Chapter 3 - Policy planning and implementation

  1. Policy planning and implementation

Overview

3.1The Department of Prime Minister and Cabinet (PM&C) through the branch of the Office of Impact Analysis (OIA) defines the considerations that need to be addressed for successful implementation of policy in its Delivering Great Policy Model.[1] The Delivering Great PolicyModel highlights that a good policy essentially is one that’s implemented and works.[2] To deliver a successful policy or program, effective implementation is needed. This includes consideration of several policy impact analysis factors that impact the success of implementation, such as:

  • evidence supporting policy design, specifically an ability to reduce or remove information gaps through the implementation phase if they cannot be closed during the policy development phase[3]
  • policy option implementation considerations, ensuring that approaches to address regulation requirements are considered, and that those affected understand their legal rights and obligations[4]
  • ensuring there are no implementation barriers or unintended consequences and shaping evaluation[5]
  • the implementation planning includes appropriate risk management arrangements.[6]
    1. Included in best practice for implementation is a clear implementation plan for delivering the proposed policy option that includes a shared understanding among key stakeholders involved in the implementation, identification of challenges, timeframes, project phases of the implementation, and appropriate resources for delivery across the life of the implementation.[7]

Findings

3.3The Australian National Audit Office (ANAO) listed key messages from the audit reports included in the inquiry, regarding policy and program implementation that were identified as important for success:

  • Regulators should implement a risk and assurance program to ensure compliance frameworks remain effective, including when implementing organisational-wide changes that span over several years.[8]
  • Large-scale cultural change programs that are intended to be implemented over several years need ongoing and active oversight. This includes clearly articulated objectives, ongoing governance including active risk management as things change, and monitoring and reporting on the achievement of outcomes. Effective planning for cultural change programs includes identifying evidence and undertaking analysis to inform the objectives of the program. Program objectives should clearly define the intended outcomes of the program, in other words, what the change will look like. Program of outcomes should be measured using relevant performance measures and established baselines, and plans adjusted to reflect progress.[9]
  • Roles, responsibilities, and governance arrangements should be defined and implemented at the commencement of the cultural change program. It is worth reviewing them at points in the long-term change program to assess if they remain appropriate as change unfolds, including where new risks emerge. Changes in senior positions within organisations during long-term change programs reinforce the need for good records to ensure continuity of intent.[10]
  • For cross-entity programs and initiatives, establishing clear governance arrangements that facilitate horizontal collaboration and ensure a clear line of vertical accountability are particularly important for success.[11]
  • The likelihood of successfully implementing recommendations is increased by establishing fit-for-purpose arrangements such as: clearly specifying roles and responsibilities; appropriate planning; monitoring, evaluation and reporting arrangements; and a process to assure or check that recommendations have been implemented in full.[12]
    1. The ANAO found several issues regarding policy planning and implementation in the audits, including:
  • implementation planning and support
  • communication
  • coordination, and
  • information management.

Implementation planning and support

Expansion of telehealth services

3.5In Auditor-General Report No. 10 2022–23, the ANAO found that while the Department of Health’s (Health) implementation of telehealth changes during the height of the pandemic ‘provided largely appropriate support to delivery partners’,[13] the expansion was ‘only partly supported by sound implementation arrangements’.[14] The ANAO noted that the expansion was largely based on the department’s routine processes for making changes to Medicare Benefits Schedule (MBS) items.[15] It found that Health did not develop an implementation plan for the initial temporary expansion of telehealth services to address the impacts of COVID19.[16]

3.6The ANAO observed that Ministerial 3C determinations under the Health Insurance Act 1973 (Cth) were used to implement the expansion of telehealth in response to the pandemic.[17] The power to make such determinations had been ‘delegated to specified’ departmental senior executives, with Health advising this ‘is an established process’ and suited the implementation of the rapid temporary expansion of telehealth services.[18] The audit identified that although this process was only partially documented, it was well understood by staff.[19]

3.7For the transition to permanent telehealth services, ANAO found that Health developed a high-level implementation plan to work alongside its Primary Health Care 10 Year Plan:

  • outlining deliverables and timeframes between April and December2021
  • proposing that permanent telehealth services items would commence from January2022
  • updating it in December 2021 to clarify timeframes and deliverables for 2022–23
  • deviating from the implementation plan in December 2021, in response to the COVID-19 Omicron variant outbreak.[20]
    1. To improve the implementation process for future changes to the MBS and telehealth services, the ANAO recommended that Health considers the lessons learned from the temporary expansion in response to the COVID-19 to guide future pandemic preparedness and finalise plans to evaluate permanent telehealth measures.[21] The audit report also recommended Health ‘strengthen its systems of control for the implementation of changes to the [MBS].’[22]

Family Migration Program

3.9In Auditor-General Report No. 16 2022–23, the ANAO found that the Department of Home Affairs’ (Home Affairs) delivery of the Family Program lacked clear implementation frameworks that would ensure consistent and timely provision of visa services.[23]The audit identified the development of guidance material as an opportunity for improvement and made several business processing recommendations to:

  • …ensure its prioritisation and risk-tiering processes are fit for purpose and consistently applied.[24]
  • …develop an overarching policy and governance framework for its case allocation model to guide allocation decision-making and ensure that this supports effectiveness and efficiency in handling…visa applications.[25]
  • …establish processes to identify, analyse and remediate potential processing inactivity to support improvement of efficiency in its business process for finalising…visa applications.[26]
  • …establish systematic processes for detecting and remediating aged cases across all parts of the [Family Program] caseload to ensure applications are appropriately finalised, wherever feasible.[27]
    1. The ANAO further advised that this guidance material should:
  • assist managers and staff at local processing offices ‘to maintain records of case allocation practices to ensure decisions can be centrally monitored and verified, if required’,[28] and
  • address the potential for unreasonable delays and remediation within policy and procedural documents.[29]

3.11Case allocation practices were also identified in the audit as needing improvement and ANAO recommended the development of internal policies and procedures by Home Affairs to ensure applications are allotted and managed consistently, efficiently and effectively by staff, and in line with government directives.[30]

3.12A related issue that arose is the cost of visa applications. The Committee brought this issue of Visa Application Charges (VACs) to the attention of Home Affairs during the public hearing in Canberra on 1 February 2024. Home Affairs were unable to provide specific costs associated with the processing of applications but did confirm the current indexed cost to lodge a visa application—$8,850.00—is currently one of the highest globally (if not the highest).[31] Home Affairs clarified in a response to the Committee the treatment of the charge as a tax, and is set by the Government and adjusted annually [usually] in line with the Consumer Price Index (CPI).[32] Home Affairs further stated that:

A range of policy considerations may be taken into account by the Government in setting individual VACs, however these are not restricted to the cost of assessing visa applications.

The Department does not record or track costs at visa level in its financial management information system to enable an average processing cost per partner visa to be derived.[33]

Communication

Expansion of telehealth services

3.13In Auditor-General Report No. 10 2022–23, the ANAO found that Health had not developed a communications plan to support stakeholders during the rapid expansion of the temporary telehealth services. This created an increased risk in changes being misunderstood by providers and patients, as well as a potential for increased risk in incorrect process for MBS claims through Services Australia. However, it noted that a substantial number of guidance documents had been developed to assist health providers and facilitate their enquiries.[34]

3.14The ANAO noted that service standards in responding to provider inquiries were inconsistently met between March 2020 and June 2022.[35] Additionally, ANAO reported that submissions received by the audit relating to the department’s implementation approach consistently highlighted concerns regarding ‘the number, frequency, and speed of changes to telehealth arrangements’.[36] The issues noted by stakeholders included that:

  • the quality and timeliness of policy guidance was variable
  • policy guidance provided limited support
  • technology guidance provided limited support
  • changes to telehealth settings were made abruptly or without sufficient notice
  • the frequency of changes to telehealth settings created confusion
  • the expiry, extension and/or reinstatement of temporary items over short timeframes prevented long-term decision making by businesses
  • the frequency of changes to telehealth settings increased costs to businesses.[37]
    1. The ANAO concluded that the lack of a communications strategy resulted in content duplication between Health and Services Australia, and led to emerging risks associated with inconsistent messaging and uncertainty around which departmental teams were responsible for deleting obsolete guidance materials.[38] Additional issues were raised by the Committee regarding changes undertaken by Health that failed to observe the requirements for Services Australia to be able to process MBS payments.[39] This created the potential for fraudulent transactions to be processed. Services Australia did raise concerns about this with Health on 16 March 2020 and requested clarification of signature requirements, with Health stating that due to the ‘exceptional and temporary circumstances’ of the pandemic at the time, providers could document those patients that had given verbal consent as adequate to address Services Australia’s concern.[40]
    2. Public facing guidance by Health also did not clarify that notating verbal consent alone in provider records would not legally address other statutory requirements requiring a signed copy of the agreement to be provided to the patient. This created legal issues that Health did not address or communicate to providers, including the potential for severe legal consequences, as there is no legal basis for Services Australia to pay benefits to the provider under the MBS if a signed agreement is not completed, and that providers can be criminally liable for failing to complete the agreement properly.[41]

Family Migration Program

3.17In Auditor-General Report No. 16 2022–23, the ANAO found that feedback submitted both to a 2022 Senate Migration Program inquiry and its performance audit of this scheme highlighted a ‘lack of communication during the visa processing period’ as a concern.[42]

3.18It noted that some family visa clients were waiting more than 12months for final decisions on their applications.[43] It further reported that while determinations were quickly made if applications were invalid, there was limited communication with clients whose applications were in progress.[44]

3.19The ANAO found that automated ‘Application in Progress’ emails (reassurance emails) are sent a year after visa applications are lodged, or six months after previous reassurance emails are received, advising applicants to check their application status online.[45] Home Affairs advised the ANAO in relation to this that:

…its ability to provide updates to clients digitally is limited by its systems, and that ‘the nature of visa processing makes it difficult to breakdown information that would be meaningful and helpful’.[46]

3.20The ANAO further determined in the audit that ‘call centre and complaints reporting does not provide sufficient detail and analysis to support improvements to the delivery of the [Family Migration Program]’.[47] The ANAO stated that Home Affairs does not monitor enquiries at the Family Program level to identify complaint trends.[48] Instead, it was indicated in the audit that quarterly complaint statistical reports broadly categorise issues into ‘digital service, policy, processing times, and decision’.[49]

3.21The audit noted that, in line with the Commonwealth Ombudsman’s advice, accurate recording and routine analysis of complaints data that identifies trends ‘can support business areas in making targeted improvements to their services’.[50] These processes should also clearly define responsibilities for responding to identified issues and tracking ‘to ensure remedial action occurs.[51] ANAO recommended that Home Affairs develop processes to meaningfully capture client feedback to enable the identification of opportunities to improve program service delivery.[52]

3.22The ANAO additionally reported that while information available on the Home Affairs website to assist applicants was relevant and was communicated in plain language, it ‘may not be sufficient in helping clients to understand all requirements for lodging a valid visa application’.[53] This was described as consistent with Home Affairs’ own analysis in November 2021, which identified web content as ‘not resolving client queries about partner visas’.[54]

Department of Agriculture, Fisheries and Forestry Cultural Reform Program

3.23In the Auditor-General Report No. 17 2022–23, the ANAO stated that:

Cultural change requires clear and persuasive communication about the change and behaviours required, supported by a clear purpose and vision of the future.[55]

3.24The ANAO concluded that the department’s communication in promoting and implementing the Blueprint was inadequate. Communication strategies and plans were not assessed for effectiveness; the planned approach to updating staff on progress was not implemented; and tailored communications to staff largely ceased beyond the release of the Blueprint in September2021.[56]

3.25To improve, the ANAO suggested DAFF maintain regular and ongoing communication with staff throughout the remainder of the Blueprint’s implementation, and any future reform programs.[57]

Coordination

3.26In the Auditor-General Report No. 10 2022–23, the ANAO found that Health did not consistently adhere to its bilateral agreement with Services Australia to rapidly expand temporary telehealth services, it acknowledged, however, Services Australia’s advice that the agency was generally comfortable with the timeliness and quantity of information provided.[58]

3.27Conversely, in the Auditor-General Report No. 39 2022–23, the ANAO reported that Treasury (Treasury) failed in its coordination role to implement the required taskforce recommendations.[59] The ANAO concluded that Treasury failed to establish coordination arrangements in which there were clearly defined responsibilities and accountabilities that would underpin the implementation of the Black Economy Taskforce recommendations in a cooperative manner.[60] It also reported that ‘there was no inter-agency operational group to support the coordinated implementation’.[61]

3.28An internal Treasury audit in November 2020 identified the lack of a framework for programs and projects.[62] Treasury then launched its Program Management Framework in November 2022[63] but advised the ANAO that although staff were encouraged in its use, it was not mandatory.[64] The audit report recommended that Treasury ‘review how its program management framework could better be applied’ in undertaking its coordination role.[65]

Information management

Implementation of the Export Control Legislative Framework

3.29The ANAO concluded from its performance audit that DAFF’s implementation of the revised Export Control Framework was only partially effective.[66] It found that the development and updating of instructional materials (IM) and other documentation, including external website content, had not been completed prior to the commencement of this legislation.[67]

3.30The audit findings further revealed that internal stakeholders relied on up-to-date IM for a successful transition to the revised legislation, both for those implementing and those administering changes, and external stakeholders were dependent on website content and documentation to understand their rights and responsibilities under the new framework.[68]

3.31The ANAO noted that PricewaterhouseCoopers (PwC) had been engaged by DAFF to assess the preparedness of the department to implement the revised export framework in September 2020 and that Noetic Group (Noetic) was contracted in October 2020 to evaluate whether DAFF was on course to review and amend existing IM, as well as develop new IM as needed.[69]

3.32The audit findings indicated that both PwC and Noetic identified and communicated concerns regarding identified failings by DAFF to update existing and develop new IM in line with the new legislation prior to its implementation.[70] PwC had reported that ‘there remain[ed] a significant volume of IM and other documentation to be completed prior to commencement [and] there is a risk of errors being made in IM due to tight timeframes for completion’.[71] Noetic had advised DAFF that the amount of IM requiring legal review had not been fully calculated, and there were ‘significant choke points’ in the legal review, clearance, approvals, editing and publishing process, with no clear understanding of the liability and processing schedule.[72]

3.33It was noted that DAFF had agreed in response to these assessments to identify high-risk IM that required development or amendment prior to implementing the revised framework, while deferring those deemed medium to low risk until after commencement.[73]

3.34The ANAO also reported that although DAFF’s internal policy required that all IM should have been updated prior to commencement of the revised framework, the department had not complied with this. Upon assessment of 2,303 IM files in March2022, the ANAO found that of the 850 relating to export activities and legislation, only 42percent had been updated. The audit report further stated that, other than the two-year review, no other requirement or timeframe had been set for the review and update of medium to lowrisk IM that required this.[74]

3.35The audit also indicated that while the website project plan rated the risk of external stakeholders utilising outdated forms and templates with incorrect information as ‘high’, no risk treatments had been identified and the residual risk had been reduced to ‘medium’. The ANAO further identified DAFF website content relating to export control that referenced already repealed legislation.[75]

3.36The ANAO’s in-audit observations on remedial actions undertaken by DAFF noted that the department had ‘developed a project plan to ensure contents on its external website [reflected] the revised export control legislative framework’.[76] In its audit report, the ANAO recommended that the department should ensure policies and procedures relating to IM and website content were up-to-date, reflect current legislation, were appropriate, and would operate as intended.[77]

Implementation of the Government Response to the Black Economy Taskforce

3.37In the Auditor-General Report No. 39 2022–23 the ANAO reiterated that information management is ‘fundamental to sound public sector administration, and that standard principles for the management of information are set out under the Archives Act 1983 (Cth) and the Public Governance, Performance and Accountability Act 2013 (Cth) (PGPA Act).[78]

3.38The ANAO’s audit of the response to the Black Economy Taskforce recommendations identified that poor IM had impaired Treasury’s ability to effectively coordinate and implement these measures:

[The audit] identified that Treasury had poor information management practices which created risks around Treasury's ability to provide quality and timely advice and reporting on the shadow economy to the Government, and to create an effective shadow economy policy environment.[79]

3.39The audit additionally found that Treasury fell short of its recordkeeping responsibilities in implementing the Black Economy Taskforce response, such that neither Treasury staff nor implementation partners could ‘find information when need[ed] [nor] trust the completeness and accuracy of the information’.[80] The ANAO highlighted the following concerns in this regard:

  • records were not always available to support efficient and continuous business
  • records of key decisions were not always documented
  • records did not always provide evidence of policy and program development and implementation
  • records did not allow for transparency and accountability.[81]
    1. The audit revealed that content relating to the shadow economy on Treasury’s website had not been updated and included information on a now defunct advisory board, used the term ‘black economy’ instead of ‘shadow economy’, and contained outdated policy information, news, and media,[82] creating a risk of misinformation.
    2. The audit recommended that Treasury employ policies and procedures to ensure its IM systems were fit for purpose, and that it review and update content related to the shadow economy on its website.[83]

Agency Responses

Implementation planning and support

Department of Health and Aged Care

3.42In response to the audit recommendations, Health advised the ANAO that it agreed in-principle to consider the lessons learned from the COVID-19 response, noting that parameters and an approach for a broader pandemic review were ‘yet to be determined by the Government’.[84] Health also advised ANAO in its audit response that it had considered the lessons learned from the COVID-19 telehealth expansion when implementing the permanent telehealth measures.[85] Health further noted that the Minister for Health and Aged Care had requested the MBS Review Advisory Committee (MRAC) to undertake an evaluation of the permanent expansion of telehealth services.[86]

3.43In its submission to the inquiry, Health advised that its internal implementation planning and tracking is appropriate, but acknowledged that it is not geared towards changes to ‘the MBS which undergoes many amendments annually’.[87] Health stated in this regard:

The Department is taking steps to formalise, at the policy development stage, consideration of whether MBS amendments are ‘material’ and therefore should be managed as a project, whether additional specific post-implementation evaluation is required; and if so, identification of relevant resources required and suitable timing.

The outcome from this project will assist MBS policy staff with the documentation for the management of implementation...[88]

3.44Health also confirmed in its submission and at the public hearing on 2 February 2024 that it was committed to improving its program monitoring and evaluation of the permanent telehealth measures, and is tracking its progress against the ANAO’s recommendations. Health further advised the Committee that MRAC’s post-implementation review of MBS telehealth arrangements was nearing completion following public consultation on the draft report at the end of 2023.[89] MRAC’s final report had not been published at the time of writing.[90]

Department of Home Affairs

3.45Home Affairs responded to the audit findings and recommendations that it had developed an assortment of management practices to support its efficiency and effectiveness in delivering the Family Migration Program and in meeting government requirements. The ANAO further advised however that these practices needed to be fully documented to ensure responsibilities for case management strategies are clear and that practices could be reviewed and evaluated.[91]

3.46Home Affairs submitted to the inquiry that it was undertaking work in response to the audit recommendations, to ensure consistency of its business processes.[92] In particular, the department indicated that it had held six meetings since January 2023, to establish ‘overarching policy, governance and principles for case allocation’.[93] Home Affairs further indicated in its submission that written guidance was developed and distributed in April and June 2023, detailing case allocations, processes, treatment recommendations, and guidelines for prioritising visa applications on compassionate and compelling grounds.[94]

3.47Home Affairs also stated in its submission that it was developing ‘an overarching framework [to] support existing case allocation tools…guided by [its] Family Program Service Design and Immigration Programs Business Improvement Strategy to deliver united and holistic outcomes’.[95] Home Affairs reiterated to the Committee at the public hearing on 1 February 2024 that it continues to strengthen its capabilities, including its business processes, in accordance with the ANAO’s recommendations.[96]

Communication

Department of Health and Aged Care

3.48Although Health did not respond directly to the ANAO’s criticism regarding an absence of a communications strategy in either its submissions or at the public hearing on 2February 2024, it affirmed at the hearing that:

The department recognises its responsibility to government and to the Australian community to ensure the integrity of the Medicare program. It continues to improve its internal processing response to the ANAO recommendations.[97]

Department of Home Affairs

3.49In response to the audit findings and to Committee queries at the hearing on 1February2024 regarding processing delays, Home Affairs advised that it recognised that some applicants were experiencing lengthy delays on the outcome of their visa applications:

…our officers are very conscious that they’re real people…particularly in the family program.[98]

...

There’s a very close focus on what sorts of outputs we’re achieving. Government has made a significant investment…in providing us with 500 additional staff, and we are accounting for that. We report weekly to our ministers on progress across all of our case loads.[99]

3.50Home Affairs submitted to this inquiry that it is also undertaking initiatives to improve its communication with clients that include:

  • new tools ‘to proactively monitor and manage caseloads’
  • priority processing on compelling and compassionate grounds
  • regular monitoring for applications due to expire or that cannot be extended to ensure finalisation prior to expiry
  • website updates to provide applicants with ‘meaningful information… in an easy-to-access manner [and] convey a more realistic processing time’
  • new approaches to give clients timely and helpful advice on their applications, including digital and online self-service tools to assist with status-related enquiries
  • regular updates and enhancements to improve and streamline online applicant experiences.[100]
    1. In response to the audit, Home Affairs advised the ANAO that it has developed policy and procedural guidelines to provide clear directions on responding to client feedback, including family visa processing. Processes and structures had been developed within its Immigration Programs Division to support consistency and timely delivery across its visa programs. Quality control checks and assurance activities were also routinely being undertaken, both prior to applications being finalised and on completion.[101]

Department of Agriculture, Fisheries and Forestry

3.52Since the ANAO’s audit, DAFF has advised it no longer uses the Blueprint[102] to drive its cultural reform program and instead uses its new Transformation Action Plan—published in November 2023.[103]

3.53At the hearing on 12 March 2024, the Committee questioned how DAFF had addressed the concerns raised by the ANAO. DAFF advised that following the appointment of the new secretary in August 2023, an organisational transformation taskforce was commissioned to build on previous reviews and the Blueprint, to take up recommendations that had not implemented, and develop the Transformation Action Plan.[104] DAFF further commented that:

If you've got a set of recommendations, it really is working through your full executive all the way to your frontline service delivery staff so that it's not just talked about but led from a cultural perspective. In the development of the transformation action plan, a very important part of the work for us was engagement across our entire organisation, in person and online.

… that's been a particular focus of deep staff engagement, so that we're getting that cultural change as well as business change.[105]

Coordination

Department of the Treasury

3.54Treasury’s response to the ANAO noted its commitment to addressing the performance audit findings but asked for acknowledgement of the progress already achieved in relation to the taskforce recommendations, the impact of reprioritising resources to support the Government’s COVID-19 response, and that it was continuing to improve its program management approach.[106]

3.55At the hearing on 1 February 2024, the Committee noted that the poor findings in the ANAO’s report were uncharacteristic of those that Treasury received in other audits. Treasury responded:

Treasury…is primarily a policy agency, not an implementation agency…It wasn’t our core business at the time.[107]

…we did launch a program management framework in 2022 so that in future, when things come up, people have a place to start. That’s been an important stepping stone in the maturity of the organisation that didn’t exist at the time of the black economy.[108]

3.56The ATO indicated in its submission to the inquiry that it was liaising closely with Treasury on cross-agency working arrangements and that the following provisions would achieve the optimal outcomes in this regard:

  • cross-agency monitoring and evaluation arrangements
  • clearly defined responsibilities and accountabilities for coordination of cross-agency activities
  • high levels of mutual trust to support early facilitation and escalation to rapidly resolve issues.[109]

Information management

Department of Agriculture, Fisheries and Forestry

3.57DAFF advised in its audit response that it would continue progressing its project plans to update non-high-risk IM and website content; review its project plans to ensure ANAO observations were addressed; and use its assurance and compliance processes to ensure IM remained up-to-date and functioned correctly.[110]

3.58In its submission to the inquiry, DAFF stated that it had developed implementation plans to address the ANAO’s recommendations, and that these ‘are on track to be implemented within two years’ of the audit report’s publication.[111]

3.59In response to questions from the Committee at the public hearing on 2 February 2024, DAFF advised that ‘all our high-risk stuff is still up to date, but the low-risk stuff comes and goes about being in and out of date all the time’.[112]

3.60DAFF again confirmed in its supplementary submission to the inquiry that all high-risk IM had been updated and published as of March 2021, in time for the commencement of the new Framework. DAFF submitted that updates to the remaining 189 medium and low risk IM are required to be completed by 18 October 2024, and of these, 128 had been finalised. The department also confirmed that they are on track to complete the remaining 61IM by October 2024.[113]

3.61DAFF remarked further in this regard at the 2 February 2024 hearing:

Instructional material…is always something we have to keep a very close eye on, and we try to make sure that we're always up to date...We're always trying to find out ways to improve it and the timeliness of it…We're trying to move away from high levels of written material to more videos.[114]

Department of the Treasury

3.62Treasury advised in its response to ANAO that it was continuing to make changes to improve its IM approach—this work commenced in December 2020.[115] The department further noted that it had:

  • implemented an information strategy and established a governance Committee that focuses on information strategy
  • improved its information storage systems policies
  • transitioned to SharePoint Online, and
  • introduced mandatory information management training for all staff.[116]
    1. Treasury advised ANAO also that it had updated its content on 24 May 2023.[117] While the ANAO acknowledged this response, it reported that these updates did not address all the issues it had identified during the audit process.[118]

Committee comment

3.64Quality policy planning and implementation are critical to ensuring government policy and program success, providing an approach and guidance for effective implementation. Clear plans also establish responsibilities and ensure consistency, which lead to the fulfilment of policy objectives.

3.65Sound implementation plans are vital to ensuring the successful implementation and delivery of government policies and programs. Implementation support provides a transitional link between the initial implementation phase and long-term performance of programs. It allows for the incorporation of feedback, adjustments, and improvements to achieve positive outcomes and program objectives.

3.66DAFF did not provide any specifics on how it is improving communication with staff on its cultural reform program. It will, therefore, remain to be seen if this improves with the implementation of the department’s Transformation Action Plan.

3.67Effective communication fosters transparency and trust. A well-designed communication strategy ensures clarity, understanding and cooperation, helps to manage expectations and reduces duplication. A good communication plan and ongoing communication leads to successful outcomes and achievement of policy objectives.

3.68Coordination plays a pivotal role in successfully implementing policy programs and initiatives across multiple agencies. It ensures the various departments are aware of their roles and responsibilities and can work harmoniously towards policy objectives.

3.69Up-to-date instructional materials (IM) and documentation are essential to support public sector staff successfully implementation of government programs. They ensure understanding and consistency in executing and achieving policy objectives.

3.70Australia’s Partner Visa charge is amongst the highest globally, if not the highest. Notwithstanding the fact that visa charges are considered a tax and hence not subject to cost recovery policies, Home Affairs was unable to provide any evidence as to the efficient cost of administrating the partner visa program and the extent to which the current fee is linked to cost recovery even as a benchmark. Given the issues of social equity which arise when considering the ability of low-income Australians to afford the current fee, there is a strong case for Home Affairs to undertake further work and advise government on options which could include consideration of a freeze in the partner visa fee.

Recommendation 2

3.71The Committee recommends that the Department of Agriculture, Fisheries and Forestry reports back to it on its progress with its Transformation Action Plan within 12 months of the date of this report.

Recommendation 3

3.72The Committee recommends that the Department of Home Affairs undertake further analysis of the efficient cost of administering the partner visa program (including integrity functions) and provide advice to government regarding the current fee.

Footnotes

[1]Office of Impact Analysis (OIA), Australian Government Guide to Policy Impact Analysis, viewed 3 June 2024, https://oia.pmc.gov.au/sites/default/files/2024-01/australian-government-guide-to-policy-impact-analysis.pdf.

[2]Department of Prime Minister and Cabinet, Delivering Great Policy Model, Practical to Implement, viewed 3 June 2024, https://www.apsacademy.gov.au/aps-craft/strategy-policy-evaluation/delivering-great-policy/practical-implement.

[3]OIA, Australian Government Guide to Policy Impact Analysis, p. 16.

[4]OIA, Australian Government Guide to Policy Impact Analysis, p. 22.

[5]OIA, Australian Government Guide to Policy Impact Analysis, p. 33.

[6]OIA, Australian Government Guide to Policy Impact Analysis, p. 40.

[7]OIA, Australian Government Guide to Policy Impact Analysis, pages 39–40.

[8]Auditor-General Report no. 6 2022–23, Implementation of Export Control Legislative Framework, p. 11.

[9]Auditor-General Report No. 17 2022–23, Department of Agricultura, Fisheries and Forestry Cultural Reform, p. 12.

[10]Auditor-General Report No. 17 2022–23, p. 12.

[11]Auditor-General Report No. 39 2022–23, Implementation of the Government Response to the Black Economy Taskforce Report, p. 13.

[12]Auditor-General Report No. 39 2022–23, p. 12.

[13]Auditor-General Report No. 10 2022–23, Expansion of telehealth services, p. 40.

[14]Auditor-General Report No. 10 2022–23, p. 40.

[15]Auditor-General Report No. 10 2022–23, p. 8.

[16]Auditor-General Report No. 10 2022–23, p. 36.

[17]Department of Health and Aged Care (Health) 2020, Australian Health Sector Emergency Response Plan for Novel Coronavirus (COVID-19), Australian Government, p.36.

[18]Health 2020, Australian Health Sector Emergency Response Plan for Novel Coronavirus (COVID-19), Australian Government, p.36.

[19]Auditor-General Report No. 10 2022–23, p. 36.

[20]Auditor-General Report No. 10 2022–23, p. 38.

[21]Auditor-General Report No. 10 2022–23, pages 67 and 70.

[22]Auditor-General Report No. 10 2022–23, pages 10 and 50.

[23]Auditor-General Report No. 16 2022–23, Management of Migration to Australia—Family Migration Program, p. 8.

[24]Auditor-General Report No. 16 2022–23, p. 56.

[25]Auditor-General Report No. 16 2022–23, p. 62.

[26]Auditor-General Report No. 16 2022–23, p. 73.

[27]Auditor-General Report No. 16 2022–23, p. 76.

[28]Auditor-General Report No. 16 2022–23, p. 52.

[29]Auditor-General Report No. 16 2022–23, p. 61.

[30]Auditor-General Report No. 16 2022–23, p. 62.

[31]Mr Matthew Noble, Acting Assistant Secretary, Family Visas, Department of Home Affairs, Committee Hansard, Canberra, 1 February 2024, pages. 15–16.

[32]Department of Home Affairs, Submission 3:1, Answer to Question on Notice, [p. 2].

[33]Department of Home Affairs, Submission 3:1, [p. 2].

[34]Auditor-General Report No. 10 2022–23, pages 50 and 52–53.

[35]Auditor-General Report No. 10 2022–23, pages 50–54.

[36]Auditor-General Report No. 10 2022–23, p. 39.

[37]Auditor-General Report No. 10 2022–23, pages 39 and 54.

[38]Auditor-General Report No. 10 2022–23, p. 52.

[39]Committee Hansard, Canberra, 2 February 2024, p. 31.

[40]Auditor-General Report No. 10 2022–23, p. 49.

[41]Auditor-General Report No. 10 2022–23, p. 49.

[42]Auditor-General Report No. 16 2022–23, p. 19.

[43]Auditor-General Report No. 16 2022–23, p. 41.

[44]Auditor-General Report No. 16 2022–23, pages 8–9.

[45]Auditor-General Report No. 16 2022–23, p. 41.

[46]Auditor-General Report No. 16 2022–23, p. 41.

[47]Auditor-General Report No. 16 2022–23, pages 8–9.

[48]Auditor-General Report No. 16 2022–23, p.45.

[49]Auditor-General Report No. 16 2022–23, p.46.

[50]Auditor-General Report No. 16 2022–23, pages 45–46.

[51]Auditor-General Report No. 16 2022–23, pages 45–46.

[52]Auditor-General Report No. 16 2022–23, pages 9 and 47.

[53]Auditor-General Report No. 16 2022–23, pages. 8 and 40–41.

[54]Auditor-General Report No. 16 2022–23, p. 40.

[55]Auditor-General Report No. 17 2022–23, Department of Agriculture, Fisheries and Forestry cultural reform,p. 17.

[56]Auditor-General Report No. 17 2022–23, pages 9–10 and 20, 24, 28, 31–33.

[57]Auditor-General Report No. 17 2022–23, p. 20.

[58]Health 2020, Australian Health Sector Emergency Response Plan for Novel Coronavirus (COVID-19), Australian Government, pages 50–51.

[59]Auditor-General Report No. 39 2022–23, Implementation of the Government Response to the Black Economy Taskforce Report, pages 6, 8 and 22.

[60]Auditor-General Report No. 39 2022–23, pages 6, 8–9, 22, 26, 32.

[61]Auditor-General Report No. 39 2022–23, p. 27.

[62]Auditor-General Report No. 39 2022–23, p. 32.

[63]Mrs Laura Berger-Thomson, First Assistant Secretary, Personal and Indirect Tax and Charities Division, Department of the Treasury, Committee Hansard, Canberra, 1February2024, p. 5.

[64]Auditor-General Report No. 39 2022–23, p. 32.

[65]Auditor-General Report No. 39 2022–23, p. 32.

[66]Auditor-General Report No. 6 2022–23, p. 8.

[67]Auditor-General Report No. 6 2022–23, p. 37.

[68]Auditor-General Report No. 6 2022–23, p. 38.

[69]Auditor-General Report No. 6 2022–23, pages 23 and 35.

[70]Auditor-General Report No. 6 2022–23, pages 35–36.

[71]Auditor-General Report No. 6 2022–23, p. 35.

[72]Auditor-General Report No. 6 2022–23, pages 35–36.

[73]Auditor-General Report No. 6 2022–23, pages 35–36.

[74]Auditor-General Report No. 6 2022–23, pages 8 and 37.

[75]Auditor-General Report No. 6 2022–23, p. 38.

[76]Auditor-General Report No. 6 2022–23, p. 59.

[77]Auditor-General Report No. 6 2022–23, p. 39.

[78]Auditor-General Report No. 39 2022–23, p. 23.

[79]Mr Grant Hehir, Auditor-General, Australian National Audit Office, Committee Hansard, Canberra, 1 February 2024, p. 2.

[80]Auditor-General Report No. 39 2022–23, p. 24.

[81]Auditor-General Report No. 39 2022–23, p. 23.

[82]Mr Grant Hehir, Auditor-General, Australian National Audit Office, Committee Hansard, Canberra, 1 February 2024, pages 28, 35.

[83]Auditor-General Report No. 39 2022–23, pages 10, 22, 27–28.

[84]Auditor-General Report No. 10 2022–23, p. 67.

[85]Auditor-General Report No. 10 2022–23, p. 67.

[86]Auditor-General Report No. 10 2022–23, p. 70.

[87]The Department of Health, Submission 4, p. 6.

[88]The Department of Health, Submission 4, p. 6.

[89]The Department of Health, Submission 4, p. 3, 10–11; Mr Daniel McCabe, Acting Deputy Secretary, Health Resourcing Group, Department of Health and Aged Care, Committee Hansard, Canberra, 2 February 2024, p. 27–28.

[90]The Department of Heath 2023, ‘Medicare Benefits Schedule Review Advisory Committee Draft Report: Post Implementation Review of Telehealth MBS items’, viewed 16 May 2024, https://consultations.health.gov.au/medicare-reviews-unit/mrac-draft-report-post-implementation-review-of-te/; The Department of Health 2021, ‘Medicare benefits Schedule continuous review to improve patient care’, viewed 16 May 2024, https://www.health.gov.au/news/medicare-benefits-schedule-continuous-review-to-improve-patient-care.

[91]Auditor-General Report No. 16 2022–23, p. 62.

[92]Home Affairs, Submission 3, p. 3.

[93]Home Affairs, Submission 3, p. 6.

[94]Home Affairs, Submission 3, p. 6.

[95]Home Affairs, Submission 3, p. 6.

[96]Mr Michael Willard, Acting Deputy Secretary, Immigration, Department of Home Affairs, Committee Hansard, Canberra, 1 February 2024, p. 12.

[97]Mr Daniel McCabe, Department of Health and Aged Care, Committee Hansard, Canberra, 2 February 2024, p. 28.

[98]Mr Michael Willard, Department of Home Affairs, Committee Hansard, Canberra, 1 February 2024, p. 14.

[99]Mr Michael Willard, Department of Home Affairs, Committee Hansard, Canberra, 1 February 2024, p. 15.

[100]Department of Home Affairs, Supplementary Submission 3.1, pages. [42–44].

[101]Auditor-General Report No. 16 2022–23, pages 3–4.

[102]Being Future Ready: Our Future Department Blueprint 2021–2025 (the Blueprint) was developed as a roadmap to coordinate ongoing reform activities and areas of reform focus, this was developed in September 2021 by the Department of Agriculture, Water and the Environment (DAWE) now know as DAFF.

[103]Department of Agriculture, Fisheries and Forestry, Supplementary Submission 5.1, p. [18].

[104]Mr Adam Fennessy, Secretary, Department of Agriculture, Fisheries and Forestry, Committee Hansard, via Videoconference, 12 March 2024, pages 1–2 and 6.

[105]Mr Fennessy, Department of Agriculture, Fisheries and Forestry, Committee Hansard, via Videoconference, 12 March 2024, p. 6.

[106]Auditor-General Report No. 39 2022–23, p. 12.

[107]Mrs Berger-Thomson, Department of the Treasury, Committee Hansard, Canberra, 1February2024, p. 5.

[108]Dr Angela Barrett, Chief Operating Officer, Department of the Treasury, Committee Hansard, Canberra, 1February2024, p. 5.

[109]Australian Tax Office, Supplementary Submission 7.1, p. [5].

[110]Auditor-General Report No. 6 2022–23, p. 39.

[111]Department of Agriculture, Fisheries and Forestry, Submission 5, p. 4.

[112]Mr Matthew Koval, First Assistant Secretary, Trade and International, Department of Agriculture, Fisheries and Forestry, Committee Hansard, Canberra, 2 February 2024, p. 7.

[113]Department of Agriculture, Fisheries and Forestry, Supplementary Submission 5.1, p. [15].

[114]Mr Matthew Koval, First Assistant Secretary, Department of Agriculture, Fisheries and Forestry, Committee Hansard, Canberra, 2 February 2024, p. 7.

[115]Auditor-General Report No. 39 2022–23, p. 27; Department of the Treasury, Submission 6, pages 2, 4–5.

[116]Department of the Treasury, Submission 6, p. 2.

[117]Auditor-General Report No. 39 2022–23, p. 28; Department of the Treasury, Submission 6, p. 5.

[118]Auditor-General Report No. 39 2022–23, pages 28, 81.