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ANAO Report No.11 2014–15 The Award of Grants under the Clean Technology Program
57
departmental
committee—low‐risk grants under 300 000. This committee
consisted of members from the program management area and
manufacturing policy area of the department and also included managers
from AusIndustry’s State Office Network and officers with responsibility
for the delivery of the programs;
CTIC—general investment applications up to a maximum value of
5 million. This committee consisted of six members who had
experience in manufacturing or engineering and business
administration, two members who had experience in clean technology
and one member who had experience in clean energy and carbon
efficiency; and
CTFFIC—food
and foundries applications up to a maximum value of 5
million. This committee consisted of five members who had experience
in manufacturing or engineering and business administration,
two members who had experience in energy and carbon
efficiency and one member who had experience in clean technology.
2.43 While
the members of the IA committees were not employees of the department,
the functions they were responsible for performing carried specific
record keeping obligations. In this context and as outlined in the CGGs and
ANAO’s Grants Administration Better Practice Guide, where the advice provided
by a committee directly informs a decision about expenditure—for example,
where the committee assesses applicants against particular criteria, andor
recommends supporting particular projects or distributing funds to particular
applicants—committee members are officials of the relevant agency.
70
Importantly, where advice and recommendations received from a panel
are intended to be relied upon by a decision‐maker in forming a view on the
merits of providing grant funding, the assessment of applications and funding
recommendations of the panel should be formulated in a manner that is
consistent with the program guidelines. This provides a sound basis for the
70 Committee members were considered officials because the provision of such advice constituted the
performance of a financial task within the meaning of FMA Regulation 3. Persons performing financial tasks are deemed by operation of part 5 of the FMA Act and Regulations 41a, 42 and 51b to
be officials of the relevant agency. In respect to the Program, IA committees were responsible for undertaking the merit assessment of eligible applications against the published merit criteria and,
accordingly, performed a task or procedure relating to the commitment of public money. In reference to the current grants framework, committee members are considered to be officials under section 13 of
the PGPA Act.
ANAO Report No.11 2014–15 The Award of Grants under the Clean Technology Program
58
departmental decision‐maker concluding that a recommendation to approve
funding is consistent with the program guidelines as a policy of the
Commonwealth as was required by FMA Regulation 9.
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Assessment of applications by the departmental committee
2.44 The
creation of the departmental committee assisted with the management
of the workloads for the CTIC and the CTFFIC. This arrangement,
however, meant that a number of merit assessments were undertaken
by the department rather than IA, as described in the program and customer
guidelines, such that specialist knowledge was not brought to bear in the
assessment of applications.
2.45 As
shown in Figure 2.3 on page 63, 345 applications 41 per cent were assessed
by the departmental committee. In 75 per cent of these assessments, the
departmental committee agreed with the score provided by the departmental
assessor. By way of comparison, the CTIC and the CTFFIC agreed
with the score allocated by the departmental assessor in 18 per cent of cases.
Given that IA had a role in providing specialist knowledge in the assessment
of applications, the use of a different arrangement did not allow for the
specialist knowledge that was available to be applied. As a consequence, the
transparency of the assessment process was reduced for applicants and the knowledge
applied differed across applications.
Documentation retained to support recommendations
2.46 The
procedures manual set out the role of departmental officials in assisting
the IA committees with the final merit assessment. This included compiling
an ‘application deck’, which included the departmental assessment report,
the submitted application and other relevant supporting documentation.
The application deck was intended to provide committee members
with ‘the core documents needed to review and assess the application’
and was only to include information ‘that is necessary and sufficient
for the committee to make an informed decision’.
2.47 While
the department developed a scoring framework to be used in the departmental
assessment that was presented to the IA committees, the
71 Up until 30 June 2014, this obligation was provided for under FMA Regulation 9. From 1 July 2014,
this obligation was provided for under section 21 of the PGPA Act, which requires accountable authorities to govern in a way that is not inconsistent with the policies of the Australian Government.
