‐
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
16 In the NATI, Round 2 and Investing in Tasmania’s Native Forests funding rounds, departmental
officers provided a ranked list of recommended projects as part of the briefing to the Minister.
ANAO Report No.10 2014–15 Administration of the Biodiversity Fund Program
20
criteria as outlined in the Biodiversity Fund program’s grant guidelines was
not sufficiently robust or transparent. In particular, the assessment of whether
a proposed project could be considered a ‘business as usual’ activity and
therefore not eligible for funding was not underpinned by: a clear definition
in the published guidelines for Round 1
17
; guidance for departmental staff on
conducting this assessment; or sufficient documentation of the assessment of
this eligibility criterion for each recommended application. In around one‐third
of the successful applications reviewed by the ANAO
18
, at least one assessor
had indicated that they considered the proposed project may represent a
‘business as usual’ activity, but the evidence retained by Environment did not
indicate that the department followed‐up this assessment and, ultimately, no
applications were assessed as ineligible against this criterion.
27. Once
the merit and eligibility assessment processes were complete, Environment
prepared generally appropriate information to support the Minister’s
the decision‐maker’s approval of grant funding. In relation to Round
1, the Minister was not, however, advised that the recommended list of applications
included a number of projects that had initially been identified by the
Moderation Group as ‘reserve’, or that these applications were not the most highly
‐ranked on the ‘reserve’ list. The department also notified the successful and
Kategori