Australian Government Grants News – April 2020 Edition

This April edition of Grants News provides a number of interesting articles on:

• Grants during COVID-19 – FAQs
• Update on the next Grants Community of Practice
• GrantConnect and COVID-19
• ANAO Audit Insights
• ACNC reporting extension
• DSS arrangements during COVID-19

Welcome to the April 2020 edition of Grants News. We hope that you find this edition full of useful updates.

The following advice provides a quick guide of key considerations for entities to aid the Government’s COVID-19 assistance efforts, as as points to consider when deciding whether to vary or terminate an existing grant opportunity.

Do you still need Guidelines for COVID-19 grant opportunities?

• Yes. Guidelines are required for all grants.
• We are prioritising urgent guidelines and responding in much less time than our usual timeframe.
• Rules for approval of guidelines still apply.
• A risk rating must be agreed between the entity, Finance AAU and PM&C for all grants.
  • This risk rating determines the approval process before publishing the guidelines.
• Grant opportunity guidelines must be published on GrantConnect.
• Finance can assist agencies to ensure that guidelines are appropriate for the current context and still meet the Commonwealth Grants Rules and Guidelines 2017 (CGRGs).

When is a one-off or ad hoc grant suitable?

• One-off or ad hoc grants can be used where a specific need is being met, often due to urgency or other unforeseen circumstance, and the grant is not available to a range of potential grantees or on an ongoing basis.
• Guidelines are required, but do not need the Finance Minister’s agreement to release.

Do we need to use the Grants Hub?

In-scope agencies must consult with the Grants Hubs about implementing grant activities.

• Hubs will help agencies, amongst other things, to:
  • design, implement and manage grants, including business processes and ICT supporting systems, and
  • provide a costing to include in the NPP.
    
    Both Grants Hubs are ready to assist entities to quickly on-board grants and will prioritise COVID-19 and Bushfire initiatives.
     
• Where the Hub and entity agree in writing (email) that Hub implementation is not feasible, entities should consult with their AAU about seeking a ‘deferral’ or ‘exemption’.
• A request for ‘deferral’ or ‘exemption’ is not required where:
  • the grant is a genuine one-off grant (see CGRGs); and
  • payments do not exceed $50,000 (GST incl) per grant; and
  • the grant is not associated with or funded out of program funding.

How do we vary or terminate existing Grant Opportunities or agreements?

A grant impacted by COVID-19 may be varied depending upon the circumstances of the grant, its policy authority and funding.

• Grants are made for the purpose of achieving Government outcomes whilst also assisting the grantee to achieve its objectives.

If a grant opportunity is open to receive applications, an addenda may be issued to alert stakeholders of changes to the process, including eligible activities, and provide fair and equitable access.

If the grant opportunity has closed and grants have been awarded, the guidelines and grant agreement will determine the flexibility available to alter the grant agreements.

Grants and the grant agreement may be varied, when:

• Some of the activities can be undertaken;
• All of the activities can be undertaken, but at a later point in time within the relevant financial period; or
• The grant can be redesigned where such re-design is still in accordance with the policy authority.
  
  Variations can be via letter, deed or Notice of Change – see templates and user guides on Finance grants website.

Grants and the grant agreement may be terminated, when:

• None of the activities under the grant can be undertaken; (NB: If terminated, any unspent monies etc can be recovered)
• All activities can be undertaken at a later point in time, and this is outside of the approved financial period; or
  • NB: in this circumstance it may be appropriate to consider requesting a movement of funds between financial periods rather than terminating the agreement.
• The grant cannot be redesigned within the current policy authority, the grant and agreement can be terminated or new policy authority sought.

How do we deviate from existing Grant Opportunity Guidelines?

• The CGRGs are largely principles based with some specific requirements, with examples where it may be necessary to deviate from what is in the grant guidelines, for example, the waiving of criteria, such as when a grant opportunity has closed but applications are still being assessed.
• Where it is necessary to deviate, officials should ensure that they have appropriate grants administration documentation and processes in place such as recording the rationale and decisions for changes.
  
  For example:
  • If intending to change the scope or type of activities to be undertaken; or
  • If assessing applications against a closed grant opportunity, document the rationale for waiving any criteria, changing the eligible expenses and activities; how the changes fall within the policy outcomes being sought; and how fairness and equity will be managed.
    
    It is better practice for changes to be agreed by the relevant delegate, accountable authority or Minister.
     
• The activities should continue to represent value with relevant money and any changes must be within the policy and legislative authority.

Officials are required to comply with the Public Governance, Performance and Accountability Act 2013 and CGRGs. Where there is any uncertainty, legal advice should be sought to ensure relevant requirements are met.

If you have any questions please contact the Grants team at grants@finance.gov.au.

Unfortunately due to the current COVID-19 crisis and social distancing requirements the Grants Community of Practice has been postponed.

However we are here to help. If you have questions or support with grants you can contact us at grants@finance.gov.au.

GrantConnect brings all Commonwealth grant opportunities for COVID-19 together in the one portal. In order to search for these opportunities please use the term ‘COVID-19’ in the grant opportunity title so that it may be used as the search term to identify all relevant grants, or use this COVID-19 search link.

Grant Opportunities are available from a number of agencies.

The Australia.gov.au website is regularly updated with the latest COVID-19 advice from government agencies and information on support for businesses and individuals.

For more information about GrantConnect, visit www.grants.gov.au or watch the video available on YouTube.

How to register for GrantConnect

Registering on GrantConnect is a simple three step process, when completed it will notify you of new opportunities and enable you to access information on GrantConnect.

1. Select ‘New User Registration’ (top right of screen)
2. Set up your preferences
   - Select from Categories, or provide Keywords within your area of interest
3. Activate the account
   - The link provided in the confirmation email must be actioned within 14 days or the account will be suspended.

Most importantly registration is free.

A timely edition of audit insights has been released by the ANAO which outlines key messages from Auditor-General reports which have examined the rapid implementation of government initiatives.

The focus is on key lessons learned from audits of past activities, which are likely to have wider applicability to the Australian Public Service as it supports the national COVID-19 pandemic response. Topics covered include risk management, governance, resource mobilisation, accountability and program oversight in the context of rapid implementation.

To view, please go to the ANAO website - https://www.anao.gov.au/work/audit-insights/rapid-implementation-australian-government-initiatives.

Due to the impact of the COVID-19 on charity operations, the Australian Charities and Not-for-profits Commission (ACNC) has granted a blanket extension to charities due to submit their annual information statement (AIS) between 12 March and 30 August 2020, until 31 August 2020.

The latest advice for charities, including information on charity meetings, reserves and fundraisers, as well as the ACNC approach to compliance during the COVID-19 crisis is on the ACNC website – acnc.gov.au/covid19.

The Department of Social Services (DSS) continues to operate as normal and functions such as administering grants continue. This includes continuing to accept and assess grant applications for the small number of grant opportunities currently open. DSS also continues to offer grant agreements and manage the grants already in place.

However, DSS is adapting its approach to the ongoing management of grants. This includes not pursuing current outstanding Data Exchange reporting or financial acquittals.

DSS also supports flexibility in the use of grants where funding has been provided to cover a workshop, event, travel or similar, which can no longer proceed due to current health advice. In this situation, funding may be used to cover non-refundable costs or the grant agreement may be extended to allow the event to be rescheduled and used as originally intended.

In the event that your organisation cannot operate either due to staffing impacts from Coronavirus (COVID-19), or your clients or customers have been impacted, DSS will work with you to consider other viable options. It is important that services are in place throughout this period, where possible, but also standing ready to operate when this period of uncertainty is over.

For further information please go to the DSS website – https://www.dss.gov.au/about-the-department/covid-19-information-and-support/information-about-covid-19-to-dss-grant-recipients.