Grants design and management are notoriously complex and resource-demanding exercises. In order to ensure that the key principles of transparency, accountability and probity are embedded in the way NSW Government grants are delivered, the 2022 Review of Grants Administration in NSW has made recommendations to improve grants delivery.
This review was led by the Department of Premier and Cabinet (DPC) in partnership with the NSW Productivity Commissioner and was tasked with delivering an updated Good Practice Guide to Grants Administration and providing recommendations for improvement.
The overall aim was to ensure that any investment the government makes in grants:
We have summarised the review’s findings into the following essential tips that should be adopted by Agency staff when designing a grant program.
NSW Public Servants love acronyms! Remember though that the acronyms we use may not be widely understood by the public. Reading documents with multiple acronyms can sometimes be like deciphering a foreign language! Try to keep internal jargon out of public-facing documents. If you must use an acronym, expand them on their first use in a document.
If you are unsure, use the Government Style Guide.
Be consistent with your terminology. This can avoid confusion for your audience and make the process easier for people to follow. Make sure your content uses plain language. This helps all users and ensures everyone can understand. Avoid (or explain) unusual words, phrases and idioms.
Be careful with discretion in your guidelines. If you publish rules with discretionary clauses, ensure that you workshop various scenarios and document your risk tolerance for each scenario. When you do exercise discretion, you should ask yourself if there will be a material benefit to the applicant because of your decision. Also ask yourself how much benefit you give an applicant by using your discretion. (For example, allowing an applicant to submit a late tender by one hour due to technical issues with the tendering website may be allowed, as it gives the proponent no real material advantage, but giving a proponent an extra week to submit a proposal would be unacceptable.)
Be mindful of the optics of your decisions, and if you do make discretionary decision, be sure to document it and have it approved by the person with the appropriate delegation.
Be sure to document roles and responsibilities up front, noting who will make a recommendation, who will endorse, and who will approve. Ensure the roles nominated have the correct delegation, and if there will be Ministerial or MP involvement, you must disclose this in the published guidelines. Establishing a governance structure up front with roles and responsibilities for each group and clear terms of reference will set the project up for success.
Conflicts of interest are only bad if they are not disclosed. You should be checking for actual or perceived conflicts at each meeting and each step of the process, not just at the outset. Things can change and this gives everyone the opportunity to raise any actual or perceived issues before they become a problem. Be sure to document any mitigation strategies you have agreed upon, making sure they are appropriate and approved by the person or group with the correct delegation. A good Probity Advisor will be able to help design mitigation strategies to manage tricky conflicts.
It is important that everyone involved in the project is aware of the confidentiality protocols and if necessary, has received training in this area. It is essential that confidentiality is taken seriously so that all grant applicants are treated equally and fairly, and the process is equitable.
If you decide to use anything other than a competitive merit-based selection process, be sure to document why, and develop a risk register with appropriate risk mitigation strategies. This must be approved by the relevant person with the delegation to make this decision, usually the Minister, or the Head of your Agency.
Build evaluation into your program design up front, and ensure you have clearly defined and measurable outcomes. This will help increase the quality of the evaluation. Use evaluation reports to inform any decisions about changes to programs in the future.
You must publish your grant on the NSW Government Grants and Funding Website. This is a mandated requirement following the 2022 Review of Grants Administration in NSW and relates to any grant being issued after 19 September 2022. Details of grants awarded must be published no later than 45 days after the first payment is made to a grant recipient.
If a grant program is either high value, high risk or politically sensitive, current guidance recommends that you use an external Probity Advisor. Getting advice from a firm that has trained and government accredited probity advisors will guide your team towards best practice and prevent any reputational risk for the agency and your staff. A good probity advisor will hold your hand throughout the process and should be able to help with training and ongoing development of your people. It is a small cost to outlay and can save a lot of time, anxiety, effort – and ultimately reputation!
While the above tips and recommendations can be used to simplify grant design and management, there is value in engaging an experienced probity advisor to offer expert support for high value or sensitive grant programs.
Centium has over 20 years’ experience offering transparent, activity-based probity advisory and auditing services and support to government agencies. A key element in providing quality probity advice is an understanding of the transaction and the associated issues and risks. Our bespoke Probity Methodology is risk-based and ensures that key probity elements are incorporated in every aspect of your transaction.
If you require probity advisory services, grant admin management support, or internal audit of your grants, reach out to Joan Cavalieri, Director, Probity & Ethics via joan.cavalieri@centium.com.au or visit our website to view our full range of probity and procurement services.
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