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seven
applications that were reframed, but no clear reason was given; and
five
applications that were reframed to exclude ineligible expenditure.
Probity of requesting additional information and reframing applications
3.35 In
previous audits, ANAO has observed that, where a department has sought
to amend a selection process, probity advice has generally recommended
that assessment and selection documentation be amended to provide
for a transparent resubmission process. This includes allowing all applications
or a subset of applications that have been assessed and shortlisted as
meeting primary program objectives as reflected by all or the most highly weighted
merit criteria to revise and resubmit information.
3.36 For
example, in relation to the Building Better Regional Cities Program see
ANAO Audit Report No. 25 2013–14, an additional step was added to the application
and assessment process to allow all applications in a particular cohort
to be revised and re‐submitted.
103
In that program, the administering department,
in consultation with its probity adviser, decided that an addendum
should be added to the Assessment and Selection Plan for the program
to allow a resubmission process to be employed for all shortlisted applications.
Applicants were informed as to those elements of their application
that they were being invited to re‐submit, with departmental preferences
in terms of those responses that would be more favourably considered
in the merit assessment process clearly identified to each applicant that
was invited to re‐submit.
3.37 As
noted at paragraph 2.12, the department did not develop a probity plan
or engage a probity advisor for the programs. Further, the department did
not establish a similar approach to that observed in respect to the Building Better
Regional Cities Program, or similar arrangements, for seeking additional information
or reframing applications to the programs. In particular, the program
guidelines did not identify the circumstances under which the department
or the IA committees could seek additional information from
103 Those applications assessed and found to meet the program objectives, but for which some improvement in terms of the value for money criterion was sought.
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applicants
104
, including by soliciting improved proposals with respect to one or
more merit criteria. Such an approach was only adopted at the very end of the
program in relation to one particularly significant government policy
change.
105
3.38 In
September 2014, the department advised ANAO that it sees a distinction
between the role of the department as a facilitator to program access
and IA committees as assessors of merit. Specifically, the department advised
ANAO that: A
key part of the AusIndustry customer service function is to assist customers to
access government programs. This extends to advising customers on what they
can do to make it more likely that their application will be considered to be
competitive. It is the role of Innovation Australia to consider applications against
the merit criteria and make recommendations to the Program Delegate. This
process ensures that only the most meritorious applications are recommended
for funding. In the event that the Committee considered that the
application was not sufficiently meritorious, it would not be recommended for
funding. This is the appropriate process for ensuring that the Program outcomes
are maximised.
3.39 Consistent
with this advice, the departmental assessment process
106
focussed on increasing the likelihood that applications would be considered,
by the IA committee, to be ‘competitive’ against the merit criterion. However,
where an application as originally submitted was identified to have scored
sufficiently well
107
that it was expected to be recommended for funding, the department
did not examine whether reframing could lead to a more meritorious
project being undertaken.
104 As discussed in paragraph 3.10, one of the ways in which the program guidelines demonstrated this was through clear advice to applicants that incomplete applications would not be assessed.
