‐
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ANAO Report No.10 2014–15 Administration of the Biodiversity Fund Program
69
which is generally a more detailed, time‐consuming and resource intensive
process merit assessment does not however generally assess the extent to
which eligibility criteria have been met.
4.30 While
Environment had developed an eligibility checklist to record its assessment
of each recommended project’s eligibility, the checklist did not include
all published eligibility criteria and, in any case, was not used by departmental
staff undertaking the assessment. As outlined in Chapter 3, the Grant
Assessment Plan and other materials for assessors did not provide sufficient
guidance for departmental staff tasked with undertaking the eligibility assessments,
such as whether a proposed project represented a ‘business as usual’
activity.
4.31 Environment
staff undertaking the eligibility assessment of recommended
applicants used a range of spreadsheets to record the outcomes of the
assessment for specific criteria, such as the applicant being a legal entity and the
proposed project including in‐kind contributions where the project was to be undertaken
on public land. Nevertheless, there was limited evidence retained by the
department to indicate that all of the published eligibility criteria had been assessed.
96
For example, to assess whether proposed projects had been previously
funded, or had outstanding reportsacquittals, Environment conducted
a review of its own records. However, there was no practical way for the
department to assess other elements of these criteria relating to whether the projects
had received funding from other sources, or had overdue reportsacquittals
from previous Australian Government funded projects.
4.32 Further,
while the internal and community assessors had been asked to indicate
whether they considered that proposed projects represented ‘business as
usual’ activities and would thus be ineligible for funding
97
, evidence was not
retained to demonstrate that Environment had followed up these comments or
otherwise assessed this criterion. In 21 out of the 64 Round 1 successful
applications reviewed by the ANAO around one‐third of the sample, at least
one assessor had indicated that they considered the proposed project may
represent a ‘business as usual’ activity. However, the evidence retained by the
96 Key eligibility criteria across the four rounds and the department’s assessment are outlined in
Appendix 2. 97
This was via a ‘Yes’ or ‘No’ response, with no further explanatory text requested from assessors.
ANAO Report No.10 2014–15 Administration of the Biodiversity Fund Program
70
department did not indicate that these comments were followed‐up and,
ultimately, no applications were assessed as ineligible against this criterion.
98
4.33 Overall,
Environment’s assessment of each eligibility criterion as outlined
in the Biodiversity Fund program’s grant guidelines was not sufficiently
robust or transparent. In particular, there was a need to: clearly define
all eligibility criteria in the published guidelines; improve guidance for departmental
staff on conducting eligibility assessment; and sufficiently document
the assessment of each eligibility criterion for each recommended application.
Recommendation No.1
4.34 To
strengthen the assessment of applicant eligibility under its grants programs,
the ANAO recommends that the Department of the Environment:
provides clear guidance in its grants framework regarding the need to
design eligibility criteria for grants programs that are clearly expressed
and able to be readily assessed;
emphasises
the importance of assessing all eligibility criteria in all grants
rounds conducted; and
retains sufficient documentation to evidence eligibility assessments.
4.35 Environment’s
response: Agreed. 4.36
The Department notes the need for eligibility criteria for grants programmes to
be clearly expressed and easily assessed by the Department and acknowledges that,
particularly in the early rounds of the Biodiversity Fund, this could have been improved.
4.37 The
Department has better articulated eligibility requirements in its current grants
rounds for example for the 25
th
Anniversary of Landcare Small Grants and the first
