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‐ ANAO Report No.10 2014–15 Administration of the Biodiversity Fund Program 19

23. The

merit assessments prepared by departmental and external assessors were undertaken broadly in accordance with the published guidelines and internal grant assessment plan, although for Round 1, in around one‐third of the assessments reviewed by the ANAO the assessors had not provided written comments in support of the scores awarded. The ‘normalisation’ process for applications where the assessor scores varied by more than 30 per cent was also appropriately undertaken and documented, although the basis for decisions to amend merit scores could have been better communicated to the decision‐maker.

24. The

role of the Moderation Group was to review the merit‐assessed applications and recommend projects considered suitable for funding, including ensuring: appropriate geographic distribution of projects across Australia; a balance of funding across program themes and project types; large and small scale projects; and appropriate representation of Indigenous groups. The moderation process was undertaken to help ensure the achievement of the Biodiversity Fund program’s overall objectives. While recognising the appropriate steps taken by the department to administer the moderation process, including probity oversight, the provision of additional information on the process in the grant guidelines for all funding rounds would have contributed to a more transparent assessment and selection process for applicants.

25. The

transparency of the decision‐making process in each funding round would have been enhanced had the Moderation Group ranked recommended applications in order of merit, rather than grouping them into ‘recommended’ and ‘reserve’ projects. 16 In addition, the department did not retain sufficient documentation to clearly explain the basis for its selection of 18 projects from the Round 1 ‘reserve’ list to be recommended for funding, in preference to other more highly‐ranked ‘reserve’ projects.

26. Applications

that were recommended for funding at the conclusion of the moderation process were then assessed for eligibility. As ‘threshold’ criteria, it is particularly important that eligibility criteria are clearly expressed in the grant guidelines, for agencies to have planned how eligibility assessments are to be undertaken, and for each assessment to be well documented. In this regard, Environment’s assessment of all the eligibility