Ministers, accountable authorities, officials and grantees all have a role to play in ensuring there is accountability and transparency in grants administration.
The Commonwealth Grants Rules and Principles 2024 (CGRPs) outline a range of obligations for officials that include documenting decisions, record keeping and obligations relating to briefing the relevant minister when the minister is the approver of a grant. These obligations are intended to ensure that there is accountability and transparency in grants administration. The obligations relate to both the processes of grants administration, including assessing and selecting grantees and grants management, as well as to the achievement of Government policy outcomes.
See Obligations for ministers for further information.
Developing policies, procedures and guidance to support grants administration
Consistent with their obligations under the PGPA Act, officials should develop policies, procedures and documentation necessary for the effective and efficient governance and accountability of grants administration. These should support officials to act in accordance with the PGPA Act, PGPA Rule and the CGRPs.
It is important that officials develop internal procedures and operational guidance to guide each aspect of the grant process and support sound administration of grant activities. It is also important that these are reviewed and maintained over the grants lifecycle.
- Processes and documents should be standardised where practicable.
- Officials should develop consistent processes for the commitment of relevant money for grants programs.
- Officials should develop appropriate risk management frameworks and procedures.
- Risks should be reviewed and managed throughout the grants lifecycle to minimise the impact of risks developing into issues.
- Issues management policies and procedures should be clearly documented.
- Decision-makers should be appropriately and consistently briefed on risks as they evolve throughout the grants lifecycle.
- Grant assessment and selection, and grant agreement negotiation processes, should be consistent with the published grant opportunity guidelines.
- Officials should establish clear and accessible feedback and complaint mechanisms for stakeholders.
- Decision-makers should be provided with clear, consistent documentation to inform their decisions.
Documenting decisions and record keeping
Officials must ensure that appropriate records of decisions are kept.
The CGRPs contain several requirements regarding documenting decisions or recording the basis for decisions.
These include:
- establishing and documenting whether a proposed activity is a grant prior to applying the CGRPs
- documenting in the relevant grant opportunity guidelines the decision and the rationale for using a selection process other than a competitive merit-based process
- documenting decisions to deviate from published guidelines (including where it is considered necessary to waive or amend selection criteria)
- recording in writing the decision to approve a proposed commitment of relevant money for a grant, and the reasons for the decision by reference to the grant opportunity guidelines and the key principle of achieving value with relevant money.
Record keeping is important to good governance and accountability. Good record keeping by officials will assist in meeting accountability obligations, demonstrate compliance with the CGRPs and the resource management framework.
It will also form the basis for developing appropriate and complete advice to decision-makers and provide feedback to applicants.
Record keeping is vital to show due process has been followed in all actions and decisions.
Briefing ministers
Accurate, complete and timely advice to ministers where they are an approver of a grant or grants supports Government to achieve the policy outcomes of a grant opportunity and value with relevant money.
When a minister is the approver of a grant, officials must provide the minister with written advice. At a minimum this advice must:
- state that the spending proposal being considered is a ‘grant’
- set out the minister’s obligations under the PGPA Act and PGPA Rule and the CGRPs (including their obligations to report to the Finance Minister if they award grants in their own electorate or approve a grant that officials recommended be rejected)
- include information about the legal authority for the grant
- outline the selection process and criteria used to assess applications
- provide clear advice about the merits of the proposed grant/s relative to the grant opportunity guidelines and the key principle of achieving value with relevant money
- clearly indicate which applications fall into each of the following categories:
- fully meet the selection criteria
- partially meet the selection criteria
- do not meet any of the selection criteria.
Officials must:
- indicate which of the applications can be supported within the available funding
- recommend that applications that do not meet any of the selection criteria be rejected.
In addition, officials:
- should include any other specific recommendations that are appropriate, which may include recommendations based on other factors that the minister might consider as set out in the grant opportunity guidelines
- may rank applications, if appropriate.
Where entities have sought advice from external committees, their recommendations can be provided to the minister (either directly or through the department) if the external committee includes the 3 categories mentioned above.
Officials are encouraged to use the checklist for briefing the minister, available in the Grants Toolkit.
Examples
The examples below provide guidance on how to use the 3 categories and provide information to ministers as well as how rankings may be used.
Example 1: I have received 30 grant applications for a grant opportunity, and the minister is the approver of the grant. 10 of the applications have been assessed to ‘fully meet’ the selection criteria, 15 applications ‘partially meet’ the selection criteria, and 5 applications ‘do not meet’ any of the selection criteria. The grant opportunity only has funding to award 5 grants. What recommendations do I need to provide to the minister?
The CGRPs set out a range of information that you must provide to the minister (see above).
In addition, you must include a specific recommendation that the minister reject (not approve) the 5 applications that 'do not meet' any selection criteria.
You must also provide the minister with an indication of which applications can be supported within the available funding.
You should also make any other specific recommendations regarding the applications – for example, you may wish to make recommendations based on other factors that the grant opportunity guidelines indicate may be considered in determining which applications will receive funding. While making specific recommendations is not a mandatory requirement of the CGRPs, it is encouraged as better practice.
You may also rank the applications if appropriate. Ranking is not mandatory but may assist the minister in their decision making – for example, by providing clear advice about the relative merits of different applications.
The minister must record in writing the basis for their decision to approve a grant, with reference to the grant opportunity guidelines and the key principle of achieving value with relevant money. If the minister does not approve a grant that you recommended be approved, the minister must record in writing the basis for not accepting this recommendation.
If the minister awards a grant that you recommended be rejected (for example, the applications that ‘do not meet any selection criteria’) the minister must record in writing the basis for approving the grant and report this decision to the Minister for Finance as soon as practicable.
Ministers must also record in writing and declare any conflicts of interest relating to a grant they approve.
Example 2: 20 applications have been received for a grant round. 10 of those applications have been categorised as ‘fully meet the selection criteria’, 5 as ‘partially meet the selection criteria’ and 5 as ‘do not meet any of the selection criteria’. Only 5 applications can be awarded within the available funding.
Scenario 1: Officials inform the minister which applications fall within which category and rank all 20 applications from 1-20, with the top 5 applications recommended for funding, noting that these 5 can be awarded within the available funding. Officials recommend that the minister reject the 5 that ‘do not meet’ the selection criteria.
Scenario 2: Officials inform the minister which applications fall within which category and indicate that 5 of the applications that ‘fully meet’ the selection criteria can be awarded within the available funding. Officials also recommend that the 5 that ‘do not meet’ the criteria be rejected, but do not make any other recommendations. Officials provide no rankings of applications, allowing the minister to choose 5 applications.
Scenario 3: Officials provide rankings only on the 10 applications ‘fully meet' the selection criteria in order of recommendations from 1-10, indicating that only the top 5 of these can be awarded within the available funding. They indicate the categories that the remaining applications fall into and recommend that the minister reject the 5 that ‘do not meet’ the selection criteria.
In each of these scenarios, the minister must report to the Finance Minister if they choose to award a grant to 1 of the 5 applications that ‘do not meet' any of the selection criteria.
