissibility analysis

8

2

2

12

New information provided to OPSIC and file was not re-evaluated

2

3

5

Decision letter signed by Registrar

1

2

3

Other types of issues

4

2

6

Total number of issues identified

48

30

36

114

Total number of files where issues were identified (1)

27

20

23

70

(1) Due to specific files containing multiple types of issues, the total number of files identified as having issues is less than the total number of issues identified.

5.4.2 Result by fiscal year

The table below is a summary of the results of our review of the 221 closed operational file, by fiscal year (year-end date being March 31), separating files where issues have been identified from files where no issues were identified in relation to the factors that were reviewed and assessed.

Table 6: Summary of Files Reviewed, by Fiscal Year

Number of files

FY 2007/2008

FY 2008/2009 

FY 2009/2010

FY 2010/2011

Total

Issues identified

34

18

16

2

70

No issues identified

43

 47

44

17

151

Total number of files

77

 66

60

19

221


The following chart summarized the types of issues identified in the files reviewed by fiscal year:

Table 7: Summary of Issues Identified, by Fiscal Year

 

Number of files where issues were identified

Nature of issue 

FY2007/2008

FY2008/2009

FY2009/2010

FY2010/2011

Total

Not all issues reported to OPSIC were dealt with

14

5

4

25

Lack of documentation to support the conclusions

19

4

7

2

32

Lack of analysis to support the conclusions

12

8

13

31

No admissibility analysis

4

4

4

12

New information provided to OPSIC and file was not re-evaluated

4

1

 

 

5

Decision letter signed by Registrar

2

1

 

3

Other types of issues

1

4

1  

6

Total number of issues identified

56

27

26

114

Total number of files where issues were identified (1)

34

18

16

2

70

(1) Due to specific files containing multiple types of issues, the total number of files identified as having issues is less than the total number of issues identified.

5.5 Discussion of types of issues identified

5.5.1 Not all issues reported to OPSIC were dealt with

We have identified twenty-five (25) instances where not all of the issues reported by the discloser or complainant were dealt with by OPSIC's analyst, investigators, Commissioner or Deputy Commissioner.

5.5.2 Lack of documentation to support the conclusions

We have identified thirty-two (32) instances where there is a lack of documentation on file to support the conclusions. This can include information that was not provided by the discloser or complainant, information that was obtained by OPSIC during additional information gathering or during investigation, and information that was relied upon by OPSIC’s analysts, investigators, Commissioner or Deputy Commissioner, but that is not located on file.

5.5.3 Lack of analysis to support the conclusions

We have identified thirty-one (31) instances where there is a lack of analysis to support the conclusions. This includes specific sections of the PSPDA which do not appear to have been dealt with in the analysis.

5.5.4 No admissibility analysis

We have identified twelve (12) instances where an admissibility analysis was not located on file. Although the existence of an admissibility analysis is not required, it provides the foundation for the recommendation put forward by OPSIC’s analyst or investigator. The basic principle of having files assessed by analysts and investigators has existed since the inception of OPSIC. Generally, the admissibility analyses contain information that is consistent with the decision letter issued by the Commissioner or Deputy Commissioner, but often include additional information or discussion which provides support as to how a recommendation was determined. Without the presence of an admissibility analysis on file, the overall level of support and justification for OPSIC’s decision is decreased.

5.5.5 New information provided to OPSIC and file was not re-evaluated

We have identified five (5) instances where new or additional information was provided to OPSIC but, based on specific comments included in correspondence to the discloser or complainant or a lack thereof, it does not appear that OPSIC reviewed the additional information or re-evaluated the status of the file.

5.5.6 Decision letter signed by Registrar

We have identified three (3) instances where a decision letter was signed by the registrar.  This practice appears to be contrary to Section 24(3) and 25(1)(g) of the PSDPA.

Section 24(3) of the PSDPA states that:

“If the Commissioner refuses to deal with a disclosure or to commence an investigation, he or she must inform the person who made the disclosure, or who provided the information referred to in section 33, as the case may be, and give reasons why he or she did so.”

And Section 25(1) of the PSDPA states that:

“The Commissioner may delegate to any employee in the Office of the Public Sector Integrity Commissioner any of his or her powers and duties under this Act, except

(g) the power in section 24 to refuse to deal with a disclosure or to commence an investigation, the power in that section to cease an investigation and the duty in that section to provide reasons;”

5.5.7 Other types of issues

We have also noted instances of the following issues:

  1. PSIC indicated that a matter would be referred to another agency but there is no evidence on file that this was done.
  2. File received in error and only referred to the Office of the Auditor General after seven weeks had gone by, without notifying the discloser.
  3. On two files, OPSIC did not address the question of whether OPSIC should investigate a disclosure against its own employee, or whether this should be referred to the Office of the Auditor General.
  4. Lack of evidence that OPSIC notified the discloser of its decision to undertake an investigation.
  5. Lack of an indication that a separate file was opened to deal with a portion of the information received (i.e. no indication that a reprisal file was opened).

Appendix A - List of OPSIC closed operational files reviewed

We have reviewed the following OPSIC closed operational files.  The files numbers are based on the numbering system utilized by OPSIC in their case management system.

1. PSIC-2007-D-015
2. PSIC-2007-R-016
3. PSIC-2007-R-038
4. PSIC-2007-D-064
5. PSIC-2007-S33-068
6. PSIC-2007-S33-072
7. PSIC-2007-R-078
8. PSIC-2007-S33-089
9. PSIC-2007-S33-094
10. PSIC-2007-S33-102
11. PSIC-2007-D-107
12. PSIC-2007-S33-108
13. PSIC-2007-S33-130
14. PSIC-2007-R-135
15. PSIC-2007-D-136
16. PSIC-2007-R-140
17. PSIC-2007-D-141
18. PSIC-2007-S33-145
19. PSIC-2007-R-147
20. PSIC-2007-D-149
21. PSIC-2007-R-151
22. PSIC-2007-S33-153
23. PSIC-2007-S33-155
24. PSIC-2007-R-156
25. PSIC-2007-S33-157
26. PSIC-2007-D-162
27. PSIC-2007-S33-163
28. PSIC-2007-D-164
29. PSIC-2007-D-168
30. PSIC-2007-R-172
31. PSIC-2007-D-173
32. PSIC-2007-D-175
33. PSIC-2007-D-177
34. PSIC-2007-R-178
35. PSIC-2007-R-180
36. PSIC-2007-S33-184
37. PSIC-2007-D-185
38. PSIC-2007-D-187
39. PSIC-2007-D-190
40. PSIC-2007-D-191
41. PSIC-2007-D-193
42. PSIC-2007-R-198
43. PSIC-2007-D-200
44. PSIC-2007-S33-203
45. PSIC-2007-R-204
46. PSIC-2007-R-207
47. PSIC-2008-D-208
48. PSIC-2007-D-209
49. PSIC-2007-D-210
50. PSIC-2007-R-213
51. PSIC-2007-S33-214
52. PSIC-2007-R-215
53. PSIC-2007-D-216
54. PSIC-2007-D-224
55. PSIC-2007-R-225
56. PSIC-2007-R-226
57. PSIC-2007-S33-228
58. PSIC-2007-D-240
59. PSIC-2007-A-243
60. PSIC-2007-S33-249
61. PSIC-2007-S33-251
62. PSIC-2007-R-252
63. PSIC-2007-R-260
64. PSIC-2008-D-269
65. PSIC-2007-R-271
66. PSIC-2007-D-281
67. PSIC-2007-D-282
68. PSIC-2007-D-286
69. PSIC-2007-R-287
70. PSIC-2007-D-291
71. PSIC-2007-D-296
72. PSIC-2007-A-299
73. PSIC-2007-D-305
74. PSIC-2007-R-310
75. PSIC-2007-S33-312
76. PSIC-2008-S33-325
77. PSIC-2008-S33-326
78. PSIC-2008-D-328
79. PSIC-2008-D-329
80. PSIC-2008-A-333
81. PSIC-2007-R-337
82. PSIC-2008-S33-338
83. PSIC-2008-D-345
84. PSIC-2008-D-350
85. PSIC-2008-D-351
86. PSIC-2008-D-353
87. PSIC-2008-D-354
88. PSIC-2008-D-362
89. PSIC-2007-A-366
90. PSIC-2008-D-368
91. PSIC-2008-R-370
92. PSIC-2008-S33-376
93. PSIC-2008-D-382
94. PSIC-2008-D-384
95. PSIC-2008-R-385
96. PSIC-2008-R-387
97. PSIC-2008-D-388
98. PSIC-2008-D-389
99. PSIC-2008-R-391
100. PSIC-2008-S33-398
101. PSIC-2008-R-400
102. PSIC-2008-D-403
103. PSIC-2008-S33-407
104. PSIC-2008-D-408
105. PSIC-2008-R-411
106. PSIC-2008-R-417
107. PSIC-2008-D-427
108. PSIC-2008-D-438
109. PSIC-2008-R-441
110. PSIC-2008-D-442
111. PSIC-2008-D-443
112. PSIC-2008-D-452
113. PSIC-2008-R-460
114. PSIC-2008-D-462
115. PSIC-2008-D-464
116. PSIC-2008-S33-465
117. PSIC-2008-R-470
118. PSIC-2008-R-476
119. PSIC-2008-D-477
120. PSIC-2008-D-478
121. PSIC-2008-D-479
122. PSIC-2008-D-480
123. PSIC-2008-R-483
124. PSIC-2008-A-485
125. PSIC-2008-D-487
126. PSIC-2008-R-490
127. PSIC-2008-R-500
128. PSIC-2008-D-502
129. PSIC-2008-R-503
130. PSIC-2008-R-509
131. PSIC-2008-D-510
132. PSIC-2008-S33-511
133. PSIC-2008-D-513
134. PSIC-2008-D-514
135. PSIC-2008-D-516
136. PSIC-2008-D-518
137. PSIC-2008-R-521
138. PSIC-2008-D-523
139. PSIC-2008-R-524
140. PSIC-2008-D-525
141. PSIC-2008-D-526
142. PSIC-2008-R-527
143. PSIC-2008-D-528
144. PSIC-2009-D-542
145. PSIC-2009-R-544
146. PSIC-2009-S33-546
147. PSIC-2009-S33-549
148. PSIC-2009-D-560
149. PSIC-2009-D-561
150. PSIC-2009-D-562
151. PSIC-2009-S33-563
152. PSIC-2009-D-564
153. PSIC-2009-S33-595
154. PSIC-2009-S33-600
155. PSIC-2009-D-601
156. PSIC-2009-S33-602
157. PSIC-2009-D-614
158. PSIC-2009-R-620
159. PSIC-2009-S33-635
160. PSIC-2009-R-636
161. PSIC-2009-D-638
162. PSIC-2009-S33-640
163. PSIC-2009-R-641
164. PSIC-2009-S33-645
165. PSIC-2009-S33-653
166. PSIC-2009-R-654
167. PSIC-2009-D-661
168. PSIC-2009-D-664
169. PSIC-2009-S33-669
170. PSIC-2009-D-685
171. PSIC-2009-S33-686
172. PSIC-2009-D-690
173. PSIC-2009-D-695
174. PSIC-2009-R-701
175. PSIC-2009-S33-706
176. PSIC-2009-D-710
177. PSIC-2009-R-724
178. PSIC-2009-R-725
179. PSIC-2009-D-726
180. PSIC-2009-D-728
181. PSIC-2009-D-729
182. PSIC-2009-R-733
183. PSIC-2009-D-741
184. PSIC-2009-D-745
185. PSIC-2009-R-749
186. PSIC-2009-S33-750
187. PSIC-2009-D-752
188. PSIC-2009-D-754
189. PSIC-2009-S33-756
190. PSIC-2009-R-767
191. PSIC-2009-D-770
192. PSIC-2009-S33-772
193. PSIC-2009-R-782
194. PSIC-2009-R-783
195. PSIC-2009-S33-786
196. PSIC-2009-D-787
197. PSIC-2009-R-792
198. PSIC-2009-D-794
199. PSIC-2009-S33-798
200. PSIC-2009-D-799
201. PSIC-2009-S33-801
202. PSIC-2009-S33-802
203. PSIC-2010-R-829
204. PSIC-2010-D-830
205. PSIC-2010-D-833
206. PSIC-2010-R-844
207. PSIC-2010-R-852
208. PSIC-2010-D-856
209. PSIC-2010-S33-864
210. PSIC-2010-D-867
211. PSIC-2010-D-874
212. PSIC-2010-R-887
213. PSIC-2010-R-895
214. PSIC-2010-R-905
215. PSIC-2010-D-909
216. PSIC-2010-S33-914
217. PSIC-2010-D926
218. PSIC-2010-R-953
219. PSIC-2010-D-961
220. PSIC-2010-D-993
221. PSIC-2010-R-1005

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2015-09-29