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which it was not clear whether the component that was excluded was integral
to the project. In these cases, the assessor’s commentary was limited to the fact
that the component did not provide a ‘competitive dollars of grant funding per
tonne of carbon abated’ or did not contribute substantially to carbon savings.
3.31 As
discussed in paragraph 3.24, any judgement about whether a project provided
‘good value for money’ was necessarily subjective in the absence of well
‐founded benchmarks. As a result, the success of an application was ultimately
dependent on the skills and experience of the departmental assessor.
3.32 Considering
that some applications were reframed because they were identified
by the department as not likely to be ‘competitive’ if the assessment was
based on the application that had been submitted, the changes that were made
to these applications by departmental officials increased the likelihood that
applications were funded. However, the approach adopted by the department
was not consistently applied, highlighting the challenges to the department
in achieving equitable outcomes when providing advice as part of the
assessment of applications.
Innovation Australia Committee merit assessment
3.33 The
published program guidelines provided that IA must undertake a formal
merit assessment of all eligible applications. As with many committee arrangements,
this provided a mechanism to bring specific knowledge to the task
of assessing the merits of applications. In fulfilling this role, the Board of IA
delegated its authority for conducting merit assessments and preparing recommendations
for the decision maker to the IA committees.
101
3.34 The
active approach that was adopted by the departmental assessors in reframing
applications was also adopted by the IA committees, with a least five
per cent of applications considered by the IA committees reframed.
102
In this
respect, there were:
24 applications that were reframed to exclude eligible expenditure
items that did not provide value for money;
101 The CTIC was established in March 2012 and first met to consider applications in April 2012, the departmental committee was established in October 2012 and first met to consider applications in
December 2012 and the CTFFIC was established in October 2012 and first met to consider applications in November 2012.
102 There were 42 applications that were reframed by the IA Committees. In three of these cases, the applications were reframed because the IA committee members disagreed with the changes that had
been made to the application by the departmental assessor.
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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.
