Evaluation of the Nutrition North Canada Horizontal Initiative

Overview

A horizontal evaluation was undertaken by the Evaluation Branch of the Audit and Evaluation Sector of Crown Indigenous Relations and Northern Affairs Canada (CIRNAC), of the Nutrition North Canada program, (also referred to herein as "the Program" or "NNC").

The Nutrition North Canada program seeks to make nutritious food and essential items more accessible and affordable in 125 isolated northern communities., NNC replaced the Food Mail Program in response to recommendations from Indigenous and northern partners to adopt a holistic approach that promotes food security and sovereignty. CIRNAC's program components include the subsidy, the Harvesters Support Grant (HSG), Community Food Programs Fund (CFPF) and Food Security Research Grant (FSRG). The program is delivered with the support of Indigenous Services Canada (ISC) and the Public Health Agency of Canada (PHAC), who manage the program component of Nutrition Education Initiatives (NEI). Ultimately, NNC aims to support the ultimate outcome of strengthened food sovereignty and resiliency to changing environments in Northern and Indigenous communities.

The evaluation examined the Program's performance over a 6-year period from 2019-20 to 2024-25 and assessed the relevance, efficiency, effectiveness, design and delivery of the Program, and of the Program's activities and outcomes. The evaluation utilized a collaborative participatory approach in the development of the methodology including engagement with community liaisons for the development of case study site visits. Multiple lines of evidence informed the Evaluation including a literature review, a document review, a program data review, key informant interviews, and seven regional case studies, which were conducted across 13 community visits.

Relevance

The evaluation found that the need for NNC remains high in eligible communities. The subsidy successfully lowers food prices from what they would otherwise be for nutritious food and many essential items. At the same time, newer components such as the HSG and CFPF offer a greater diversity of community-led food security solutions that better support food sovereignty and empower Indigenous leadership over local food systems. These changes were made in collaboration with Indigenous partners, and are positively received. However, the program itself is not enough to address persistent food insecurity. Food insecurity in Northern and Indigenous communities is a systemic challenge impacted by a broad range of factors, including infrastructure, employment, inflation, and the environment. The evidence collected indicates that the Program supports the federal government in meeting its objectives, and the program's evolution has been positively viewed by partners. However, further reforms are seen as necessary to improve the Program's responsiveness to Indigenous needs, particularly for the subsidy.

Effectiveness and efficiency

The evaluation found that, within its current performance measurement framework, the subsidy delivered most intended outputs. Performance measurement of the HSG and CFPF faced challenges. Reporting rates were inconsistent and responses could be unclear, making it difficult to quantify results. Despite these challenges, recipients and community members consistently praised the HSG/CFPF for its support of food sovereignty, self-determination, and a more holistic, Indigenous lens to food security. This indicates that some detail and data on the activities supported by HSG/CFPF are being lost in reporting. FSRG projects were launched and undertaken, meeting expectations. The project findings have yet to be published, limiting the ability of the evaluation to assess how they contribute to program data. ISC and PHAC met within 83% - 100% of their participation targets for NEI in the evaluation period, facing initial challenges during the pandemic, but recovering in later years. The program seeks to advance food sovereignty in the North by strengthening and diversifying local food systems. It seeks to promote access to competition, supports not-for-profit services, as well as local production of food, and, critically, resources Indigenous leadership to guide a distinctions based and self-determined approach. However, structural barriers can make new initiatives fragile and pose difficulties to continuity and growth over the long term.

Design and delivery

Since 2019, NNC's design and delivery have become more flexible and community-focused. New program components and changes to the subsidy have been positive shifts towards a more diversified and sovereign Northern food system. However the subsidy – the program's largest component – remains  a significant area of concern for stakeholders. Market food remains unaffordable for many residents in NNC communities. The subsidy's aim is to lower prices from what they might otherwise be, but it is not intended to achieve a clear outcome or target that responds to local needs. This persistent misalignment with community needs has been a fundamental challenge to how the program's impact is perceived. NNC has conducted greater engagement with Indigenous partners, through collaboration with governance bodies such as the NNC Advisory Board, which advises on the subsidy, and Indigenous Working Group and Inuit-Crown Food Security Working Group, which have shaped NNC's newer program components. There continues to be demand for greater Indigenous sovereignty in the design of program governance, including a shift from advisory to decision making power and greater involvement in subsidy management. Additionally, as noted, food security and sovereignty is heavily impacted by a variety of factors, many external to NNC. Greater coordination across governments at all levels will better improve these structural challenges from a strategic perspective, to better support durable food security.

Recommendations

It is recommended that CIRNAC:

1. Embed NNC Within a Whole-of-Government Food Security Approach for the North
   1. Co-develop an approach that reflects the unique rights and priorities of eligible communities.
   2. Coordinate across Indigenous, federal, provincial, and territorial levels of government.
2. Align the Subsidy to Deliver on Outcome-Based Affordability Targets
   1. Establish clear, measurable affordability targets for subsidized goods in collaboration with Indigenous partners, retailers, and pricing experts.
3. Advance Indigenous Leadership in the Governance of NNC
   1. Transition NNC toward shared decision-making and accountability with Indigenous partners across all core components.
4. Strengthen Transparency at the Community Level Through Collaborative Communication Mechanisms
   1. Transparency should be strengthened by working with Indigenous governments, regional bodies, and community organizations to enhance communication mechanisms.
   2. This could include creating a localized feedback system allowing for greater ongoing understanding of the unique circumstances of each community.
5. Continue Seeking Long-Term Investment in Community-Led Food Systems
   1. NNC should build on its success by seeking to expand long-term support for community-led food systems such as extending multi-year funding, reinforcing Indigenous governance and leadership.
   2. NNC should co-develop communication and reporting tools with Indigenous partners to strengthen performance measurement of HSG/CFPF.

Project Title: Evaluation of the Nutrition North Canada Horizontal Initiative

1.1 Overview

Nutrition North Canada (NNC) is a federal horizontal initiative led by Crown–Indigenous Relations and Northern Affairs Canada (CIRNAC), in partnership with Indigenous Services Canada (ISC) and the Public Health Agency of Canada (PHAC), that helps make nutritious food and essential items more accessible and affordable in 125 isolated northern communities. Operational since 2011, NNC evolved from the Food Mail Program in response to recommendations from Indigenous and northern partners to adopt a holistic approach that promotes food security and sovereignty to strengthen local food systems.

1.2 Program Profile

Northern and Indigenous communities face some of the highest food insecurity rates in Canada and the reasons for this are complex. Poverty, limited job opportunities, high transportation costs, and the impacts of climate change all make it harder to access healthy food.

The federal government has been involved in northern food access since the 1960s through the Food Mail Program. In 2011, Food Mail was replaced by NNC. Over time, NNC has grown to include new streams that better reflect Indigenous priorities and food systems.

• Subsidy (2011): Improves accessibility and affordability of nutritious food and essential items by subsidizing eligible products in isolated communities. Subsidy rates have increased over time, and in 2022 the subsidy was extended to cover seasonal surface transport such as sealift and winter roads. There are 5 subsidy levels, High, Medium, Low, Surface, and Charitable Organization. NNC requires companies to use the most cost-effective mode of shipment available, and report savings on store receipts.
• Nutrition Education Initiatives (NEI) (2011): Delivered by ISC since 2011 in 113 NNC-eligible Indigenous communities. PHAC became involved in NEIs in Budget 2016 to provide coverage for an additional 10 NNC communities that fall outside ISC's mandate. Supports locally determined and delivered activities that increase knowledge of healthy eating and strengthen skills for selecting and preparing store-bought and traditional or country food. NEI funding has not increased since the program's debut.
• Harvesters Support Grant (HSG) (2018): Co-developed with Indigenous partners, the grant increases access to country food in isolated communities by providing funding to support traditional hunting, harvesting and food sharing, while also upholding the inherent rights of Indigenous Peoples to hunt and harvest.
• The HSG has two streams: Stream 1: Land claim organizations and self-government is for communities with settled land claims. These organizations are accountable to their own citizens for how they use and allocate the funding. Stream 2: Communities is for communities without a settled land claim, and proposals are developed collaboratively with NNC. In both streams, multiple communities can be represented by a single Indigenous recipient organization, who will determine how they choose to allocate funding. Many organizations implement an application and proposal process for their communities, independent from NNC.
• Community Food Programs Fund (CFPF) (2022):^{Footnote 1} Co-developed with Indigenous partners, the fund is an expansion of the HSG and delivered as a single grant. It supports community food-sharing activities that include locally grown, market, and country food.
• Food Security Research Grant (FSRG) (2022): Supports Indigenous-led research on food insecurity and informs future program design.

1.3 Resources

Between 2019 and 2024, NNC managed approximately $800 million in spending. Most went to the retail subsidy, with significant investments in harvesting, community food programs, and NEI.

2.1 Scope and Timing

In compliance with Treasury Board Secretariat's Policy on Results and Section 42.1 of the Financial Administration Act, this evaluation looked at how Nutrition North Canada (NNC) has performed since its redesign and expansion in 2019 with a focus on relevance, effectiveness, design and delivery, and efficiency. The evaluation covered activities and funding from 2019-20 to 2024-25.

2.2 Collaboration

The evaluation was developed through a collaborative partnership approach with Indigenous and Northern partners to ensure it reflected community realities. An Evaluation Working Group (EWG), including federal and indigenous partners helped shaped the evaluation methods and case study design. Partners Include:

1. Inuit Tapiriit Kanatami;
2. Tlicho Government;
3. KKETS;
4. Island Lake Tribal Council;
5. Nunatsiavut Government;
6. Nunavut Tunngavik Inc;
7. Public Health Agency of Canada (PHAC);
8. ISC; and
9. CIRNAC Reps (NNC Program, CFRDO, Evaluation).

Partners advised on culturally appropriate approaches, such as storytelling and local engagement, and supported site visits and analysis. Input from the Inuit Food Security Working Group (IFSWG), First Nations Partners, and local liaisons in each case study community added depth and ensured the evaluation respected Indigenous perspectives through a distinctions-based approach. Partners also reviewed each technical report and the draft Evaluation Report and recommendations in a shared process.

2.3 Data Collection

The evaluation used qualitative and quantitative methods—literature, document, and data reviews; key informant interviews; and case studies—to assess NNC's relevance, design and delivery, efficiency, and effectiveness:

Together, these methods provided both quantitative and qualitative evidence, giving a fuller picture of how the program is working.

2.4 Limitations and Mitigation Strategies

As with all evaluations, there were limitations. HSG reporting varied across communities, which led to difficulties in capturing its impact at the data level. Gender and equity data was limited, and climate change and COVID-19 impacts were not always well captured in existing research. These gaps were partly offset by interviews and case studies, but they highlight the need for stronger data going forward.

3.1 Food Security Challenges and NNC Response

Food insecurity in northern and Indigenous communities remains severe and persistent, rooted in both history and current structural barriers. Through the subsidy, Nutrition North Canada (NNC) lowers food prices from what they would otherwise be for nutritious food and many essential items, and additional program components such as the Harvesters Support Grant (HSG) and Community Food Programs Fund (CFPF) offer a greater diversity of community-led food security solutions. Despite this, NNC operates within broader challenges of poverty, infrastructure gaps, and systemic inequities that the program cannot solve alone.

For Indigenous Peoples, food security is inseparable from food sovereignty. Food sovereignty may look different for different communities. For many, it centres around harvesting practices and food-sharing traditions. It also includes engaging Indigenous communities as active leaders in food security programming that reflects their values. Another aspect of food sovereignty could be involving Indigenous leadership in the retail or transportation sectors. Several Indigenous organizations have stakes in the airlines that ship food to their regions. Other communities choose to run local stores, food banks, or buying groups. In Nunavik, the Kativik Regional Government administers cost-of-living reduction measures, including a subsidy for food and other essential items applied in addition to the NNC subsidy. Inuit Tapiriit Kanatami (ITK) stresses the importance of food sovereignty for Inuit, describing it as the right to shape food systems and maintain land-based practices.^{Footnote 2} The Assembly of First Nations' First Nations Food, Nutrition and Environment Study also reflects this view, stating that traditional food connects to cultural, spiritual, and traditional values that are core to First Nations, and recommending that First Nations' sovereignty and self-determination be supported in food security policy.^{Footnote 3} In this view, healthy food is about more than price—it is tied to governance, identity, and cultural continuity.

There is a significant gap in food insecurity between Northern communities and the national average. For example, in 2022, in Nunavut, 76% of Inuit experienced food insecurity^{Footnote 4}. In Yukon 37.6% of First Nations living off reserve and 25.5% of Metis were food insecure^{Footnote 4}. In Northwest Territories, this was 42.3% of First Nations living off reserve, 27.7% of Metis, and 60.7% of Inuit^{Footnote 4}. In comparison, the national rate of food insecurity for all persons was 22.9% in the same period^{Footnote 5}.

NNC reported that the Revised Northern Food Basket (RNFB) accounts for 35–40% of household income in the North. Meanwhile, nationally, Canadians spend around 11% of their disposable income on food.^{Footnote 6} Single-parent families are even more affected, and in some regions, single parents spend nearly half their income to cover basic needs.^{Footnote 7} It is important to note that data on food insecurity among Indigenous peoples often faces significant gaps that can prevent the full picture from being seen though available data suggest disproportionately higher rates of food insecurity among Indigenous Peoples, especially in the North.

The drivers of food insecurity are layered. At its roots are colonial policies that disrupted harvesting practices, forced relocations, and weakened Indigenous governance. Poverty is a significant risk factor for food insecurity and is a prevalent issue in northern communities, where many households face low incomes, high unemployment, poor access to education, and overcrowding.^{Footnote 8} In addition, remote communities continue to face fundamental challenges to accessing market foods and essential items. These include fragile supply chains, which are frequently impacted by harsh weather, a lack of infrastructure to move and store food efficiently and safely, and the high cost of fuel and electricity to do so, which puts further pressure on shelf prices and impacts food quality.

Furthermore, Northern and Indigenous communities are experiencing rapid environmental change. Research has shown that the Arctic is warming four times faster than the rest of planet.^{Footnote 9} Climate change has shortened ice road seasons, exacerbated supply chain issues, and reduced access to harvesting lands. The effects of global inflation are also compounded in remote communities, as supply chains are longer. All these factors contribute to a complex operating environment for the program.

3.2 How NNC Has Changed Since the Last Evaluation

The last evaluation of NNC (2012–2018) found that while the subsidy improved access to nutritious foods, key changes were needed. It recommended updating the list of eligible foods, developing strategies to further reduce prices, supporting harvesters and locally produced food, and developing improved program measures, such as relevant indicators and better communication strategies. The House of Commons Standing Committee on Indigenous and Northern Affairs also recommended a reorientation of federal food security policy.^{Footnote 10}

Indigenous priorities have been central in shaping reforms. ITK's 2021 Inuit Nunangat Food Security Strategy described the subsidy model as too limited and called for direct support to harvesters, food-sharing networks, and Inuit-led delivery.^{Footnote 7} The Assembly of First Nations (AFN) emphasized that climate change and industrial activity were damaging the land and threatening access to food, while calling for stronger action on affordability.^{Footnote 11}

These, and other, assessments gathered Indigenous and community perspectives to set the policy foundation for NNC reforms, including the recent expansion to its current suite of food security programs. The HSG began by supporting communities to address harvesting needs and related infrastructure like freezers and sheds. Then, the CFPF extended the HSG's scope to support food-sharing and local production, like school meals and gardens. The Northern Food Security Research Grant (FSRG) launched to fund Indigenous-led research on food security in NNC-eligible communities to guide future program improvements. Subsidy eligibility was extended to food banks and not-for-profit organizations, which can now register as suppliers and use the subsidy when bringing food into communities. Together, this expansion of the program was intended to encourage a diversity of food providers, and to support greater food sovereignty.

Additionally, subsidy rates have increased and NNC now subsidizes all NNC-eligible food items to be shipped by surface transportation, which is typically lower-cost relative to shipping by air. These changes were intended to support lower shelf costs for a wider range of items.

These changes were developed in collaboration with the NNC Indigenous Working Group (IWG), the Inuit-Crown Food Security Working Group (ICFSWG), and the NNC Advisory Board. Key informant interviews and case studies report that the changes have been positively received. Retailers noted that higher rates and the expansion of the surface subsidy were much needed in the context of high inflation and led to savings for consumers. The flexibility of new grant funding was praised by Indigenous organizations for supporting greater food sovereignty, as Indigenous leadership determined and directed programming. Inuit representatives valued the HSG's role in supporting country food and cultural practices, while First Nations highlighted the flexibility of the CFPF. These program changes reflect a broader shift toward Indigenous-led programming.

NNC is Canada's most visible program addressing food security and sovereignty in the North. However, the issue of food security is multifaceted, and touches on a variety of deeply rooted issues, beyond the price of food on the shelf. These include key issues of infrastructure, housing, poverty, and climate change, among others. While the program's changes have been received positively, interviewees stressed that the structural supports needed to address food insecurity have not kept pace. Without stronger cross-government coordination to holistically address food insecurity, NNC's impact will continue to be limited by external factors and struggle to produce long-term results.

3.3 Does NNC Reflect What Communities and Governments Say Matters Most?

NNC has made meaningful progress in aligning with Indigenous and federal priorities with the introduction of the HSG, CFPF, FSRG, and the continuation of Nutrition Education Initiatives (NEI). These programs represent distinctions-based, community-led delivery and are widely seen as responsive and empowering. Indigenous partners note that supporting self-determined programming is a step toward reconciliation and food sovereignty, yet many also stress that overall alignment is still partial.

For Indigenous partners, the expansion of grant-based programs has been viewed as a way of advancing the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) and the Truth and Reconciliation Commission (TRC) Calls to Action. By funding harvesting, food sharing, and community-driven initiatives, NNC supports culturally appropriate food systems and strengthens Indigenous and northern food sovereignty. The HSG is often cited as a model of how to support food sovereignty, by contributing to knowledge transfer, wellness, and access to country food. NNC funding has supported community hunts, food-sharing, and school programs that align with regional strategies like ITK's Inuit Nunangat Food Security Strategy.

From a federal perspective, NNC supports multiple mandates. It advances Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC)'s focus on self-determination and northern development. It also supports Indigenous Services Canada (ISC)'s mandate to work collaboratively with Indigenous Peoples to support and empower independent delivery of services, and Public Health Agency of Canada (PHAC)'s health promotion mandate. More broadly, NNC fits within the Arctic and Northern Policy Framework, which commits to Indigenous-led food systems and reduced reliance on imported food.

However, the Assembly of First Nations, ITK and others continue to stress that the subsidy does not fully reflect First Nations and Inuit priorities. Partners have called for greater Indigenous leadership in subsidy management, adjustments to make the subsidy more responsive to community needs, and continued support for local food systems. These critiques point to the need for further reform.

NNC is seen as moving in the right direction. The new grant-based programs demonstrate that co-development and collaboration with Indigenous partners can create responsive and culturally grounded approaches. To fully meet what communities and governments say matters most, NNC requires continued reform, greater transparency, and stronger collaboration within a broader food security environment.

4.1 Did NNC Deliver on What It Set Out to Do?

4.2 Did NNC’s Delivery Translate into Better Access and Stronger Local Food Systems?

NNC has made meaningful progress in improving access to market food, by increasing the quantities of subsidized food shipped. Subsidized shipment volumes rose steadily between 2019 and 2023, with the largest increase during the pandemic.^{Footnote 13} Most food categories have since stabilized within the program's targets, showing that access to market food has improved. However, affordability remains a major challenge for consumers.

The HSG has expanded access to traditional and country foods, supporting over 500 documented hunts, fishing trips, and food-sharing events between 2021 and 2024.^{Footnote 14} These activities strengthened cultural practices and intergenerational learning. HSG support was widely praised by recipient organizations and the need for continued, strengthened support for harvesting was strongly emphasized across interviews and case studies.

However, many communities also faced significant challenges implementing HSG-funded programming due to underlying factors. Increasingly expensive shipping costs and fuel prices have eroded the value of funding. Additionally, wildfires, pandemic measures, staff turnover, infrastructure challenges, and climate and weather-related incidents disrupted efforts. While support from the HSG has helped alleviate these difficulties, they still placed limitations on activities. Organizational capacity also impacted HSG rollout. Across case studies, it was observed that some organizations with greater capacity, through existing expertise, greater infrastructure, available staff, and strong coordination and leadership, were better equipped to adapt to challenges and efficiently distribute funding. Other organizations faced delays. One key challenge for regional organizations distributing the grant was ensuring awareness in the communities. In some regions with slower rollout, many community members were unaware that support was available.

Community food initiatives supported through the CFPF have grown but remain fragile. Of 13 reported gardening and greenhouse projects, 9 were reported to be operational. Additional community food-based initiatives are supported by NEI. However, local food production is still small-scale and vulnerable to short growing seasons, high costs, and turnover in staff. No subsidized local food was reported in 2022–23 or 2023–24. In some cases, facilities sat unused due to procurement delays. Success depended on local capacity and context. — Stable coordinators and facilities, as well as a supportive political context and strong stakeholder engagement supported better outcomes.

Efforts to expand access through direct orders and non-retail participation saw limited success. Supplier registration grew slightly, and food banks reached shipment targets, but individual participation in direct orders remained well below expectations.^{Footnote 15} Many residents were unaware of how direct ordering worked, unsure of product eligibility, or found the process too complex.

Finally, the FSRG is helping to improve the data needed for local food security planning. Through the FSRG, NNC has begun to support communities in addressing gaps in evidence on access, program performance, and food insecurity. Five projects were funded, offering valuable insights but covering only a small share of NNC communities, leaving large gaps in evidence.^{Footnote 16}

NNC's delivery has increased access to market food and expanded traditional food harvesting, while also supporting community-led initiatives and research. But persistent affordability gaps, fragile local food projects, and uneven participation mean that results are not consistent across communities and depend heavily on local leadership, administrative capacity, and infrastructure.

4.3 Is the Subsidy Being Fully Passed On to Consumers?

Pass-through is an economic concept that represents the change of an item's price in response to a change to the cost of providing that item.^{Footnote 17} In the case of NNC, pass-through refers to the idea that if the subsidy reduces the cost of providing an item, that saving will be passed onto the consumer through lower shelf prices. However, pass-through is only relevant when comparing prices immediately before and after a rate change. This is because there are a range of additional factors that influence prices that fluctuate over time, such as transportation costs, wholesale food costs, and inflation. Nor is there an established appropriate profit margin for Canadian retailers whereby it could be determined that retailers are profiting "too much" from their business.

Retailers face high fixed costs to operate in remote communities, many passed directly to consumers. Freight price increases, limited cargo capacity, reliance on aging aircraft, airline monopolies, lack of climate-controlled transport and storage, gravel runways, and weather-related delays were all cited as common challenges that raise prices and reduce reliability. A lack of competition among retailers and airlines in Northern communities is another factor that impacts prices. Structural poverty further means that even with subsidies, many residents cannot consistently afford healthy food.

There have been many studies on the subsidy, utilizing different methodologies, that focus on pass-through as the key metric to assess the subsidy. Pass-through is also an indicator that the program utilizes in its Performance Information Profile.^{Footnote 18} Studies of the program have come to different conclusions on pass-through, showing mixed and incomplete results.

Several studies have attempted to estimate actual pass-through levels. Galloway and Li (2023) found that, on average, prices declined by $0.67 for every dollar of subsidy issued in communities with monopolies. Naylor et al. (2020) estimated that 91 cents of every subsidy dollar reached consumers in Nunavut. The program undertook a study (Lazar 2025) that reported pass-through rates as high as 98% for some retailers. It is important to note that these figures were based on internal costing models, not verified shelf prices, and did not account for broader structural factors such as cost escalation or corporate vertical integration. Preliminary findings of a Hamlet Food Voucher Program in Qikiqtaaluk, Nunavut demonstrated that the price of a basket in 2024 was 2.32 times higher in the region of Qikiqtaaluk than the rest of Nunavut after accounting for the NNC subsidy, demonstrating one instance of the variation in pricing across the North.^{Footnote 19}

No studies could completely assess the impacts of external factors on prices. Ultimately, this indicates that measuring pass-through is complex. While it has dominated public discourse about the subsidy, its relevance only in the very short term limits the utility of this measure. Focusing on pass-through is increasingly seen as inadequate and even misleading when evaluating the subsidy, as it ignores the impacts of deeply rooted drivers of price and broader questions about how Northern food security could be better supported.

Distrust in subsidy pricing was common in communities and influenced by many factors. High prices were a consistent issue, as was the observation that inputs contributing to prices were opaque to many residents. While outside of the program's control, the quality of store management was another contributing factor to distrust in retailers and, as a result, in the subsidy. Food quality was a major concern, with many communities sharing stories of spoiled or expired food remaining on store shelves, indicative of issues in stock management. Poorly labelled shelves, with mismatched or missing price tags was another concern. Finally, stronger collaboration between store management and community members is an important factor to support transparency at the local level, and community members that reported positive relationships with store management also reported fewer issues with food quality.

NNC requires that subsidy savings are visible on store receipts. While this provided some clarity as to subsidy savings at the cash register, distrust of retailer pricing limited the effectiveness of this measure to promote transparency. Some retailers voluntarily indicate which items receive the subsidy on shelf tags, but this was inconsistent across different chains. Some stores show the pre and post subsidy price and others add a small "NNC" label to the tag without information about savings. Many residents across communities noted that as prices were expensive regardless, they didn't find the savings indicated on the receipt or shelf tags relevant, and had greater interest in how overall prices were determined.

Community members suggested various ways to improve transparency around the subsidy. Many were interested in greater clarity and consistency in-store about how the subsidy is applied. For those that shopped at retailers without clear shelf tags, there was support for information on subsidized items to be clearly and consistently posted. While most community members were aware that perishables were subsidized, fewer were aware that many non-perishable foods and essential items were also subsidized. At the community level, there was interest in access to community data, such as tracking of local prices over time or information on total dollar amount of subsidy received by local retailers annually, and general support for greater public engagement and consultation on the subsidy list.

A great deal of concern lay with the power of the retailer over prices. Many community members suggested having posters or public engagements that explain how store prices are set, however, that information lies with the retailer and not NNC. Having a clearer subsidy target, such as a benchmark relative to Southern prices, was widely supported for ensuring that prices themselves can be held to a measurable standard and to reduce concern about price gouging.

The concept of pass-through has become a symbol of program accountability but is not a reliable measure of impact for the consumer. Moving toward outcome-based measures focused on affordability, price stability, and consumer access would make the subsidy more meaningful and accountable to the people it is meant to serve.

4.4 Is NNC Building More Resilient and Equitable Food Systems?

NNC has made progress toward building stronger local food systems, especially through co-developed components such as the HSG and the CFPF. These programs have enabled communities to expand access to nutritious, culturally relevant foods. However, results are uneven across communities, and heavily impacted by local context. Smaller or more remote communities, in particular, face ongoing challenges with staffing, building or maintaining infrastructure, and coordinating programming, which limit their ability to utilize funds to their full benefit.

The gains reflect a broader shift toward collaboration with Indigenous partners. Since 2017, NNC has worked closely with the Indigenous Working Group (IWG) and the Inuit-Crown Food Security Working Group (ICFSWG). Their input has shaped new program elements, outreach materials, and more flexible reporting methods. This approach marks a major change from the program's historical, top-down design.

Evidence shows momentum in developing local food systems and community food economies, but progress is often slow. The HSG and CFPF funded hundreds of community-led projects, supporting new freezers, storage containers, gardening tools, safety equipment, and harvesting gear. Additional local projects are funded by NEI. However, building infrastructure is often hindered by factors such as weather and environmental conditions, the high cost of materials and building, and challenges with ongoing maintenance. For example, while in some regions interest in gardening and greenhouses was high, only a handful of such projects were fully operational. Many faced delays due to short growing seasons, limited land or heated space, lack of equipment and soil, or high staff turnover. In Clyde River, a greenhouse sat unused for more than a year awaiting electrical work; in Nain, gardening efforts stalled due to staffing shortages; and in Rigolet, lack of training and coordination limited participation. These cases show that without stable capacity and infrastructure, local food production remains vulnerable.

Community food programming in schools has also emerged as a promising foundation. The CFPF funded 21 school food programs, many combining meals with land-based learning and youth engagement. Interviewees stressed that meal programs also build learning, cultural identity, and participation. However, many schools lacked safe kitchens, storage, or transport, which restricted their ability to expand programs or extend support to Elders, even where demand was strong.

The challenge of equity across communities is clear. Where capacity and funding flexibility aligned, outcomes were strongest. Some case study communities delivered a wide range of projects, facilitated by strong local leadership, infrastructure, and coordination. In some cases, initiatives were funded but stalled when key coordinators left, or supplies could not be delivered on time. Case studies showed that stable staffing, intergenerational participation, and flexible local coordination were central to success. Several interviewees described this dynamic as creating a "two-tier program": one for communities with the capacity to fully use funds, and another for those unable to access the same opportunities. This suggests that the effectiveness of NNC's programming is shaped as much by community conditions as by the grant funding itself.

Despite these uneven outcomes, a major success has been greater Indigenous leadership in program design and oversight. NNC's partnerships with governance bodies like the IWG, have shaped the CFPF, HSG, and FSRG, which many informants viewed as important supports for food sovereignty. Examples include Inuvik, where Inuit organizations used CFPF funds for regional food initiatives, training, and storage facilities, and Old Crow, where funding supported land-based practices tied to cultural and ecological calendars by the Vuntut Gwitchin First Nation. Consultation also led Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC) to accept oral and narrative reporting formats, respecting Indigenous communication protocols, reducing administrative burden, and encouraging engagement.

These gains, however, were not consistent. NNC's governance advisory bodies remain consultative rather than decision-making, and the retail subsidy remains outside the co-development model. Communities questioned why they could influence harvesting programs but not subsidy design or pricing. Until co-development and Indigenous oversight extend across all program elements, including the subsidy, NNC's contribution to food sovereignty will remain limited.

4.5 Is NNC Helping Advance Food Sovereignty in Northern and Indigenous Communities?

NNC has strengthened food sovereignty and resilience in many northern and Indigenous communities. Through the HSG and CFPF, communities have expanded harvesting, food sharing, and local infrastructure, while co-development has allowed Indigenous governments and organizations to shape delivery. These results show that when communities are well-resourced and respected as leaders, innovative, adaptable, and culturally grounded food systems can flourish. Yet progress has been uneven, and barriers, such as capacity, infrastructure, and climate change, remain.

NNC measures food sovereignty by the share of median after-tax income needed to buy the Revised Northern Food Basket (RNFB) in each NNC region. Despite improved quantities of food shipped, the cost of food in NNC communities was still high. Community feedback corroborates these findings. Stakeholders across communities reported that while store shelves were better stocked, household purchasing power had not improved or even worsened in the current climate of inflation. The NNC Performance Information Profile states that the program aims to cut severe food insecurity by 5% by 2026, but no comprehensive data tracks changes at the community level. Studies have raised concerns about the effectiveness of NNC and existing food policies, given the persistently high rates of food insecurity.^{Footnote 20} These concerns reflect broader critiques of the current subsidy logic and the limited effect of market-based interventions on deep structural inequities.^{Footnote 21} In this regard, NNC must improve the way it measures medium and long-term indicators to clearly establish whether the program achieves reduction in food insecurity.

As previously noted, local food production has grown but remains limited and can be fragile to external factors. The most visible success has been harvesting and food sharing, which builds on longstanding traditional practices. Recipients share that HSG funding has improved food access and supported cultural practices and intergenerational learning. Communities consistently described HSG as the most empowering part of NNC, enabling them to define wellbeing on their own terms.

Some respondents note that these initiatives could also reduced stigma around food insecurity by enabling greater food sharing that aligns with traditional practices and supporting the creation of inclusive community spaces. Many communities paired harvesting with land-based education and cultural knowledge transmission, linking food systems to governance and identity. Interviewees emphasized that such programs support well being through nutrition, identity, and pride.

Indigenous leadership has expanded, but not across the whole program. HSG and CFPF reflect Indigenous priorities, and CIRNAC's piloting of oral and narrative reporting formats is one way the program can reduce barriers. But the subsidy remains outside Indigenous governance, limiting their authority over the largest part of NNC. While NNC governance advisory bodies include Indigenous representatives, they remain consultative, and decisions on subsidy design, list, and rates rest with the federal government.

Many interviewees noted that NNC's eligibility criteria exclude some communities that face food insecurity equal to or worse than NNC-eligible communities. The program's definition of "remote" may not match territorial or regional definitions. Examples include communities connected by train or road, but are far from population centres. In these cases, communities still face high prices or lack a local store altogether. In these cases, residents must travel hours to access a grocery store, at their own expense.

NNC has supported important gains in food sovereignty by enabling communities to lead harvesting, sharing, and cultural programs. Yet the foundation remains fragile. Lasting progress will require sustained investment in infrastructure and staffing, stable long-term funding, and extending co-development and Indigenous governance to the subsidy itself—with coordinated intergovernmental action to address the broader social, economic, and governance factors that shape food security and food sovereignty. Only then can NNC evolve from a program delivering subsidized food to driving systemic change rooted in self-determination and community-defined success.

4.6 Were There Any Surprises?

Harvesting, food-sharing, and education programs under the HSG and CFPF fostered cultural revitalization, youth engagement, and community cohesion. These activities became central to local concepts of food security. However, it was noted that due to difference in capacity, HSG/CFPF funding may have contributed to widening the gap between communities. For those that were able to efficiently and effectively put funding to use, they advanced progress on food sovereignty and security. Meanwhile, communities that were unable to utilize the funding could not progress at a similar pace. This indicates a need to work with recipient organizations to note where additional support may be needed for smaller or less well-resourced communities.

5.1 Have Changes to NNC’s Design and Delivery Better Met Community Needs?

Since 2019, Nutrition North Canada (NNC)'s design and delivery have become more flexible and community focused. The expansion of grant-based programs—the Harvesters Support Grant (HSG), Community Food Programs Fund (CFPF), and Northern Food Security Research Grant (FSRG)—has allowed communities to fund locally driven, culturally grounded initiatives. Informants widely agreed these changes better reflect Indigenous priorities and provide tools more responsive than the original subsidy model.

Subsidy reforms, such as the expansion of eligible establishments, sought to reduce dependence on a few large retailers and respond to long-standing recommendations.^{Footnote 14} However, uptake is uneven. Many eligible establishments were unaware they could participate or found the application and reporting requirements burdensome. This led some businesses, including Indigenous-owned stores in Attawapiskat, Sandy Lake, and Poplar River, to withdraw from the program. Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC) data shows that uptake among non-retail participants remained low in 2023, accounting for less than 3% of total volume.

The current subsidy approach uses historical rates that are uniformly increased. This has been criticized.^{Footnote 22Footnote 23Footnote 24} The rates lack transparency and community input, leaving many community members uncertain of how the rates were determined. Highly remote communities still face unaffordable food costs even with subsidies, leading many respondents to question why a dynamic subsidy approach has not been implemented, such as through the setting of target pricing ratios.^{Footnote 25}

The subsidy list was often raised as an area for improvement. While some community members felt that a targeted list would be more appropriate, others noted the importance of variety in order to serve those with specific dietary needs. There was broad support for extending the subsidy list to include harvesting equipment, such as bullets, which community members felt would better reflect a holistic and responsive approach to food security.

While Nutrition Education Initiatives (NEI)-funded activities have improved knowledge, skills, and partnerships, they are limited in scope due to resourcing. NEI did not undergo significant changes since the last evaluation.^{Footnote 26} However, it is operating within a changed program environment. All NNC eligible communities are eligible for NEI. Therefore, as the number of eligible communities have increased, it has stretched the NEI budget, which has remained unchanged since the program's debut in 2011. As with the HSG/CFPF, NEI's success in community depends on local capacity—particularly access to facilities, skilled staff, and stable funding. Additionally, it was noted that the overall visibility of the initiative is low, and many interviewees were unaware that NNC supported such programming in their communities. Nevertheless, across many communities there was an interest in greater programming around nutrition education and local food production. Some suggested bundling NEI with CFPF to improve coordination, streamline reporting, and increase funding to expand its reach.

Despite these limits, many communities saw important improvements in responsiveness. For example, HSG allowed local organizations to purchase harvesting equipment, freezers, and fuel storage, directly supporting access to country food. The CFPF funded school meal programs and Elder-focused initiatives that combined traditional and market foods. In Old Crow, funding supported land-based practices tied to cultural calendars; in Inuvik, Inuit organizations used CFPF for coordinated regional food initiatives, training programs, and new storage facilities. These examples highlight how co-developed funding streams have aligned with community priorities.

5.2 Does NNC Have the Right Governance in Place?

NNC has broadened and diversified its governance structures since 2017. Governance Advisory bodies now include the NNC Advisory Board, Indigenous Working Group (IWG), Inuit-Crown Food Security Working Group (ICFSWG), and the Women's Council, each bringing distinct perspectives to policy dialogue and strategic guidance.^{Footnote 27}

The IWG exclusively focuses on NNC and was instrumental in shaping the HSG, CFPF, and FSRG, with representatives from:

• Dene Nation;
• Sahtu Dene Council;
• Tlicho Government;
• Prince Albert Ground Council;
• Four Arrows Regional Health Authority;
• Nishnawbe Aski Nation;
• Vuntut Gwitchin First Nation; and
• Nunatukavut Community Council.

The ICFSWG is a body of the Inuit-Crown Partnership Committee, co-chaired by Inuit Tapiriit Kanatami (ITK) and Indigenous Services Canada (ISC), and advances Inuit-specific food security priorities, that inform NNC's work. The Women's Council brought gender-informed, culturally grounded perspectives to policy design. Internally, the Horizontal Initiative Oversight Committee—once the high-level governance body for NNC—has been absorbed into the Arctic and Northern Policy Framework's governance structure. The NNC Advisory Board consists of 5-7 members serving 3 year terms, appointed by the Minister of Northern Affairs for their experience living and working within the NNC delivery area. Members apply for the position and serve as individuals, and not representatives of an organization. They are mandated to provide strategic advice to the Minister, and while their informal approval of changes to the subsidy – such as additions to the list of eligible items – provide some degree of community control, they do not have decision-making authority over the program.

These mechanisms show expanded inclusion but remain limited in authority. All governance bodies are advisory only, without decision-making power over program budgets, priorities, or rates.^{Footnote 28} Many members said it was unclear how their input was used, since federal departments are not required to respond to or publish outcomes of what is achieved through the Advisory Board, leaving unclear how their input affects final program direction. Advisory bodies provide space for dialogue but not accountability, leaving communities uncertain whether their concerns are reflected in decisions.

NNC's governance structures face challenges of siloed delivery and coordination across program components. Interdepartmental coordination—once supported by the Horizontal Oversight Committee—now relies on informal working-level tables with no public mandate or documented link to NNC's governance advisory bodies. Although meetings occur regularly, there is no formal mechanism for governance input into joint planning, and program officers reported limited collaboration between CIRNAC, ISC, and Public Health Agency of Canada (PHAC).

Some communities recommended publishing decisions linked to advisory recommendations, listing member affiliations, and creating clearer feedback loops so communities could see how their voices shape policy. Interviewees stressed that meaningful governance in Indigenous food systems requires moving beyond consultation and supported formal accountability mechanisms to shift program governance towards shared authority.

5.3 Is NNC Working with the Right Partners in the Right Ways?

NNC has expanded consultation mechanisms since the last evaluation, particularly through the IWG and ICFSWG. These bodies have provided more consistent input from First Nations and Inuit partners and reflect a stronger commitment to distinctions-based co-development and collaboration.

Engagement with national and regional Indigenous organizations has improved, and Indigenous inclusion has grown. Yet influence varies—Métis participation has been inconsistent, regional differences are not always addressed, and community-level involvement remains limited. Many local retailers and residents reported little direct contact with NNC, uncertainty about their representation, and often do not know if their input is acted on. Communities called for regional roundtables or liaison roles to bridge the gap between national engagement and local realities.

Partner engagement has shaped newer elements like the Harvesters Support Grant (HSG) and CFPF, as well as changes to subsidy eligibility and communication materials. But input into the subsidy—the largest part of NNC—remains limited.

Coordination across federal departments and partners remains limited. While CIRNAC, ISC, and PHAC collaborate, to some extent as horizontal partners, other federal departments affecting food security—such as those mandated to address housing, transportation, and economic development—are not consistently involved. Provinces and territories play major roles in income supports and infrastructure but have no formal mechanism to align their efforts with NNC.^{Footnote 14}

NNC has broadened partnerships and strengthened national dialogue. Moving forward, strengthening community-level engagement could support trust and transparency. Additionally, the program would benefit from greater co-ordination with other relevant programs across governments to develop a far-reaching, holistic approach to Northern food security. As work is done to support poverty reduction, strengthen infrastructure, and improve transportation in the North, existing limitations posed to NNC programming will also improve, allowing the program to see greater impacts.

5.4 Is NNC Measuring What Really Matters?

NNC's current performance measurement framework does not fully reflect how the program achieves impact. While new indicators have been introduced since 2019, the system remains heavily focused on operational outputs such as shipping weights and compliance reviews, rather than outcomes like affordability, food quality, or cultural relevance. This limits its usefulness for accountability and learning.

For the program's first immediate outcome—"residents in eligible communities have access to nutritious, perishable foods that are shipped by air at a subsidized rate"—the primary indicators focus on shipping weights and completion of compliance audits. While these measures can demonstrate an improvement in affordability, respondent questions whether these measures meaningfully address affordability, and cultural responsiveness. The 2021 Auditor General report concluded the department could demonstrate progress on food accessibility, but not on affordability.^{Footnote 29}

The second immediate outcome—"strengthened data availability and data quality"—is measured by the number of communities participating in funded research. While this supports Indigenous-led projects, the data is often not standardized, timely, or integrated into program monitoring, and does not address persistent gaps in retail performance and subsidy effectiveness.

For the ultimate outcome—"northern and Indigenous communities are resilient to changing environments and food sovereignty is strengthened"—the main measure is food expenditures as a percentage of median after-tax income. While a useful metric, this indicator is focused on market foods, and does not present a complete picture of how the program supports resilience and food sovereignty.

Broader gaps in data and indicators persist. Many communities and partners called for co-developed indicators reflecting Indigenous concepts of wellness, cultural connection, and land-based food systems. They also called for regionally tailored monitoring and more flexible reporting formats, such as oral or video submissions which can better reflect Indigenous knowledge and values.

6.1 Is NNC Managed in a Way That Maximizes Efficiency and Value for Money?

There is high administrative burden for both program officials and recipients. For the subsidy, retailers and suppliers experience reporting burden. Retailers submit large volumes of detailed monthly and quarterly data, which staff must review and validate. This workload has increased with the expansion of eligible communities and suppliers. For smaller retailers, data submitted is often unreliable and requires significant program support to correct. Backlogs are common, and enforcement tools are limited, as withholding the subsidy from retailers may go on to negatively affect communities, through such potential outcomes as sharp increase in price or the withdrawal of retail operations. The reporting burden is heavier for smaller retailers with less capacity, and it can discourage direct participation in the program. Several informants recommended more automated validation systems, such as replacing the general subsidy list with a Universal Product Code (UPC) database to increase efficiency.

The HSG and CFPF reporting format was co-developed with the intent to minimize reporting burden. However, recipients were not always able to respond effectively within the existing format. Although reporting extensions were often granted when recipient organizations faced delays, they slowed delivery. In 2022–23, 10 of 28 grant recipients sought extensions or clarification.

Delivery is also fragmented across components. The HSG, CFPF, Nutrition Education Initiatives (NEI), and Northern Food Security Research Grant (FSRG) each operate under different timelines, reporting requirements, and procedures. While this allows tailored delivery, in instances where the recipient organization is the same for multiple grants it can be inefficient. Key informants suggested potential improvements, such as a shared intake portal, modular templates, and unified management systems to consolidate program information.

From the community perspective, longer funding cycles and reduced reporting burden would be beneficial. Many stated that longer multi-year agreements would reduce administrative costs and provide the stability required for long-term planning.

Recipients also stressed the need for capacity-building support. Communities with limited administrative infrastructure often struggle to manage grants or meet reporting requirements. Interviewees called for technical assistance, training, and more flexible timelines Without such support, smaller communities risk exclusion from funding opportunities, widening inequities.

Strengthening administrative systems, streamlining reporting, and embedding capacity supports will be essential for Nutrition North Canada (NNC) to maximize efficiency and value for money.

6.2 Is NNC Using the Best Approach to Set and Adjust Subsidy Rates?

As mentioned throughout the report, NNC continues to use a fixed-rate model to determine subsidy levels, carried forward from the Food Mail program. Each eligible community receives a set per-kilogram rate by category of goods. While this system is straightforward to administer, it is seen by some interviewees as not responsive to need and without a clear policy direction.

Rates have not been comprehensively reviewed since 2016 and are not indexed to inflation, freight costs, or supply chain complexity. They do not account for climate-driven changes to access routes, such as shorter ice road seasons, or for rising energy, labour, or infrastructure costs. Rates may be raised on an ad-hoc basis when funding capacity allows for it. This leaves the most remote communities struggling even after subsidies are applied, particularly in smaller, lower-income communities where retail competition is minimal.

Moving toward a transparent, responsive, and participatory approach—anchored in affordability benchmarks, clear policy direction, and culturally relevant measures—will be critical for NNC to demonstrate that subsidy rates are truly making nutritious food more affordable in the North.

6.3 Are There Similar Programs, Policies, or Initiatives in Other Jurisdictions?

NNC's focus on food security in isolated northern communities does not duplicate other federal programs, but it operates within a much larger landscape of overlapping initiatives. Federal, provincial, territorial, regional, and Indigenous governments all deliver programs that share NNC's objectives of improving access to nutritious food and advancing culturally grounded food systems. The challenge is that most of these programs function in isolation, with separate planning, funding, and reporting processes.

Internally, it is notable that prior to program expansions, NEI represented the only community-determined aspect of the program. The more recently added CFPF and HSG programs complement the NEIs well, where the NEI objective is focused on health promotion - which is in alignment with the food utilization dimension (PDF) of food security - rather than food sovereignty. For example, HSG supports hunting and harvesting activities by funding hunting equipment and supplies, while NEIs focus on food skills initiatives such as Elder teachings and hands-on workshops for preparing and preserving traditional foods. HSG supports this work through the lens of local food production, whereas NEI through the lens of health promotion, chronic disease prevention, and nutrition education. However, the small amount of NEI funding places significant limitations on the scope of activities that can be funded.

At the federal level, NNC aligns with the Food Policy for Canada and the National School Food Policy, both of which emphasize Indigenous-led delivery and traditional food systems. Other departments also fund food-related initiatives. Agriculture and Agri-Food Canada's Local Food Infrastructure Fund supports greenhouses and cold storage, but without a shared intake process or harmonized reporting. During the evaluation period, many community members noted Jordan's Principle and the Inuit Child First Initiative funding, which was used in some cases to fund food vouchers or school food programs for families with children. Although these initiatives reinforce NNC's objectives, they are not coordinated, leaving communities to juggle multiple applications and reporting requirements.

Provincial and territorial governments also run programs with similar aims. Examples include Manitoba's Affordable Food in Remote Manitoba program, Newfoundland and Labrador's Aboriginal Nutritional and Artistic Assistance Program, and Nunavik's regional subsidy for staples combined with prenatal supports. Other examples include the Northwest Territories' Take a Kid Trapping program and Yukon's Local Food Strategy (PDF) and Yukon Grown Program, both of which promote sustainable agriculture and food sovereignty. While effective locally, these initiatives rarely connect with NNC, creating a patchwork rather than a system.

Indigenous-led models demonstrate alternative approaches that integrate food access, sovereignty, and cultural revitalization. Inuit Tapiriit Kanatami (ITK)'s Inuit Nunangat Food Security Strategy envisions a sustainable Inuit food system and seeking $100 million in federal investment to support the implementation of the strategy.^{Footnote 7} Regionally grounded strategies—such as the Nunavik Regional Board of Health and Social Services' Nunavik Food Guide or the Government of Nunavut's Makimaniq Plan (PDF) poverty-reduction framework—demonstrate strong local leadership and tailored responses to food insecurity, especially in Inuit regions.^{Footnote 30}

In Nunavik and Nunatsiavut, Inuit organizations run harvesting programs, community freezers, and subsidies that directly support country food and reinforce self-reliance.^{Footnote 31} In British Columbia, the Indigenous Food Sovereignty Grant combines agriculture and land-based practices.^{Footnote 32} In northern Manitoba, the Northern Manitoba Food, Culture and Community Collaborative provides flexible, low-barrier funding for harvesting and food knowledge-sharing, with relationship-based accountability and culturally relevant reporting.^{Footnote 33} These examples show that Indigenous-led systems are often more holistic and responsive than federal programs, but they remain disconnected from NNC.

Interviewees consistently described this fragmentation as inefficient and burdensome. Communities must navigate multiple, unaligned funding streams for harvesting, infrastructure, education, and health, often with limited staff to prepare proposals and reports. Similar activities may be funded by several departments, each requiring separate monitoring and evaluation. This not only drains local capacity but also limits learning across programs, since outcomes are tracked differently.

Respondents recommended moving toward a more integrated, distinctions-based approach. Suggestions included coordinated intake processes, aligned reporting tools, and shared outcome frameworks across federal, provincial, territorial, and Indigenous programming. Many argued that Indigenous-led governance models should be at the center, with governments aligning their investments under these structures rather than requiring communities to adapt to multiple external systems.

NNC must be understood as a part of a larger policy and program environment. Improving coordination and mapping a holistic food security strategy for the North would increase efficiency and impact. Informants recommended that CIRNAC convene intergovernmental and Indigenous partners to co-develop a shared food systems performance framework for the North, with common indicators, reporting tools, and data-sharing agreements. Such a framework could improve accountability, reduce administrative burdens, enable cross-program learning, and support long-term planning—particularly for communities served by multiple funders.

7.1 Is GBA Plus Reflected in How NNC Is Designed and Delivered?

Although Gender-based Analysis Plus (GBA Plus) is not formally integrated into Nutrition North Canada (NNC)'s logic model, design, or performance framework, it is often evident in how communities deliver projects. Local organizations frequently focus on women, Elders, caregivers, and youth, tailoring food-sharing or education programs to meet their needs. These practices show that equity considerations are embedded at the community level, even if not captured federally.

At the federal level, The Women's Council is currently the only governance body explicitly linked to GBA Plus. Composed of Indigenous and non-Indigenous members, it reviews Harvesters Support Grant (HSG) proposals and advises on gender-informed approaches. The Council has identified barriers to food security for Indigenous women and provided recommendations to improve access to country food and close affordability gaps. GBA Plus is not included in other areas like the NNC logic model, Treasury Board's Results Information System, or funding decision tools. Reporting requirements do not request disaggregated data. NNC officials acknowledged that NNC predates many of the government's current equity frameworks and has not been updated to reflect them.^{Footnote 34}

To embed GBA Plus more fully, suggestions included updating reporting templates with optional equity sections, providing guidance tailored to northern and Indigenous realities, and strengthening the role of governance bodies like the Women's Council in shaping program-wide policy. Communities also called for flexibility in how equity information is shared—for example, through oral or narrative reports that align with local practices.

7.2 How Did COVID-19 Affect NNC and Northern Food Security?

The pandemic amplified existing weaknesses and created new vulnerabilities. COVID-19 exposed and intensified long-standing problems in northern food systems and NNC's delivery structure. Travel restrictions disrupted seasonal harvesting, food sharing, and cultural practices, and the cancellation of school programs and closure of community kitchens further increased household vulnerability.

Freight delays, stock shortages, and price volatility were common. In some communities, staples such as flour, canned milk, and cleaning supplies were unavailable for long periods. Residents expressed frustration that shelves were bare even as prices stayed high.

NNC's internal operations were also strained. Staff shortages, remote work, and delivery slowdowns reduced its ability to respond quickly or maintain communication. Interviewees reported backlogs, slower payment cycles, and delays in technical support, particularly for new grant recipients trying to adapt plans or reallocate funds.

Despite disruptions, NNC adapted quickly, introducing measures to reduce hardship and increase flexibility: temporary subsidy rate increases, expanded eligibility for essential goods, administrative flexibilities for grants, and outreach to retailers and communities. The 2021 OAG audit found Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC) did not consult stakeholders before allocating the $25M emergency subsidy top-up, limiting its ability to assess impacts or adapt processes. This meant NNC missed opportunities to capture and share community-led innovations that could inform future preparedness.

COVID-19 demonstrated the value of flexibility, local control, and strategic investment. The pandemic highlighted how infrastructure deficits—limited freezer space, inadequate broadband, and lack of backup vehicles or generators—constrained local response. Some HSG recipients lacked storage for harvests, while others could not shift to home delivery because of staffing shortages or lack of vehicles. One-time COVID relief funds helped fill some gaps, prompting calls for ongoing investment in assets critical to food security resilience.

7.3 How Are Climate Change and Other External Pressures Affecting NNC?

Climate change is becoming a major stressor on northern food systems, disrupting both retail supply chains and traditional harvesting practices. These pressures are making freight less reliable, increasing costs, and weakening cultural continuity, yet NNC has not integrated climate risk or adaptation into its design.

Supply chains and infrastructure are increasingly fragile. Rising temperatures, permafrost thaw, shoreline erosion, and unpredictable freeze-thaw cycles shorten ice road seasons and make deliveries less predictable. Interviewees reported missed or delayed shipments that led to shortages, higher prices, and damaged perishables. In many communities, inadequate cold storage, airstrips, and docking facilities magnify these risks, while climate change accelerates infrastructure degradation and increases maintenance costs.

Traditional food systems are also under pressure. Environmental changes affect hunting, fishing, and harvesting, undermining safety, reliability, and transmission of Indigenous knowledge. In Nunavik, Hudson Bay freeze-up has been delayed by months, cutting off offshore hunting and creating dangerous travel conditions. In Tuktoyaktuk, shoreline erosion and habitat loss were reported. Elders and harvesters described thinning ice, unpredictable weather, and wildlife population changes requiring longer travel at higher costs, often beyond community capacity. In northern Ontario and Manitoba, wildfires destroyed harvesting areas and forced community evacuations, causing some to miss entire harvest seasons, limiting access to country food and disrupting food-sharing and knowledge transmission.

These impacts reduce both the availability of country food and participation in harvesting, particularly among youth and Elders. Several respondents stated that the costs of climate adaptation, such as extra fuel, equipment repairs, new safety measures, exceeded HSG support. Without adjustments, climate impacts threaten both nutrition and cultural resilience.

Interviewees and program staff called for a more adaptive, climate-responsive model. Proposals included dedicated funding for emergency harvest funds, equipment replacement protocols, and seasonal or regional top-ups tied to environmental risk. Others stressed the importance of incorporating Indigenous knowledge into climate adaptation planning. Retailers noted that often they take on the informal role of informing the program of major climate or weather related disruptions to their supply chains. Improved communication channels across communities, retailers, and Indigenous organizations may help systematize this process and ensure timely adaptation can occur.

Climate change and other external pressures are deepening food insecurity and exposing design gaps in NNC. Without structural reform, the program will remain vulnerable to predictable disruptions. Building resilience will require integrating climate risk into subsidy and grant design, investing in community infrastructure, and embedding Indigenous knowledge into adaptation strategies.

7.4 What Will Keep NNC Strong and Deliver Lasting Success

The long-term success of NNC depends on strengthening food systems rooted in community priorities, culturally grounded practices, and stable institutional frameworks. Across case studies, the most consistent gains came where communities had the resources and control to shape their own food systems.

Communities emphasized that infrastructure should not be treated as an add-on, but as a core program element, supported by flexible, predictable funding, ongoing maintenance, and equipment replacement. Multi-functional facilities, such as freezers that double as preparation sites or cabins used for both teaching and harvesting, were especially valued.

Capacity building is another critical factor. Even with flexible grants, some communities lacked the people, skills, or systems to sustain programs. Case studies in Island Lake and Neskantaga showed how staff turnover or poor infrastructure limited sustainability, while communities like Old Crow succeeded because of stable leadership and coordination. Respondents called for embedded supports such as regional liaison staff, onboarding resources, technical training, and peer-to-peer mentorship to strengthen local delivery.

Cross-community learning is also underdeveloped but highly valued. Many effective practices—shared logistics hubs, cooperative purchasing, intergenerational harvest-sharing—remain isolated rather than scaled. Communities recommended regional networks, knowledge hubs, and small grants to support exchanges. Such efforts would spread innovation and reduce duplication, while honoring Indigenous traditions of knowledge sharing.

Finally, success will depend on connecting NNC to broader structural solutions. Food insecurity is shaped by income, housing, transportation, education, climate, and governance. Communities stressed that NNC cannot succeed in isolation. Aligning with investments in these areas—through whole-of-government action and Indigenous-led governance—will be critical to sustaining progress. Canada is turning its attention to the Arctic and seeking to bolster Canadian sovereignty and strengthen the economy in the North with investments in infrastructure and development. Strengthening food security and First Nations and Inuit food sovereignty within that process is essential to ensuring the federal goal of a strong and prosperous North.

8.1 Conclusions

Nutrition North Canada (NNC) has achieved important progress since the last evaluation in 2020. Currently, this evaluation finds that while communities value the program and its newer components, fundamental weaknesses in governance, subsidy design, and coordination continue to constrain its impact.

The program focuses heavily on input-based accountability—tracking kilograms shipped, dollars spent, and compliance audits—rather than outcome-based accountability such as affordability, stability, and cultural relevance. Subsidy levels can be calibrated to support these goals, shifting accountability from internal mechanics to real-world food prices. This would provide NNC with a transparent, outcome-driven objective—making nutritious food more affordable—and give communities, Parliament, and the public a clear basis for evaluating impact.

The Harvesters Support Grant (HSG) and Community Food Programs Fund (CFPF) demonstrated that communities can design and deliver initiatives that restore harvesting, strengthen food sharing, and build cultural identity. These models show that Indigenous leadership produces outcomes that extend beyond nutrition to include well-being, governance, and resilience. However, issues with reporting data indicate that greater work can be done to co-develop a reporting framework that better works with Indigenous cultural practices. Communities used flexible grants to launch harvesting programs, provide school meals, support cultural mentorship, and build infrastructure. Yet persistent structural barriers and rising challenges, such as inflation and climate change, can erode impact. Communities continue to seek extended, predictable, long-term investment, to ensure that promising models can grow in the long term.

NNC has enabled meaningful progress. Flexible, distinctions-based programming aligned with reconciliation has advanced food sovereignty for many Indigenous communities. These successes demonstrate the program's potential when communities are trusted and supported as leaders. At the program governance level, while NNC's Indigenous governance bodies provide important input, there is a need to strengthen these bodies so they can function as formal decision-making authorities. This will further ensure that program direction and design is grounded in Indigenous-led governance.

Communities consistently stressed that food security cannot be solved by subsidies alone. Broader structural improvements in areas such as income support, housing, infrastructure, transportation, education, and climate adaptation are needed to sustain NNC's impact. NNC's design is increasingly outpaced by a rapidly changing environment. Climate change is shortening ice road seasons, degrading infrastructure, and increasing costs. Wildfires, erosion, and unpredictable weather are disrupting both retail supply chains and harvesting. Demographic change, shifting transportation patterns, and high living costs are reshaping needs. In this environment, food security solutions must be dynamic, collaborative, and holistic to achieve a more sustained impact.

The government's response to Northern and Indigenous food security would benefit from NNC being positioned within a broader federal strategy, recognizing that food insecurity is shaped by interconnected social, economic, environmental, and geopolitical factors. This strategy should be co-developed with Indigenous governments and align with frameworks such as the Arctic and Northern Policy Framework and could integrate income security, infrastructure, climate adaptation, health and education services, regulatory reform, supply chain modernization, and accountability systems.

NNC stands at a crossroads. It has shown that community-led approaches work, but for lasting success, the program must evolve into a strategic platform for Indigenous-led food systems, supported by predictable funding, streamlined administration, and stronger whole-of-government alignment.

8.2 Recommendations

NNC cannot solve food insecurity alone. Lasting solutions require coordinated action across Indigenous communities, all levels of governments and organizations, the private sector, and not-for-profits—anchored in integrated investment, shared responsibility, and co-governance.

The following recommendations target structural and operational challenges while leveraging emerging opportunities.

It is recommended that CIRNAC:

1. Embed NNC Within a Whole-of-Government Food Security Approach for the North
   1. Co-develop an approach that reflects the unique rights and priorities of eligible communities.
   2. Coordinate across Indigenous, federal, provincial, and territorial levels of government
2. Align the Subsidy to Deliver on Outcome-Based Affordability Targets
   1. Establish clear, measurable affordability targets for subsidized goods in collaboration with Indigenous partners, retailers, and pricing experts.
3. Advance Indigenous Leadership in the Governance of NNC
   1. Transition NNC toward shared decision-making and accountability with Indigenous partners across all core components.
4. Strengthen Transparency at the Community Level Through Collaborative Communication Mechanisms
   1. Transparency should be strengthened by working with Indigenous governments, regional bodies, and community organizations to enhance communication mechanisms.
   2. This could include creating a localized feedback system allowing for greater ongoing understanding of the unique circumstances of each community.
5. Continue Seeking Long-Term Investment in Community-Led Food Systems
   1. NNC should build on its success by seeking to expand long-term support for community-led food systems such as extending multi-year funding, reinforcing Indigenous governance and leadership.
   2. NNC should co-develop communication and reporting tools with Indigenous partners to strengthen performance measurement of HSG/CFPF.