Procurement Ombud Says ‘Bait and Switch’ Federal Contracts Common Beyond ArriveCan

Procurement Ombud Alexander Jeglic speaks during a news conference in Ottawa on July 8, 2025. The Canadian Press/Adrian Wyld

Federal Procurement Ombud Alexander Jeglic said a review of procurement practices found numerous instances of “bait and switch” in government contracts, where companies receive contracts based on their current employees and then switch them with less qualified personnel that perform the actual work.

The Office of the Procurement Ombud said in its Oct. 16 report that in more than half the files it reviewed, the replacement of resources by companies “was done correctly” and did not impact the selection of the “best-value  supplier.”

“However, in some cases, replacement resources did not meet or exceed the qualifications of the original resource proposed to secure the bid,” the office said, adding that this raises questions about “the selection of the winning supplier and the fairness of the procurement process.”

In October 2024, Jeglic launched a review of “bait and switch” practices across five government departments: Employment and Social Development Canada; Global Affairs Canada; Immigration, Refugees and Citizenship Canada; National Defence; and Shared Services Canada. Public Services and Procurement Canada (PSPC) was also included in this review due to its role as a central purchasing agent.

This came following a January 2024 report by the office that found 76 percent of contractors named on the proposal to work on the ArriveCAN application did not do any work on the app. The app was used to track the COVID-19 vaccination status of travellers crossing the Canada-U.S. border during the pandemic.

The Committee on Government Operations and Estimates conducted months of investigations into ArriveCan, which culminated in GC Strategies partner Kristian Firth being called to the House of Commons and admonished for failing to answer the committee’s questions. The RCMP said in 2024 that it had “multiple” ongoing investigations into ArriveCan, and GCStrategies has been barred from entering into contracts with the federal government for the next seven years.

The procurement ombud’s Oct. 16 report found that out of 17 contracts examined, there were nine cases where some or all of the individuals put forward to win the contracts were switched out. Additionally, in seven out of those nine cases, the replacements were not evaluated to see whether they met the experience of the original workers, which was required under the contracts.

The report stated that “bait and switch” tactics can be considered a violation of procurement rules and can even be considered to be fraud if the supplier “never intended to use the resources they originally proposed.”

The ombud noted that PSPC has made policy changes that effectively eliminate the use of “bait and switch” tactics by discontinuing the process of evaluating the qualification of proposed resources as part of the bid evaluation process.

However, the report said it was “unclear” why PSPC did not choose to merely strengthen existing controls. It also raised concerns about small and medium-sized businesses not being able to successfully participate in the processes if they do not have a track record of past contracts.

The report said that while PSPC’s decision to stop evaluating the experience and qualifications of resources will eliminate the issue of “bait and switch,” it does “little to achieve for the department the quality of product it bargained and paid for.”

The PSPC sent a response to the ombud’s office, which was included in the report, that requested the office to remove this criticism. The department said that several paragraphs in the report were “speculative and out of the review’s scope,” are not supported by data and information obtained by the office, and should not be made public. The ombud’s office said it noted this response but decided to include the paragraphs.

Jeglic said a follow-up review will be conducted in two years to assess whether the federal departments have implemented his recommendations.