Department of Finance

RMG-412: Australian Government Grants – Briefing, Reporting, Evaluating and Election Commitments

Australian Government Grants – Briefing, Reporting, Evaluating and Election Commitments

Resource Management Guide No. 412

JUNE2018

© Commonwealth of Australia 2018

ISBN: 978-1-925537-20-8 (online)

With the exception of the Commonwealth Coat of Arms and where otherwise noted, all material presented in this document is provided under a Creative Commons Attribution 3.0 Australia () licence.

The details of the relevant licence conditions are available on the Creative Commons website (accessible using the links provided) as is the full legal code for the CC BY 3 AU licence.

Use of the Coat of Arms

The terms under which the Coat of Arms can be used are detailed on the following website: .

Contact us

Please direct questions or comments about the guide to:

Resource Management Branch

Department of Finance

1 Canberra Avenue

Forrest ACT 2603

Email:

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The words ‘must’, ‘required’, ‘requires’ and ‘requiring’ denote mandatory compliance by accountable authorities/officials. The use of the words ‘could’, ‘may’, ‘encouraged’ or ‘consider’ convey non-mandatory guidance. The guidance to which these words relate may or may not be applied by accountable authorities/officials in their approach to resource management, depending on the operating circumstances of the entity and its appetite for risk.

Contents

Australian Government Grants – Briefing, Reporting, Evaluating and Election Commitments

Audience

Key points

Resources

Introduction

Part 1 – Briefing Requirements for accountable authorities and officials

1.1 Documenting decisions

1.2 Grants administration through hubs

1.3 Briefing Ministers

Part 2 –Ministers’ Reporting Requirements

2.1Ministers’ grants reporting obligations

2.2‘Report once, use often’

Part 3 – Evaluation requirements

Part 4 – Election Commitments

Attachment A – Checklist for officials briefing ministers on proposed grants

Attachment B – Template – Grants awarded in Minister’s own electorate

Attachment C – Template – Annual ministerial report where a minister has approved a grant that the relevant officials recommended be rejected

Appendix 1 – Glossary

Audience

This guide is relevant to accountable authorities and officials involved in grants administration in all non-corporate Commonwealth Entities (Entities)[1].

Key points

This Resource Management Guide (RMG) provides guidance for accountable authorities and officials on briefing requirements that apply to grants administration. It also includes other guidance to assist with implementing the Commonwealth Grants Rules and Guidelines 2017 (CGRGs) and provides detailed technical information in the attached templates.

It reflects the resource management framework under the Public Governance, Performance and Accountability Act 2013 (PGPA Act). The CGRGs are issued by the Finance Minister under section 105C of the PGPA Act.

This guide replaces Resource Management Guide (RMG) 412 (dated 2014): Australian Government Grants – Briefing and Reporting.

Resources

This RMG is available on the Department of Finance website at .

Other relevant publications include:

  • Commonwealth Grants Rules and Guidelines 2017
  • RMG No. 411: Grants, Procurements and other financial arrangements
  • RMG No. 421: Publishing and reporting Grants and GrantConnect.
  • RMG No. 415: Procurement and Grants Connected Policies
  • GrantConnect Entity Implementation Guide

Should you have any questions regarding this guide, please contact:

Grants Policy Team email:

Introduction

1.The objective of grants administration is to promote the proper use and management of public resources through collaboration with the non-government sector to achieve government policy outcomes.

2.Grants administration encompasses all the processes undertaken by entities and can be described through the grants lifecycle (see paragraph 2.8 of the CGRGs):

  1. design of grant opportunities and activities, such as:
  • planning
  • defining objectives and determining desired outcomes
  • identifying, managing and mitigating risks, and
  • collaborating with government and non-government stakeholders
  1. assessment and selection of grantees, including:
  • compliance with eligibility requirements
  • assessment of grant applications (where applicable), and
  • decision making
  1. the establishment of grants, such as:
  • making of a grant
  • developing the grant agreement (where applicable) – based on the whole-of-government grant agreement template suite and
  • finalising the grant agreement with the potential grantee
  1. the ongoing management of grantees and grant activities, such as:
  • stakeholder management and managing grant agreements
  • monitoring grantee performance and compliance with the grant agreement
  • managing risks and issues, and
  1. evaluation of grant opportunities and activities, such as:
  • review of individual grantees or grants, and
  • evaluation of the grant opportunity against the desired policy outcomes and any performance indicators.

3.In addition to the guidance contained in this RMG, there are tools and templates attached for officials to assist them to comply with the briefing requirements in the CGRGs, the PGPA Act and to assist with promoting the proper use of Commonwealth resources. These tools are aids and are not designed to capture each particular circumstance.

  • Attachment A provides a checklist for officials briefing ministers on proposed grants.
  • Attachment B provides a template letter for reporting on grants awarded in a Minister’s own electorate.
  • Attachment C provides a template for the annual ministerial report where a minister has approved a grant that the relevant entity official recommended be rejected.

Part 1 – Briefing Requirements for accountable authorities and officials

4.Accountability arrangements in grants administration relate to both the processes of grants administration, including grants allocation processes and ongoing grants management as well as the achievement of Government policy outcomes.

5.Ministers, accountable authorities, officials and grantees all have their respective roles to play in achieving specific government policy outcomes and should be held accountable for the manner in which they fulfil these roles.

1.1 Documenting decisions

6.The CGRGs()contain a number of provisions regarding documenting decisions or recording the basis for certain decisions, for example:

  • Officials must establish and document whether a proposed activity is a grant prior to applying the CGRGs[2] (see paragraph 4.2, CGRGs)
  • Where an accountable authority or official approves the proposed commitment of relevant money in relation to a grant, the accountable authority or official who approves it must record, in writing, the basis for the approval relative to the grant opportunity guidelines and key consideration of value with relevant money (see paragraph 4.5, CGRGs).
  • Where a method, other than a competitive merit-based selection process is planned to be used, officials should document the decision and recordwhy a different approach will be used (see paragraph 11.5, CGRGs).

7.Officials should develop policies, procedures and documentation necessary for the effective and efficient governance and accountability of grants administration(see paragraph 12.4 of the CGRGs). Documented internal procedures and associated operational guidance assist in guiding each aspect of the grants lifecycle and support sound administration of grant opportunities and grant activities. They can also assist with setting out processes for documenting decisions to meet the requirements in the CGRGs. It is important that internal procedures and operational guidance are developed prior to the commencement of a grant opportunity or program and are reviewed and maintained over the grants lifecycle. For example:

  • Officialsshould develop appropriate risk management frameworks and procedures
  • Risks should be reviewed and managed throughout the grants lifecycle to minimise the impact of risks developing into issues
  • Issues management policies and procedures should be clearly documented
  • Decision makers should be appropriately and consistently briefed on risks as they eventuate throughout the grants lifecycle
  • Officials should establish grants assessment and negotiation processesthat are consistent with the published grant opportunity guidelines
  • Decision-makers should be provided with clear, consistent documentation outlining the processes and recommendations of a grant opportunity
  • Officials should develop consistent processes to commit relevant money for grants programs
  • Officials should provideclear and accessible feedback and complaint mechanisms for stakeholders
  • Processes and documents should be standardised where practicable.

8.Processes for keeping accurate and complete records are important not only to inform and support the outcomes of assessments but also to:

  • form the basis for developing appropriate and complete advice to decision-makers, and
  • provide feedback to applicants, (see paragraph 13.2 of the CGRGs).

1.2 Grants administration through hubs

9.When developing policy proposals, entities should seek to leverage whole-of-government initiatives. Entities should make the best use of existing entity structures, business processes, and ICT architecture that is compatible with relevant whole-of-government strategies and the Government’s Digital Transformation Agenda.

10.The Government has established the Streamlining Government Grants Administration (SGGA) program, under which participating entities are required to consume grants administration services from one of the Community or Business Grants Hubs.

11.Entities that consume grant administration services from Hubs should clearly advise their Minister on which services have been delivered by a Hub,how these services have informed decision-making bythe entity, and any recommendations for Ministerial approval.

12.Consuming grant administration services from a Hub does not reduce accountable authorities’ responsibilities under PGPA Act. Further information on the responsibilities of accountable authorities as part of these arrangements is available via the Shared Services Arrangements Guide 04/2017: Governance (Assurance) Framework – available from .

1.3 Briefing Ministers

13.Accurate, complete and timely advice to decision makers assists Government to achieve the policy outcomes of a grant opportunity and value with relevant money (refer below).

14.The CGRGs also require that Ministers must not approve a grant or group of grants without first receiving written advice from officials on the merits of the grant or group of grants. That advice must meet the requirements of the CGRGs (see CGRGs paragraph 4.6). Officials can refer to Attachment A, which outlines the minimum briefing requirements and provides a checklist for officials to use when preparing advice where Ministers are approving grants.

  • The CGRGs provide that when briefing Ministers on the application and selection process followed, for demand driven selection processes, the advice should include how the grant allocation method was developed, explain how implementation issues were considered and outline the risk mitigation strategies. Officials may consider providing similar information for other grant selection processes, when briefing Ministers.

15.Entities may seek advice from committees comprised of external representatives (external committees). For the purposes of briefing Ministers, recommendations from external committees can be provided (either directly or through the department), so long as the briefing includes information noting which applications:

  • Fully met the selection criteria;
  • Partially met the selection criteria; and
  • Did not meet the selection criteria.

16.Ministers must also record, in writing, the terms and basis for the approval of the grant, relative to the grant opportunity guidelines and the consideration of value with relevant money.In addition to the requirements in the CGRGs, there are further requirements in section 71 of the PGPA Act.

Part 2 –Ministers’Reporting Requirements

2.1Ministers’ grants reporting obligations

17.When briefing Ministers in their role as an approver, officials must provide information on the applicable requirements of the PGPA Act and Rule and the CGRGs, including the legal authority for the grant (see paragraph 4.6.b,of the CGRGs).

18.Officials must advise their Minister on whether a grant will provide for activities in the Minister’s own electorate. This must be identified in the brief to the Minister when advising on grants approval options, in line with the minimum briefing requirements.

19.Paragraphs 4.11 and 4.12 of the CGRGs contain specific requirements for Ministers where they approve grants in their own electorate and where they approve grants that are not recommended by the relevant officials.

20.Paragraph 4.11(a) provides that where a Minister (including an Assistant Minister) approves a proposed grant in his/her own electorate, the Minister mustwrite to the Finance Minister advising of the details. To assist with this requirement, Attachment B provides a template letter.

21.Paragraph 4.12(a) provides that Ministers (including Senators) must report annually to the Finance Minister on all instances where they have decided to approve a particular grant which the relevant official has recommended be rejected. The report must include a brief statement of reasons (i.e. the basis of the approval for each grant). The report must be provided to the Finance Minister by 31 March each year for the preceding calendar year.

  • The information that should be included in the annual report to the Finance Minister is outlined at Attachment C.
  • ‘Report once, use often’

22.The CGRGs do not mandate any reporting requirements for grant recipients. However, appropriate performance and other information from grant recipients is important to achieving government policy outcomes. It can help evaluate whether a grant opportunity has achieved the desired results and achieved value with relevant money.

23.Officials should apply the ‘report once, use often’ and proportionality principles when designing grants application and reporting requirements. Officials should not seek information from grant applicants and grantees that has already been provided to an Australian Government entity and is available to officials. Officials should only seek information where it is necessary to assist them to properly administer or evaluate the grant.

24.Wherever possible, officials should seek to reduce/consolidate the amount of information requested from grantees. Officials may consider how standardising grantee reporting across multiple grant agreements can reduce the administrative burden on grantees.

25.If an organisation is registered with an Australian Government regulator, then a financial acquittal should not be required, unless the activity is high risk. Box 1 provides an example of an Australian Government regulator. Officials can still seek a declaration or certification from the grantee that the grant was spent for the purposes specified in the grant agreement, as well as requiring them to identify any underspends. This does not affect the need for grantees to maintain financial and other records that would enable a review of financial information if required.

Box 1: Australian Charities and Not-for-profits Commission

The Australian Charities and Not-for-profits Commission (ACNC) is the independent national regulator of charities. The ACNC is working with state and territory governments (as well as individual federal, state and territory government agencies) to develop a ‘report once, use often’ reporting framework for charities.

The ACNC Charity Passport enables authorised government agencies to access ACNC charity data via a file transfer protocol (FTP) process for the purpose of reducing red tape for charities. By allowing agencies to access charity data directly from the ACNC, the Charity Passport reduces the amount of information that charities have to provide to different government agencies, in line with a ‘report once, use often’ reporting framework.

Charities registered with the ACNC have an ongoing obligation to report each reporting period. Charities report by submitting an Annual Information Statement and an Annual Financial Report (if medium or large in size).

Part 3 – Evaluation requirements

26.A key principle of grants administration in the CGRGs is an outcomes orientation. Paragraph 10.1 of the CGRGs notes that grants administration should be designed and implemented so that grantees focus on outcomes and outputs for beneficiaries, while seeking the most efficient and effective use of inputs. Accountable authorities and officials should focus on achieving government policy outcomes.

3.1Evaluation Strategies

27.Entities should adopt an early focus on evaluation, through developing an evaluation strategy during the design phase of the grants lifecycle. Evaluation includes establishing appropriate performance measures on which to evaluate individual grants and the grant opportunity program as a whole.

28.An effective evaluation strategy should support assessment of:

  • the continued appropriateness of the grant opportunity
  • the effectiveness of the grant opportunity (that is, whether the stated objectives have been achieved, and any barriers to success). Effectiveness indicators should demonstrate the effect to which grant activities have made positive contributions to the outcomes of the grant opportunity
  • if there would be a more efficient or effective way of achieving the Government’s policy outcome(s),and
  • whether the Government’s resources should remain allocated at current levels, be increased, reduced or discontinued.

29.It is important that published grant opportunity guidelines, other guidance (if applicable) and the grant agreement clearly outlines the nature of information expected to be collected and reported by grantees as part of an evaluation. A sound strategy would be expected to identify the:

  • performance measures
  • performance indicators
  • data sources intended to be used, and
  • methodologies to be appliedto analyse the data.

3.2Conducting the evaluation

30.The evaluation of individual grants is best achieved through specifying their reporting requirements, including performance measures, in grant agreements. This data is also a common source of information used to evaluate the overall grant opportunity, or broader grant opportunity program. In this respect, it is important that entities take steps to ensure that grantee data has been presented on a comparable basis for analysis. This may be through standardised reporting systems, or analytical work undertaken in the entity.

31.There are also benefits in considering additional data sources. Additional data sources, such as statistics from the Australian Bureau of Statistics, other government data references (including State/Territory data), or stakeholder data may be useful for an evaluation. Entities can use population-level data to ascertain if grant activities have achieved broader Government policy outcomes.