Chapter 2 The role of the Auditor-General in scrutinising government
The role of the Auditor-General and ANAO
The Auditor-General and the Guidelines
On 2 July 2008 the Government announced the Guidelines on Campaign
Advertising by Australian Government Departments and Agencies.
The Guidelines would govern the content and presentation of Commonwealth
Government campaign advertising.
The Guidelines stated that government information and advertising
campaigns with expenditure in excess of $250,000 would be reviewed by the
Auditor-General, who would then report on the proposed campaign’s compliance
with these Guidelines.
The Auditor-General and the ANAO were responsible for reviewing the
compliance of individual campaigns with the Guidelines throughout the campaign
process, from June 2008 until 31 March 2010.
undertakes assurance activities in accordance with his functions and powers
under the Auditor-General
Act 1997; in particular, section 20(1)(c) of the Auditor General Act
1997, which allows the Auditor-General
to enter into an arrangement with any person or body to provide services of a
kind commonly performed by auditors.
Apart from performance and financial statement audits, the
Auditor-General can also undertake other assurance activities. The ANAO website
describes these as generally consisting of reviews undertaken by agreement with
the client, either at the request of the client or in response to requests from
stakeholders, including Ministers and parliamentary committees.
Prior to 31 March 2010, the ANAO undertook two main assurance
activities, the Government Information and Advertising Campaigns, and the Defence
Materiel Organisation Major Projects Report. The ANAO website also indicates
that two other assurance reviews were completed in 2007-08.
‘Limited’ and ‘reasonable’ assurance
Assurance reviews such as those performed by the ANAO on advertising
campaigns are not an audit. They are conducted in accordance with the
Australian Standard on Assurance Engagements ASAE 3000 issued by the Australian
Auditing and Assurance Standards Board (AUASB) which applies to assurance
engagements other than audits or reviews of historical financial information.
In terms of the assurance framework developed by the auditing
profession, reviews and audits are elements of an assurance continuum, with
reviews providing limited assurance and audits providing reasonable
assurance; the difference being a function of work effort.
The AUASB defines an assurance engagement as:
…an engagement in which an assurance practitioner expresses a
conclusion designed to enhance the degree of confidence of the intended users
other than the responsible party about the outcome of the evaluation or
measurement of a subject matter against criteria.
A reasonable assurance engagement is commonly referred to as an audit
while a limited assurance engagement is commonly referred to as a review.
The Independent Auditor of the ANAO further
explained to the Committee the difference between the two engagements:
The difference between limited assurance and reasonable
assurance is the amount of work that you actually do. In a limited review you
are doing certain discussions and reviewing certain documents. In terms of
reasonable assurance you are increasing the level of work that you are doing,
including reviewing and testing various systems. That is a choice that is part
of the engagement.
The ANAO advised the Committee that they performed limited assurance
engagement in the case of government advertising campaigns rather than
reasonable assurance engagement, as there was insufficient time for reasonable
The review of government information and advertising campaigns
Purpose of the review
The review of government information and advertising campaigns was
designed to enable the Auditor-General to obtain sufficient appropriate
evidence to form a conclusion in relation to the proposed campaign’s compliance
with the Guidelines.
The ANAO review was separate to, and independent of, any consideration
of the proposed campaign and associated materials that had been undertaken by
the Interdepartmental Committee on Communications (IDCC).
The role of the ANAO
The ANAO conducted the review by making enquiries and performing
procedures considered reasonable in the circumstances.
- examining all
relevant campaign materials including, for example, television, cinema and
radio commercials, print and magazine advertisements, letters, and on line and digital
- reviewing supporting
documents and records relevant to the campaign, including but not limited to
strategic documents, policy and administrative approvals, developmental and
market research, financial approvals and procurement documentation, and advice
and assurances from third parties;
- interviews with staff
and contractors involved with the preparation of the campaign;
- an assessment of the
reasonableness of the judgements made by the administering department against
each of the Guidelines; and
- an examination of the
certification by the Chief Executive.
The ANAO worked with the agency over the development of the campaign and
was able to provide the agency with preliminary feedback on matters arising in
respect of each of the Guidelines.
Use of ANAO resources
The ANAO was provided with additional funding when the Guidelines were
introduced and was able to establish a small team to undertake the review of
The ANAO advised the Committee that during 2008-2009 a total of 58
reports were completed, taking some 7,728 hours. This was equated to be 4.8
full time equivalent employees. Up to 31 March 2010, the
ANAO website indicated that a total of 87 reports had been completed.
The Campaign Advertising Review 2008-09 indicated that the
workload associated with individual campaigns was higher than anticipated, with
campaigns being delivered in sections, therefore requiring multiple review
reports and consequent duplication of effort and administration for the
commissioning agency and the ANAO.
The ANAO indicated that they had obtained specialist advice when
...very early on in the process of government advertising
reviews we look at various academic areas and players in the game from various
agencies to see whether there would be a suitable person to provide, initially,
brief training for the team in terms of this type of campaign process. Then, as
we progress, we seek out other specialists in the areas that we would have to
delve into—for example, electronic media, research and research techniques.
Obviously we had presentations to all of our staff on all of those matters as a
training program, which was fairly rigorous. Then, as necessary, we sought
advice from those specialists on elements of the campaigns where we deemed we
needed further support.
The role of the Department of Finance and Deregulation
The Department of Finance and Deregulation (Finance) was responsible for
the application and operation of the Guidelines and for providing a framework
to agencies that were considering conducting advertising campaigns. The
framework consisted of a number of elements including:
- the Guidelines themselves,
which included supporting information, an explanation of the underlying principles
and Finance’s description of campaign costs and activities;
- advice, guidance and support
by Finance to departments and agencies;
- the Interdepartmental
Committee on Communications, chaired by Finance, which provided advice
and guidance to agencies from a whole-of-government perspective;
- certification against
the new Guidelines by the Chief Executive of the commissioning department
or agency; and
- the Auditor-General’s
review and subsequent report to the relevant department or agency’s Minister on
the proposed campaign’s compliance with the Guidelines.
Finance released Business Planning Processes for Campaign Information
and Advertising Activities in February 2009 to assist agencies in
understanding their roles and responsibilities, to ensure that campaign
advertising processes were compliant with the Guidelines.
The ANAO stated that they regarded Finance as the gatekeeper for what is
considered as normal business for an agency and what is considered campaign
The Auditor-General stated that he received formal references from
Finance as to agencies that were running advertising campaigns.
Agencies could also approach the ANAO when considering a campaign and could
seek informal advice.
The role of the Interdepartmental Committee on Communications
The IDCC was a committee of officials which reviewed advertising
campaigns where expenditure was expected to be above $250,000. The IDCC considered
campaigns to ensure whole-of-government coordination.
The IDCC consisted of deputy secretaries from five agencies, chaired by
a deputy secretary from Finance. The IDCC met monthly.
Departmental processes for development and launch of campaigns
The Business Planning Processes for Campaign Information and
Advertising Activities broadly outlined the process that agencies were
required to follow for the development and launch of campaigns over $250,000:
- the Minister of the
relevant department or agency (Department) agrees to the development of a
campaign, subject to funds being available;
- the Department
informs the Department of Finance and Deregulation (Finance) and the Australian
National Audit Office (ANAO) of the impending advertising campaign;
- Finance assists the
department in the selection of the communications research consultant, to
inform the communication strategy, and in the selection of other communications
consultants (such as the creative agency and Non-English Speaking Background
- the Department
develops the campaign, which is reviewed at different stages by the
Interdepartmental Committee on Communications (IDCC) from a whole-of-government
- agency Chief
Executive Officers are responsible for certifying that the campaign complies with
- the campaign is
independently reviewed by the ANAO in relation to its compliance with the
- the Minister of the
Department developing the campaign approves the launch of the campaign after
receiving the ANAO review report and the Chief Executive certification.
Finance, the IDCC and the ANAO interacted with the responsible agency
throughout the development of the information or advertising campaign.
ANAO review process
The ANAO produced a guide for agencies that outlined the review process
and the suggested points in the campaign development process where the agency
could liaise with the ANAO. The process of the
review involved the ANAO working closely with agencies through all stages of
In summary the process was:
- Step 1 - Campaign
- Focusing on the underlying principles
for campaign development and relevance of materials to government
responsibilities. (Guideline 1)
- Step 2 - Strategy and
- Focusing on campaign presentation and
content (Guidelines 2 and 3) and production and distribution (Guideline 4)
- Step 3 – Creative
- Monitoring the presentation and content
of materials to assist with assessing compliance with Guidelines 2 and 3.
- Step 4 – Reporting
- At this stage the ANAO was seeking
final assurance in relation to the requirement for Chief Executive
certification, the underlying principles and the Guidelines.
The ANAO stated that they received formal references from Finance as to
agencies that were running advertising campaigns.
Agencies also contacted the ANAO when considering a campaign and could seek
informal advice. The ANAO indicated that they reiterated the Business
Planning Processes for Campaign Information and Advertising Activities when
discussing potential advertising campaigns with agencies.
The ANAO considered that early consultation was a key factor in
assisting agencies’ compliance with the Guidelines and also ensuring that agencies
had the documentation and processes in place to support efficient and effective
review by the ANAO.
The Auditor-General outlined to the Committee the ideal model that
agencies could follow in the lead up to certification:
They have done the work to support the adherence of the
campaign to the guidelines. They have laid out the cost benefit, they have laid
out the research, they have justified their campaign and my people, apart from
having a conversation, were able to say, ‘Yes, that meets the guidelines and
we’re in good shape and you can tell your secretary that we would be willing to
provide an opinion if she is willing to sign off.’ That is the desirable model.
Additionally Finance and the IDCC would also interact with the
responsible agency throughout the development of the information or advertising
Access to agency staff and documentation
The Committee was interested in finding out about the ANAO’s ability to
access agency staff and key documentation as part of the certification process.
The ANAO replied:
…in brief, we provide agencies with a clear indication of
what we expect to find. We are looking to get an efficient process going on our
part and on their part. We provide them with our expectations and we certainly
do get access, including, from time to time, discussions with secretaries to
make sure that we are getting a good outcome and we understand each other’s
perspective. In the broad, there are no problems.
The ANAO further added:
Following advice from an agency that a campaign is being
developed or they have ideas, we immediately recommend that we have an initial,
or opening, meeting with them. We provide them with a reference to our guidance
on the website and to the Department of Finance and Deregulation’s guidance. We
also have a section 20 contract, which is the agreement under which we are
performing these reviews. We then establish a contact within the actual
campaign—the campaign manager—and allocate one of our managers to the role of
overseeing that campaign. We then sum that up in what we call an ‘opening
letter’ and provide that to the branch head of the department or agency.
Mr Michael White from the ANAO gave an example to the Committee of the
review process for the Child Care Rebate advertising campaign. He described the
level of cooperation from the Department of Education, Employment and Workplace
Relations as being at a high level, also acknowledging that there was a short
time frame for the Child Care Rebate advertising campaign.
Ordinary business activities
The ANAO reported that they had informed Finance of a potential issue in
distinguishing between ordinary business activities of agencies and campaign
In practice, the ANAO used the decisions by Finance as the discriminator
for what is regarded as normal business for an agency and what is campaign
Accuracy of information and advertising campaigns
The ANAO explained to the Committee that in the early stages of the
Guideline implementation they were alerted to inaccuracies with information in
a particular campaign.
I recall getting an email or a letter from a citizen out
there saying, ‘In those ads those stacks aren’t coal stacks.’ They were
actually something else.
As a result the ANAO subsequently sought representation from agencies
about the factual accuracy of the information being portrayed in all campaigns.
Later in the inquiry, the Commonwealth Ombudsman informed the Committee
about some of the issues identified in his report, Administration of the
Economic Security Strategy Payment - An examination of the implementation,
monitoring and review of the scheme, November 2009.
The report focussed on information material about the Economic Security
Strategy Payment (ESSP) that created misapprehensions in members of the public
and resulted in 156 complaints to the Ombudsman’s office.
The ANAO were challenged by some Committee members as to the accuracy of
their review of the ESSP campaign in light of the issues and findings raised by
the Ombudsman. They responded that they were provided with a sign-off that the
information being presented by the advertising agency was accurate.
Additionally the ANAO considered that the information was not inaccurate but
could have been made more complete.
It was acknowledged that there were significant time constraints around