Stage 3 - Implementation

The broad implementation strategy developed during the policy design and considered as part of the policy approval, should be updated.

Entity staff should have a plan that outlines and considers:

Internal controls

Accountable authorities are responsible for the implementation of charging activities, consistent with the Government policy approval, PGPA Act and Rule, other relevant legislation, and the broader resource management framework. This involves:

• establishing internal controls (for example, systems and procedures to monitor and report on the production of outputs of the activity against financial estimates and performance targets)
• ensuring that staff have the skills to manage the charging activity and continue to improve those skills.

Other entity staff support these processes (for example, chief financial officers are usually involved in developing, monitoring and updating financial estimates for the activity). As part of this work, staff may:

• explain performance variances and analyse implications for the activity to support decision-making
• monitor business processes to make them more efficient
• ensure that the costing methodology remains relevant and any relevant documentation is up to date (for example, by assessing whether cost drivers, cost allocation methods and other assumptions are still correct)
• undertake ongoing and open stakeholder engagement (particularly important for regulatory activities)
• identify the need for operational or policy changes, and implement them in a timely manner in accordance with the appropriate approval procedures (for example, through the Budget process).

Before commencing an activity that is charged for, or implementing significant changes to the activity, staff may need to make adjustments to their information management systems. In particular, the systems should enable the collection of relevant, up-to-date and accurate information (financial and non-financial) to support performance monitoring, evaluation and decision-making. This information may also be useful when providing input to the portfolio charging review.

Relevant internal systems and controls may include:

• workflow systems or databases, such as those that:
  • maintain records for decision-making and audit purposes
  • track performance (for example, progress in the processing of applications)
  • contain compliance histories for regulated individuals or organisations
• financial management information systems, such as those that:
  • collect timely and accurate cost information to determine charges
  • track financial performance against budget
  • identify gaps between financial estimates and actual results
  • record details of those liable to pay charges and their payment status
  • issue invoices or notifications for payments
• payment systems, which enable receipting, banking or processing of refunds by entities and provide payers with flexible and easily accessible payment options
• debt recovery procedures
• risk management and other internal procedures.

Charges for regulatory activities in particular require well developed and effective financial management that will support information on the cost recovery, and identified any possible over and under recovery charges. Short term over and under recovery charges are often part of natural business lifecycle (driven by specific activity time cycles, for example, end of license period for a large population of customers). However, entities are expected to develop systems and processes to prevent a systematic over or under cost recovery, and manage it appropriately over the charging business cycle.

In addition to the information generated by internal systems, stakeholder feedback or the findings of internal and external enquiries, audits and other reviews of the entity’s operations are likely to identify further opportunities to improve the management of the activity.

The entity’s internal management information systems are one source of information that can assist in measuring and reporting on the performance of the regulatory or non-regulatory activity. That information should be relevant, up to date and accurate to enable appropriate decision-making about the activity. Feedback can provide valuable information on how stakeholders perceive the entity’s performance. Entity staff may also actively seek stakeholder feedback (for example, by conducting stakeholder surveys).

The Cost Recovery Implementation Statement (CRIS) is an explanatory document that provides key information on how cost recovery for a specific government activity is implemented and managed. The CRIS is usually developed in parallel to the policy proposal explaining the business processes and the allocation of resources (people, assets and supplies) for outputs of the regulatory activity. CRIS may need to be updated post Government decision to incorporate any possible changes to policy, level of charge and legislative authority as part of progressing to implementation.

The CRIS must be:

• certified by the accountable authority of the entity 
• approved by the responsible Minister 
• agreed for release by the Finance Minister, where the CRA rating for the activity is 'high'
• published on the responsible entity's website before charging begins 

For more information on CRIS please refer to Regulatory Activities 

For new regulatory activities, entities should consider updating the Charging Risk Assessment (CRA), post Government decision to incorporate any possible changes to policy, level of charge and legislative authority as part of progressing to implementation. Significant changes to the risk level effecting the charging activity may impact the CRIS previously prepared. Any changes to the risk assessment and risk treatment need to be captured in the annual CRIS update.

For more information about CRA please refer to Regulatory Activities