Chapter 5 - Decision-making processes
In this chapter, the Committee outlines the processes
involved in decision-making on Commonwealth government advertising, including
the role of the Government Communications Unit and the Ministerial Committee on
The chapter is divided into three sections. The rest of
this introductory section discusses the institutions and participants in the decision-making
processes. Section two discusses these processes – including at what point and
by whom various decisions are made. Section three discusses some criticisms and
issues relating to the decision-making processes.
Government Communications Unit
The evolution and history of the GCU is summarised by
the following excerpt taken from its web site:
The GCU traces its origins to the Commonwealth Advertising
Division, established in 1941 to coordinate government advertising, and to the
Information Coordination Branch, established in 1982, to improve the delivery
of government information. These units merged in 1984 to become the Office of
Government Information and Advertising (OGIA) in 1989. In 1997 OGIA transferred
from the Department of Administrative Services to the Department of Finance and
Administration and, in 1998, as the GCU, it became part of the Department of
the Prime Minister and Cabinet.
Like its predecessors, the GCU is tasked with the role
of coordinating and providing advice on the executive government's
communications strategies, including advertising campaigns. In broad terms, the
GCU assists ministers and their departments with 'communications issues' and
provides secretariat support to the Ministerial Committee on Government
Communications (MCGC). The GCU also manages the Central Advertising System
(discussed below) and provides 'advice about the implementation of Australian
The GCU's principal functions are to:
provide strategic advice on proposed
communications issues to the Prime Minister and the Ministerial Committee on
Government Communications (MCGC);
maintain a whole of government overview of
current and forecast communications activities;
provide advice to the MCGC on major and/or
provide advice on communications best practice,
including research, public relations and advertising, to the MCGC and
departments and agencies;
monitor current industry developments and
provide a secretariat to the MCGC;
maintain a register of communications
consultants (including advertising agencies, public relations consultants,
market research companies, graphic designers, writers and the like) interested
in undertaking government work which is drawn on by departments and agencies
seeking to engage consultants for communications activities;
assist in developing communications strategies
and briefs for consultants; and
manage the Central Advertising System (CAS) to
achieve effective media planning and cost-effective media placement for
Central Advertising System (CAS)
CAS operates as both a monopoly buyer of government
advertising time and space, and a
monopoly supplier of government advertising contracts. In theory this unique
situation should give the government significant market power, enabling it to
influence the price of goods and services. The GCU states that the CAS:
...allows the Government to establish contractual arrangements,
which have consistently achieved significant savings in the cost of media
placement for departments and agencies.
According to the government website ads.gov.au, 'the Commonwealth
Government is generally one of the largest national advertisers in Australia'. Dr
Lecturer, Media and Communications Program, University
of Melbourne, stated that: 'the
federal government has recently become the biggest advertiser in the country
out-spending commercial giants such as Coles-Myer, Holden, McDonalds
Every Commonwealth department and agency that is subject
to the Financial Management and
Accountability Act 1997 (FMA Act) must place all advertising, both campaign and non-campaign, through the CAS.
Although the CAS is managed by the GCU, media
specialists, or 'master media placement agencies', are engaged to 'assist in
media planning, placement and rates negotiations with media outlets'. Both Universal McCann and hma Blaze
have been engaged on four-year contracts, which expire on 30 September 2006, to perform these
activities—the former handling aspects relating to campaign advertising and the
latter handling all non-campaign advertising.
In its submission, PM&C stated that the primary
rationale for having the CAS is to 'consolidate government advertising
expenditure' and to 'ensure that Australian Government departments and agencies
do not compete against each other for media time and space' as doing so would
bid up the price, thereby increasing the cost for taxpayers.
Ministerial Committee on Government
The Prime Minister established the Ministerial
Committee on Government Communications (MCGC) in 1996. It replaced the former Ministerial
Committee on Government Information and Advertising (MCGIA), which had been established in 1982.
The MCGC has a mandate to:
approve the manner in which communications
campaigns are delivered;
ensure that all government information
activities meet the information needs of the community; and
make key decisions relating to major and/or
sensitive information activities undertaken by Commonwealth departments and
agencies subject to the FMA Act.
In regard to the last point, 'major' is defined as an
information activity that involves the expenditure of $100,000 or more. This
sum is either the cost of the actual advertising campaign itself or any market
research to the value of, or higher than, $100,000. 'Sensitive' is defined as an
information activity which covers issues that 'might offend sections of the
community or produce negative reactions from target groups'.
The MCGC is also responsible for:
selecting the successful consultant from a
shortlist prepared by the department, assisted by the GCU; and
approving the creative material and the media
plan before it is placed in the media.
Furthermore, the MCGC is 'responsible for scrutinising
all departmental proposals for information activities to ensure that they are
justified and well directed'.
The Special Minister of State, Senator Abetz,
chairs the MCGC. The name 'Ministerial Committee', however, is a misnomer
because Senator Abetz is the
only minister who is a permanent member of the committee. The other five permanent
members include a parliamentary secretary, backbench MPs and senior ministerial
In addition to the permanent members, the responsible portfolio
minister for the department proposing the campaign or their delegate sits on the
MCGC for the deliberations on that campaign. The frequency of MCGC meetings is
determined on an 'as needed basis'.
Evidence given at a supplementary budget estimates
hearing of the Finance and Public Administration Legislation Committee, in
relation to the WorkChoices campaign, suggests that the MCGC meets at least
once or twice a week when considering significantly high profile advertising
campaigns. Referring to this campaign, Mr Williams, First Assistant Secretary,
Department of the Prime Minister and Cabinet, stated that the MCGC held
meetings on '12 August, 16 August, 18 August, 22 August, 30 August, 2
September, 6 September, 9 September, 13 September, 23 September, 27 September,
3 October and 6 October '. He
went on to say that 'those meetings basically considered the iterative process
of developing an advertising campaign that resonates with the target audience,
based on research'.
The decision-making processes
The overarching principles and regulations governing
the processes are the:
for Australian government information activities: principles and procedures (the
guidelines), February 1995; and
Commonwealth Procurement Guidelines, 'which are
based on the principles of value for money, open and effective competition,
ethics and fair dealing, and accountability and reporting'.
Within these broad guidelines the decision-making
processes can be thought of as having at least three distinct phases: a
developmental/research phase, a communications strategy and consultant
selection phase and lastly, the advertising production and placement phase.
Most of these phases are iterative processes involving the responsible
department, its minister, the GCU and the MCGC. Excluding the GCU, each of
these participants is responsible and accountable for making particular
decisions along the way. These phases and their respective decisions are
discussed later in the chapter.
Before moving to these, however, it is necessary to
clarify who initiates government advertising campaigns.
The Special Minister of State, Senator Abetz,
in his opening statement to the Committee's public hearing said:
I want to make one point clear in relation to oversight: the
departments initiate campaigns. It is a common error among submissions [to this
inquiry] that the Ministerial Committee on Government Communications somehow
performs a proactive role in initiating campaigns. It does not.
Explaining the overall process Senator Abetz
reiterated this point and told the Committee that:
In general terms, there is a departmental initiative. The
department believes that it needs some communication around it, as a result of
which a communication strategy is developed by the department. That goes from
the department to the Government Communications Unit and things get developed
from there. Depending on what decisions are made, a shortlist of possible
agencies is provided. These agencies are asked for submissions, they are put
through a rigorous process and, usually, the final two are submitted to the
committee [MCGC] for examination and determination. Then a decision is made.
The funding for the campaigns comes out of the particular department that has
initiated the campaign.
The Committee notes that while the MCGC does not
initiate advertising campaigns, portfolio ministers, who will sit on the MCGC, may
do so. As Mr Williams
...the minister is fulfilling two roles in a sense. He is
fulfilling his role as a minister, so he approves material going to the MCGC,
but he is a member of the committee for the purposes of considering the items
that are being deliberated upon by the committee.
The Committee accepts that the MCGC is not likely to
formally initiate advertising campaigns itself. There are, however, obvious links
between key participants which suggest that it is unrealistic to draw a hard
line between departmental and ministerial initiation of advertising campaigns.
This important point emerged in discussion at a public hearing
of the Committee:
my question to you is this: if the department did not come up with an advertising
proposal or a campaigning proposal, would there be circumstances where the
Prime Minister or perhaps you or the ministerial group itself might say that a
public communication campaign would help to support this legislation?
indicated in my opening statement that the MCGC is not a proactive body but a
reactive body. We react to that which is put to us by the various departments
when they consider there is a need.
you never propose a campaign?
that I can recall.
is not to say discussions are not held between ministers’ offices and ultimately
a minister will come forward with his department suggesting a campaign.
In other words, Senator Abetz's
insistence that departments initiate
campaigns should not be understood to mean that ministers have little role in this process. The Ministerial
Committee on Government Communications does not, as a body, initiate campaigns
but equally, the Committee does not believe that public servants initiate major
campaigns unbidden and without ministerial direction and oversight.
There may be government communications activities, such
as defence force recruitment, electoral or taxation related advertising, that
are managed and initiated routinely by departments. However, major and
sensitive campaigns such as the WorkChoices campaign are instigated by
ministers at the highest level of government. Based on ministerial directives,
the department 'initiates' the formal process with the GCU and MCGC.
Development and research phase
Notwithstanding who initiates a particular government
advertising campaign, the formal processes start within the responsible
portfolio department. At this stage and throughout all the processes, departments
liaise with the GCU. Research consultants, according to their expertise, may
also be engaged to assist in developing aspects of the campaign. The GCU's
role, according to Mr Williams,
'is essentially as a facilitator'.
He stated that:
A department would come to the GCU with advice of a prospective
campaign. Generally, depending on the nature and urgency of the campaign, we
will start with some developmental research on the topic which will ultimately lead
to a communication strategy and the appointment of consultants. GCU's role in
that case is to look at the briefs that will go out to consultants to respond
to. It will work with the department to identify a list of appropriate
consultants to be approached. It will look at the communication strategy to see
what the message is, what the target audience is and other issues associated
with a proper communication strategy.
went on to say:
The GCU's role is to help get those lists and briefs into a
shape that is proper to go out for the tender process. It is [also] there to
ensure that the department is programmed into a meeting of the MCGC to have the
MCGC consider it.
The briefs and lists of possible consultants are first
put to the portfolio minister for their general approval. Once approved the
material is taken to the MCGC. If the MCGC's approval is given, the department
and the GCU then begin the detailed development phase.
Communications strategy and
consultant selection phase
During this phase several issues must be addressed and
further developed from the previous phase. These include identifying a target
audience, developing a communication strategy and identifying a list of
appropriate consultants for select tender.
At this time the master media planning and placement agency is also preparing
the media strategy and plan according to its brief from the department. Again,
both the portfolio minister and MCGC are appraised of and approve the communications strategy, briefs and consultant list,
and note the draft media plan.
As indicated above, consultants are assessed through a
select tender process. The consultants who would be considered must be
registered with the GCU. The following exchange provides a concise explanation
of this register:
do not go to open tender. We use a selective tender process. We take companies
who are registered on the GCU register of consultants ... [which] is covered by
the Commonwealth Procurement Guidelines.
is a panel?
is not a panel; it is a register.
advertise every year inviting any companies in this field that would be interested
in undertaking government work and those details are registered, along with
their relevant experience et cetera. It could be in public relations, research,
creative advertising companies et cetera. That is the list that we draw from to
compile a list of candidates with relevant experience for particular campaigns.
Following selective calls for tenders, the department,
GCU and research consultant (if one is engaged) evaluate and test the tenders received.
The department then recommends, or shortlists, two consultants for which the portfolio
minister's approval is needed before the shortlist is considered by the MCGC. It
is at this point that the MCGC selects the successful consultant.
Advertising production and
This phase of the process is where two final decisions
are made before the advertising campaign goes public. The successful consultant
further develops and refines the 'creative materials'. According to the submission
of Senator Abetz, the 'MCGC
closely monitors creative development of the campaign including subsequent
testing of materials to ensure they are capable of appropriately achieving the
communications objective'. The
MCGC approves all the materials pre-production and again approves the final
materials post-production. In other words, the MCGC first approves the concept
for the campaign and second, it approves the final campaign product.
The final decision to be made concerns the plan for
placing the advertisement in the media. The department, creative agency or consultant
and the master media placement agency 'review and book a media plan', which is
considered and given final approval by the MCGC.
Summary of the decision-making
It is evident from the discussion above that there are
various levels of decision-making during different phases of the overall
process. These decisions are made at many levels of executive government,
including departmental, ministerial, and the MCGC. Appendix 4 lists each step
in the decision-making processes.
The Committee notes that the MCGC is the prime decision making body for
government advertising campaigns. The MCGC makes the final decision at each
phase of the process and is responsible for making the following key decisions:
first, it must approve all the associated
materials, including, but not limited to, briefs and lists of possible
second, it must (i) approve the communications
strategy and (ii) select the successful consultant; and
third, it must (i) approve the final creative
concept and final creative materials and (ii) the media placement plan.
The final question relating to decision making that the
Committee examined was on whose authority the decision to expend Commonwealth
funds on government adverting campaigns is made. As Senator Carr put it, 'is it
the decision of the portfolio minister, the relevant agency’s communications
unit, the MCGC or the GCU? Which one is it?'
The Committee heard that the responsible department,
and by extension, the portfolio minister makes the final decision. When the question of who makes the
decision to expend funds was put to GCU officials, the Committee was told:
delegate within the department or agency who has the power to commit funds on
behalf of that agency.
is the department that makes that decision?
Criticisms and issues relating to the MCGC and GCU processes
The following three matters relating to the MCGC and
GCU processes were raised:
efficiencies of centralised processes;
evaluation of advertising campaigns; and
application of the 1995 Guidelines.
Efficiencies of centralised processes
Visiting Fellow, Asia-Pacific School of Economics and Government, Australian
(and former deputy secretary to the Department of Finance and Administration
1997 to 2003) questioned the merits of centralised processes for government
advertising and, in particular, the extent of any savings resulting from the
GCU and the CAS.
argued that 'the idea that centralised purchasing secures discounts for
government has been comprehensively disproven in relation to a range of other
formerly centralised services'. He
noted that 'government rates' in many cases may be nominally lower than the
market's but suggested that centralised regimes inevitably cause other
associated inefficiencies, thus raising the overall cost. 'The devolution of
responsibility for their own purchasing decisions', according to Professor
Bartos, 'has meant agencies have greater scope for innovation and for tailoring
services to best meet their needs, generally at a lower cost'.
For example, Professor
Bartos noted that large advertisers, such as
the Department of Defence, are by themselves more than likely to obtain media discounts
based on sheer volume and without the need of a centralised purchasing system. Savings
then, are more likely found in smaller agencies without purchasing power.
However, he argued that these savings are nominal and with
the real costs considered any savings are quickly eroded. Professor
...any savings on the advertising rate are likely to be more than
offset by the additional costs of having to go through the CAS and GCU
processes. These compliance costs
[emphasis added] are considerable – they involve additional expenditure within
agencies associated with the time and effort involved in shepherding proposals
through the processes, and also some risk to delivery of government programs
given the delays they entail.
went on to say:
The cost of maintaining the GCU itself is also a factor, but a
much lower cost than the invisible – but real – costs of compliance spread
across FMA Act agencies as a whole.
Another submission, from The Agency Register, stated
that as of January 2005 there were about 915 advertising agencies operating in Australia
but that the number of agencies contracted for major federal government
advertising campaigns since 2001 was only around 20. If these figures represent an
accurate picture they suggest that the current level of competition for
government advertising contracts is perhaps not as high as might be desirable. Lower
competition implies higher prices than otherwise would be likely.
A second argument given for the centralised processes
was that it ensures that agencies do not compete for advertising time and space.
Commenting on this argument, Professor Bartos
thought that excessive competition was unlikely, except perhaps during the
pre-election 'advertising spike'. He stated that: 'if there were no such spike,
this justification for centralised purchasing would be much less plausible'.
The Committee notes two points here. First, this centralist
approach is in contrast to the government's overall preference for the
devolution observed in many other areas of public administration. Second, this discrepancy,
together with the close editorial control exercised by the MCGC, enhances the
perception that at least some government advertising campaigns may be used for
Evaluation of advertising campaigns
The Committee notes that responsibility for evaluation
of government advertising campaigns resides solely with the initiating
department. Evidence to the Committee indicated that the MCGC's formal
involvement with particular advertising campaigns ceases once the campaign goes
to air or print.
The Committee is unable to determine the extent to
which departmental evaluations of the efficiency and effectiveness of campaigns
are made available to and considered in detail by the MCGC. This of itself
suggests that the intensity of evaluations is limited.
The Committee notes that there are least three forms
that evaluation of the effectiveness of campaigns might take, and that need to
be distinguished here.
The first involves the tracking of the impact of a campaign, measured in terms of the
public's awareness of a particular issue or their support for a particular
proposal. The second involves evaluating whether the campaign met its planned
target of reach and frequency of media placements. Finally, the third would
involve evaluation of the efficiency and effectiveness of particular facets of the media strategy, or of
particular creative concepts. Was it, for example, the radio advertisements or
the television advertisements that really grabbed people's attention? Did the
advertisement with one slogan have more impact than the alternate slogan? Did
the volume of the advertisements
placed create negative feedback from the community? What is the evidence that
the particular target audience (for example, those entitled to family benefits
payment) was actually reached by the advertisements?
In relation to the first form of campaign evaluation,
tracking of a campaign's impact is done by departments and that the results of
this tracking can be made available to the MCGC. Mr
Williams described the methodology used for
tracking research in the following terms:
[T]racking research is done against a benchmark. It is a
standard process. You attempt to benchmark knowledge levels and familiarity
with particular issues, and your tracking research will tell you whether you
are building on that benchmark. At the end of the campaign in your final
element of tracking research you will be able to get a view on how much you
have changed people's knowledge, based on the particular issue that the
campaign has been focusing on.
In relation to the WorkChoices advertising campaign,
for example, the Department of Employment and Workplace Relations (DEWR)
advised a Senate Estimates hearing that focus group and tracking research was
undertaken and the results provided to the department and thence to the GCU and
the MCGC. Evidence indicated that
those results were provided at times once or twice per week, and at other times
at longer intervals.
The second type of evaluation, the report on the
campaign against its placement objectives, is routinely undertaken by the media
placement company and, the Committee understands, is also provided to the MCGC.
elaborated on the usefulness of this type of evaluation in the following terms:
When you are buying television you buy on the expectation of the
programs you are in delivering certain ratings. The aggregate of that is in a
sense the TARP [target audience rating point] weight of the campaign. Ex post
you can see what those programs delivered in rating points and audience and you
will get a more precise view on what you actually achieved. It is a standard
When questioned on the evaluations to be conducted on
the WorkChoices campaign, Mr Williams
indicated that only the first and second types of evaluation were planned. He
You should, through your tracking research, conducted by Colmar
Brunton, get an indication of the target audience's reaction to the campaign in
terms of knowledge levels growing of particular elements of the campaign. And
you will get, on your TV spend at least, more precision on your reach and
frequency outcomes because you will actually know what has been delivered. So
between the two you will get a better picture - .
It appears from this evidence, then, that evaluations
of the third type are not routinely conducted for major government advertising
campaigns. That is, it does not appear that assessment of the effectiveness of
particular facets of a campaign are commissioned by departments and provided to
Without such qualitative evaluation, however, it would
seem that the MCGC is not in a position properly to assess the effectiveness of
the media placement strategy and campaign concepts used for a particular
campaign. This means that the MCGC is unlikely, as a body, to learn from past
campaign successes or failures.
Given that the MCGC makes important decisions about the
creative content and media placement strategy for government advertising
campaigns, and given that tens of millions of dollars of public funds are at
stake, the Committee believes that this kind of evaluation should inform the
MCGC's decision-making processes.
Application of the 1995 Guidelines
The Committee noted earlier in this chapter that the
overarching guidelines for government advertising campaigns are the February
1995 Guidelines for Australian government
information activities: principles and procedures (the guidelines).
The Committee is concerned that there appears to be no
point in the decision-making processes of the MCGC at which the guidelines are
formally considered and certified as having been met. This lessens
accountability and makes it more difficult to assign responsibility.
Mr Williams advised that, as an advertising campaign is
being developed, 'we look at the nature of the message and the target audience
and we look to see that it is consistent with the guidelines', but that there
is no formal process for a minister or someone representing the minister to
certify that the campaign is in accord with the guidelines.
The Committee recognises that guidelines may well be
internalised and followed without there being a formal certification process.
Such a formal process can itself risk becoming a mechanical 'tick and flick'
exercise which does little to guarantee that the guidelines shape the choices
made in developing a campaign.
Nevertheless, the Committee is concerned about this
matter for two reasons. First, it seeks assurance that the guidelines really do
inform the development of campaigns and are not simply a form of policy
'theory' or smokescreen which has no effect in day to day practice. The
question over the relationship between guidelines and practice in this case is
particularly pertinent, given the fact that the targets set by the guidelines
for advertising in non-English language media are consistently not being met. This
is issues is discussed in detail in Chapter 6.
Second, the Committee considers that it should be clear
who it is that is accountable for the guidelines being met in relation to each
campaign. Is it the portfolio minister whose department has commissioned the
campaign? Is it the officials in the Government Communications Unit, or the
Minister who chairs the MCGC?
Without clarity on this question, ministers or officials
cannot be held to account in cases where the guidelines are not met. This may
become particularly relevant if some of the suggested revisions to the current
guidelines, discussed in the following chapter, are adopted.
In this chapter, the Committee has outlined the
decision-making processes involved in Commonwealth government advertising. It has
highlighted concerns relating to the efficiencies of a centralised advertising
system, feedback of detailed campaign evaluation to the MCGC and the extent to
which the guidelines play a real role in shaping advertising campaigns.
The Committee also found that only limited evaluations
of the effectiveness of campaigns are undertaken. While there is some degree of
tracking of the impact of campaigns and reporting of campaigns against their
objectives, no qualitative evaluation of the particular facets of campaigns
occurs. This is a significant gap in the government's own oversight of its
advertising strategies. Qualitative evaluations are routinely done as an
element of program management across most areas of government activity. Without
this form of evaluation the MCGC and relevant departments are unable to gauge
the effectiveness of media strategies and campaign concepts. The Committee
believes this needs to be rectified.
The Committee recommends that for all major government
advertising campaigns, the responsible department should conduct or commission
a qualitative evaluation of key facets of the campaign (such as media placement
strategy, campaign concept, response of target audience, value for money and so
on) and report the evaluation results to the MCGC.
In the next two chapters of the report, the Committee
considers the adequacy of the current guidelines, suggested revisions to them
and other measures to improve the accountability framework for government
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