The objective of the audit was to assess the effectiveness of the Department of Health and Ageing’s administration of the GP Super Clinics program to support improved community access to integrated GP and primary health care services.
1. New Directions for Australia’s Health: Delivering GP Super Clinics to local communities (the GP Super Clinics policy) was released by the Australian Labor Party (ALP), then in opposition, on 24 August 2007.1 The policy outlined a plan to fund the establishment of an unspecified number of ‘GP Super Clinics’ across the country that would provide multidisciplinary care and help reduce pressure on Australia’s hospitals.2 In regard to the specific location of Super Clinics, the policy provided that the ‘factors that will be taken into account ... will include’ areas:
- where there is currently poor access to services, particularly where this is due to shortages of doctors;
- where there is currently poor health infrastructure;
- where a clinic could help take the pressure off local public hospital services; and
- with high levels of chronic disease and/or demographics with high needs, such as large numbers of children or elderly residents.
2. Following the release of the policy, the locations of 32 proposed GP Super Clinics3 were announced progressively in the lead-up to the 2007 federal election, held on 24 November, along with the indicative maximum level of grant funding for each location. Another five proposed locations were announced in August 2009 by the Labor Government, taking the total of ‘first round’ clinic locations to 37. A second round of funding, as part of the National Primary Health Care Strategy, was announced in the context of the May 2010 Budget, to establish ‘around’ 23 new GP Super Clinics. The locations for 28 new clinics were subsequently announced by the Government during the 2010 election campaign. With the exception of the five clinics announced in 2009, the location of individual GP Super Clinics reflected policy announcements made in the context of the 2007 and 2010 federal elections.
3. Across the two funding rounds, $418.7 million in grant funding was announced to establish 65 GP Super Clinics. As at 5 April 2013, $396.6 million has been committed through executed funding agreements, with $278.4 million expended. Funding for individual clinics has ranged from $1 million to $15 million, and a number of clinics have been jointly funded by state and territory governments.
4. While the incoming government’s 2007 GP Super Clinics policy did not specify how capital funding for the clinics would be made available, the GP Super Clinics program subsequently established in 2008 provided for a mix of competitive and non-competitive grant processes. Typically, non-competitive grant processes were adopted where a clinic was to be built by a state health department, regional or community health service, Division of General Practice or local council. In total, non-competitive processes were adopted for 22 of the 65 locations.4
5. The Department of Health and Ageing (DoHA) administers the GP Super Clinics program. The department’s responsibilities have included the: provision of policy and program advice; development of program guidelines; assessment of grant applications; selection of a preferred applicant for each location; negotiation of funding agreements; and administration of funding agreements. While the two funding rounds are now largely complete5, there will be an ongoing administrative role for DoHA, as a condition of the grant funding is that the clinics must operate for 20 years and continue to report to DoHA during this time.
6. Commencing in December 2007, at the time the GP Super Clinics program was under development, significant enhancements were made to the Australian Government’s grants administration framework. The enhancements included the introduction, initially through Finance Minister’s Instructions promulgated in 2007 and revised in 2009, of requirements for published program guidelines, departmental advice on grant applications, and public reporting of the award of grants. In July 2009, the Commonwealth Grant Guidelines (CGGs)6 came into effect and related changes were made to the Financial Management and Accountability Regulations 1997 (FMA Regulations). Whilst 16 first–round GP Super Clinic grants were awarded before the CGGs and associated FMA Regulations amendments came into force on 1 July 2009, the enhancements to the grants framework introduced between 2007 and 2009 applied to the program, as did the financial framework requirement for the ‘proper use’ of public money, which pre–dated the CGGs and applied to all GP Super Clinic grants.
Audit objective and scope
7. The objective of the audit was to assess the effectiveness of DoHA’s administration of the GP Super Clinics program to support improved community access to integrated GP and primary health care services.
8. The audit examined DoHA’s compliance with the mandatory requirements of the CGGs and the extent to which DoHA adopted sound practices in relation to the key principles for grants administration in the CGGs. In cases where grants were approved prior to the CGGs coming into effect the audit examined compliance with the applicable parts of the relevant Finance Minister’s Instructions of December 2007 and January 2009.
9. While the audit examined whether DoHA had considered the issue of local health needs in its administration of the program, it did not assess whether GP Super Clinics had a direct business or economic impact on existing primary healthcare facilities.
10. The GP Super Clinics program is one of a number of health infrastructure grant programs administered by DoHA in recent years7, and is intended to improve access to integrated primary health care services8 and improve opportunities for education and training placements in a multidisciplinary setting. Over two funding rounds administered by the department between 2008 and 2012, grant funding of $418.7 million has been announced for 65 GP Super Clinics across Australia. Individual clinics have variously received capital funding, recurrent funding and relocation incentives, through a combination of competitive and non-competitive grants processes. As a condition of Commonwealth funding, clinics are expected to operate in accordance with the program objectives for 20 years, leaving an administrative role for the department which will continue long after the clinics are established and grant funds are disbursed.
11. Overall, DoHA’s administration of the GP Super Clinics program has been generally effective and consistent with government policy. In support of the incoming government, DoHA acted quickly, within relatively tight timeframes, to consult with stakeholders on program design, assess and plan for risks, and draft grant guidelines, and was consequently in a position to provide well developed first round program guidelines for ministerial consideration by April 2008. These guidelines addressed the key elements of the program’s operation and formed the basis for a generally sound grants application and assessment process. Revised program guidelines were issued for the second round and essentially the same application process was employed. The funding agreements used by the department evolved over time, in light of experience and in response to emerging issues.9 The department also placed considerable emphasis on operational reporting; recognising the challenges the clinics would face in their construction and early operational phases.
12. As part of developing the relevant new policy proposal (NPP), in less than four weeks following the election of the new government in 2007, DoHA advised the incoming Minister on a range of program implementation risks. A risk identified by DoHA in its advice was the degree of ‘acceptance and support’ for the announced clinics by local communities and health professionals, including possible concerns about impacts on existing health services. The department proposed that this risk be managed through consultations with stakeholders both nationally and at the local level, with the latter focussing on ensuring that proposals addressed local needs and priorities and complemented existing services. However, while the department provided the Minister with some general background information on the Divisions of General Practice in which the announced clinics were located, its advice did not address whether it was aware of any particular implementation risks applying to the specific locations announced in the context of the 2007 election.
13. Further, notwithstanding the incoming government’s decision that all guidelines for new discretionary grant programs be submitted for consideration by the Expenditure Review Committee of Cabinet (ERC)10, this was not done. While the program guidelines were approved by the Minister in April 2008, DOHA’s briefing seeking ministerial approval did not advise her of the requirement for ERC consideration. The guidelines for the second round were however submitted for ERC consideration.
14. As discussed above, DoHA assessed potential risks and their treatment early, in the context of its original planning and design of the program. One issue that would have benefited from further consideration related to the use of both competitive and non-competitive processes to select funding recipients within the one program11, and the attendant risks to be managed.12 In the event, non-competitive processes were adopted for 22 of the 65 locations, typically where a clinic was to be built by a state health department, regional or community health service, Division of General Practice or local council.
15. DoHA’s approach to risk management for the program has evolved over time, drawing on lessons learned from the first round. The department sought to better manage risks through changes to funding agreement requirements and its internal processes; measures which improved the overall effectiveness of program administration in the second funding round. Nonetheless, a range of complex issues, including land acquisition and development approval matters which have delayed the completion of certain clinics, are likely to remain an ongoing challenge for the department. These and related issues have emerged in the other infrastructure grants programs administered by DoHA, and the ANAO has observed in previous audits13 that DoHA has over time strengthened its capacity to effectively administer such grant programs, informed by practical experience and initiatives such as the establishment of the Centre for Capital Excellence within the department, comprising staff with expertise in infrastructure project management.
16. In light of the experience gained by DoHA in the administration of a variety of infrastructure projects over some years, there is scope for the department to draw on and document its experience, including the scope for applying a more consistent and systematic approach to the assessment of value for money. This process could consider the use of commercially available ‘cost per square metre calculation’ tools in infrastructure programs, which did not feature in the assessment process for the first round of GP Super Clinics.14
17. As at 5 April 2013, funding agreements for all of the first round locations have been executed and 29 of the 36 clinics15 have been completed and are operational; with seven not yet completed.16 For the second round, funding agreements for 24 of the 28 clinic locations have been executed and one clinic is operational, with so–called ‘early services’17 being provided from existing premises at another seven locations. The time taken from the execution of funding agreements to the completion of clinics has varied considerably, reflecting amongst other things, delays associated with resolving often complex issues of land tenure, development approvals and construction works.
18. The ANAO’s analysis of operational reporting to DoHA on 18 first round clinics indicates that the majority of these clinics are making good progress towards achieving some key service delivery expectations, though recruiting and retaining sufficient staff has been the biggest challenge for most clinics. However, the key performance indicators for the program are framed in a qualitative and descriptive manner and there would be merit in enhancing them to support longer term reporting to the Parliament and government on the extent to which the program is achieving its intended outcomes. With the maturing of an increasing number of clinics, it is timely for DoHA to consider revising the overarching framework for reporting on the performance of individual GP Super Clinics and the program as a whole.
19. The ANAO has made four recommendations. One relates to providing Ministerial advice on implementation risks in the establishment phase of grant activities, one addresses better practice assessment of value for money for health infrastructure projects and two propose improvements to the framework for reporting on program performance.
Key findings by chapter
Chapter 2: From Policy to Program
20. The ANAO has previously observed that departments should advise Ministers on any measures considered necessary to manage risks to the Commonwealth achieving value for money when acting on election commitments.18 In the lead up to the 2007 election the ALP announced 32 proposed locations for GP Super Clinics. Following the election, DoHA provided advice to the Minister that a key implementation risk was the degree of ‘acceptance and support’ for the announced clinics by local communities and health professionals—including possible concerns about impacts on existing health services—and proposed that this risk be managed through consultations.
21. However, the department did not advise the Minister whether it was aware of any particular implementation risks applying to the specific locations announced in the context of the incoming government’s 2007 election policy. A range of options were potentially available for doing so, including some analysis, in the time available, of the extent to which the announced locations potentially satisfied some or all of the four factors outlined in the incoming government’s GP Super Clinics policy.19 The department advised the ANAO that it considered there was insufficient and unsophisticated data available at the time to draw conclusions on location issues. While some information and analysis was provided to the Minister’s office by DoHA on a number of factors that might inform the choice of clinic locations in the second round in 2010, that information was of a relatively informal nature through emails to ministerial staff rather than a formal briefing to the Minister.20 To inform the development and administration of infrastructure grant activities, the ANAO has proposed that the department advise Ministers of any significant risks to the effective implementation of election policy commitments.
22. In response to a question on notice at Senate Estimates in early 2011 regarding the 65 locations announced across the two rounds, DoHA commissioned a broad post–hoc analysis against the four factors in the 2007 election policy, plus an additional fifth factor of high population growth. The analysis indicated that a high proportion (83.8 per cent) of first round clinic locations met one or two of the five factors.21 Conversely, a reasonably high proportion (71.4 per cent) of second round clinics met three or more factors.
23. Over one-third of the 65 locations were subject to non-competitive grant processes. The choice of competitive or non-competitive processes was informed by the media statements released in the election context22, and bilateral discussions with other jurisdictions where relevant.23 Based on these considerations, DoHA sought and received confirmation from the Minister for both rounds as to which process should apply to the individual clinics announced by the Government. However, DoHA’s advice to the Minister on program implementation did not address the risks to be managed24 in adopting a non-competitive process for specific locations. The ANAO observed that typically, non-competitive grant processes were adopted where a clinic was to be built by a state health department, regional or community health service, Division of General Practice or local council.
24. While the first round GP Super Clinics program guidelines suggested that the program was at that stage restricted to the 32 locations announced in the 2007 election context, a number of unsolicited proposals for GP Super Clinics funding were submitted to DoHA and the Minister during 2008 and 2009. These received varying treatment. One proposal received in early 2008 for the establishment of a clinic in the Australian Capital Territory was rejected by the Minister on the basis that a GP Super Clinic ‘was not planned for the [ACT] at this time’.25 However, a further five unsolicited proposals received over the period late 2008 to early 2009 were the subject of detailed departmental advice to the Minister and were subsequently included in the program. The department’s advice did not address the issue of whether, in the absence of any analysis against other areas of poor access to health services, and the reference in the program guidelines to the specified locations, it was equitable or appropriate that the new locations be considered for potential funding. Following further development, these proposals were formally assessed by the department and collectively received $26.2 million of funding under the program.
25. Analysis of the distribution of the clinic locations announced in the 2007 election context shows that 54.8 per cent of clinics were located in marginal electorates; these clinics also accounted for 65.7 per cent of the announced indicative funding. This compares with 31 per cent of electorates being marginal in the 2007 election. In relation to the remaining clinics—the five announced in 2009 and those announced in the 2010 election context—43.8 per cent were in marginal electorates; these clinics also accounted for 43.7 per cent of the announced indicative funding. This compares with 37 per cent of electorates being marginal in the 2010 election. Further analysis of clinics announced in marginal electorates, on the basis of District of Workforce Shortage (DWS) status26, shows that 82.4 per cent of these clinics announced in 2007 were in a DWS. For the remaining clinics announced in 2009 and 2010 that were in marginal electorates, 57.1 per cent were also in a DWS.
Chapter 3: Selection Processes
26. DoHA established a generally sound and well documented framework for assessing applications.27 The department made extensive use of relevant expertise from medical and independent financial advisers and accessed probity advice to align its approach with better practice in grants administration.
27. While the GP Super Clinics program guidelines required applications to address the extent to which a proposed clinic could impact on existing health services, this issue was not explicitly or substantively considered in the overall application assessment.28 DoHA faced challenges in determining whether applications for funding would meet local needs and whether a proposed clinic would affect existing health services. There was limited, if any, specific information from independent sources about existing health services available to assessment panels, which had to rely almost entirely on information contained in applications, which was of variable quality.
28. The ANAO observed a number of opportunities for DoHA to improve how it assessed value for money. In respect to the assessment of physical infrastructure, assessment panels were not asked to use commercially available ‘cost per square metre calculation’ tools during the first round. The consideration of value for money was also hampered by a lack of clear and specific guidance to assessment panels on assessing the value for money of physical infrastructure, resulting in a lack of clarity and consistency in how the concept was applied in the assessment and selection process. In terms of the services to be delivered by clinics, of the six locations in the ANAO’s sample where a grant of up to $15 million was available to establish a GP Super Clinic, DoHA did not explicitly assess whether the specialised services required under the program guidelines for these locations were appropriately addressed in the applications.
29. In instances where the initial Invitation to Apply process did not identify a successful applicant, DoHA used a variety of strategies and processes to generate new or substantially revised applications and subsequently assess the merits of those applications. The processes adopted in these cases were generally adequate and there was a positive trend in the second round where DoHA involved the Minister earlier in advising on risks and options, especially where non-competitive processes were involved. However, the absence of a full panel assessment in some instances meant that the expertise of a medical adviser was not used in assessing some applications.
Chapter 4: Rolling out the Clinics
30. In establishing the program, DoHA assessed and planned for a range of program implementation risks. During the first funding round, there were nonetheless occasions when DoHA’s risk management approach in the awarding of grants, and subsequently managing risks in the early stages of clinic roll-out, lacked rigour. This contributed to the eventual inability to establish a clinic at Sorell, where the estimated cost of constructing a clinic exceeded available grant funding by around $880 000, as well as being a factor in the long delay in opening the Redcliffe clinic.29
31. In the case of Sorell, DoHA took six months to fully recognise and respond to the risks of a budget shortfall after the funding recipient advised the department that it had concerns about the adequacy of the amount available under the GP Super Clinics grant. While the department responded appropriately once the shortfall was confirmed (after the receipt of building quotes), earlier engagement with the funding recipient on building design and construction costs would have enabled the department to better manage the risk. In the case of the Redcliffe project, while the department identified a number of financial risks during the assessment stage of the initial $5 million grant, and a mitigation strategy was proposed (including finding a financial guarantor for the project and / or reducing its capital cost), the FMA Regulation 9 documentation did not refer to whether the identified risks had in fact been treated, and a funding agreement for $5 million was subsequently signed without explicit provisions relating to those risks. In the event, the recipient was unable to secure a loan to fund any of the project’s cost30, resulting in a significant increase in the Commonwealth contribution towards construction works; from $5 million to $13.2 million.
32. Overall, DoHA’s compliance with the requirements of the Commonwealth financial management framework in the awarding of grants has been generally sound. Exceptions related to the FMA Regulation 9 documentation for Redcliffe, discussed above, and non-compliance (identified during the audit) with the mandatory public reporting of grants as required under the Finance Minister’s Instructions and later by the Commonwealth Grant Guidelines.
33. As at 5 April 2013, funding agreements for all of the first round locations have been executed and 29 of the 36 clinics have been completed and are operational; with seven not yet completed.31 Of the 29 completed clinics, three were completed within the timeframe originally specified in the funding agreement, while four clinics were completed 12 months or more after the specified date and 22 clinics were completed less than 12 months after the specified date. For the second round, funding agreements for 24 of the 28 clinic locations have been executed and one clinic is operational, with so–called ‘early services’ being provided from existing premises at another seven locations. The time taken from the execution of funding agreements to the completion of clinics has varied considerably, reflecting amongst other things, delays associated with resolving often complex issues of land tenure, development approvals and construction works.
Chapter 5: Reporting and Assessing Clinic and Program Outcomes
34. The ANAO’s analysis of the operational reports of the 18 clinics in its sample indicates that the majority of these clinics are making good progress towards achieving some key service delivery expectations. Recruiting and retaining sufficient staff have been the biggest challenges for most clinics. However, an analysis of patient presentations does not show any particular trend, at this stage, in support of DoHA’s objective to achieve a significant shift towards an increasing proportion of overall services at GP Super Clinics being delivered by nurses and allied health professionals.
35. The development of key performance indicators (KPIs) for the ten GP Super Clinic program objectives was originally to occur in 2008, but this process was not commenced by the department until 2010. A set of detailed and measurable KPIs were agreed between DoHA and the Department of the Prime Minister and Cabinet (PM&C) and DoHA sought the Minister’s formal endorsement of these in March 2011.32 The Minister directed that the KPIs be reworked, and a revised set of KPIs, now framed in a more qualitative manner, was approved by the Minister in November 2011. As discussed below, there remains scope for revised KPIs to support longer term reporting on the extent to which the program is achieving its intended outcomes.
36. With the maturing of an increasing number of clinics, it is timely for DoHA to consider whether more quantifiable information on the services provided by clinics—focusing particularly on those that involve integrated, multidisciplinary team based care and preventative care—should be collected and publicly reported on an aggregated basis. Similarly, aggregated public reporting of the numbers of vocational placements and other education and training activities for medical, nursing and allied health professional students, including GP registrars, could be commenced. This reporting would usefully be supported by analysis of whether the more mature clinics are providing vocational placements and educational activities at proportionally higher levels than other comparable primary healthcare facilities. In addition to information provided by the clinics, reporting could be informed by data collected by the Department of Human Services as part of its administration of healthcare–related financial payments.
37. As already noted, the GP Super Clinics program will have an effective life of 20 years, and a revised performance and reporting framework would provide an improved basis for assessing the extent to which the program is achieving its key intended outcomes: improved access to integrated, multidisciplinary primary care health services; and increased education and training placements in a multidisciplinary care setting for the future primary care workforce.
Summary of agency response
38. The Department of Health and Ageing notes the audit report and agrees with the recommendations.
To inform the development and administration of infrastructure grants activities, the ANAO recommends that DoHA advise Ministers of any measures considered necessary in managing any significant risks to the effective implementation of election policy commitments.
DoHA response: Agreed.
To maximise the benefit from DoHA’s experience in the administration of health infrastructure grant programs, the ANAO recommends that the department document a better practice approach for the assessment of value for money for health infrastructure projects.
DoHA response: Agreed.
To improve longer-term reporting on program outcomes, the ANAO recommends that DoHA revise the GP Super Clinics performance and reporting framework to include measurable KPIs on the extent to which the program is achieving its key intended outcomes.
DoHA response: Agreed.
To support a more outcome-focused performance reporting framework for the GP Super Clinics program, it is recommended that DoHA put in place arrangements with the Department of Human Services to obtain information on claimable services provided by operational GP Super Clinics, as well as information regarding vocational placements, medical education and training for GP Registrars and allied health professionals.
DoHA response: Agreed.
 The policy was announced as part of a wider $2 billion National Health and Hospitals Reform Plan.
 Australian Labor Party, New Directions for Australia’s Health: Delivering GP Super Clinics to local communities, ALP, Canberra, 2007, p. 3.
 Clinics announced in 2007 included a Hobart clinic (‘Hobart Eastern Shores’) which was to have branches at two locations approximately 15 kilometres apart. These locations were subsequently funded through separate grant processes, and funding agreements were executed with two different recipients. For the purposes of this audit they are treated as two clinics.
 Applications submitted under non-competitive grant processes were subject to the same assessment procedures as those used for the competitive grants.
 Funding agreements have yet to be executed for four second round clinic locations.
 Department of Finance and Deregulation, Commonwealth Grant Guidelines: Policies and Principles for Grants Administration, Canberra, July 2009. The CGGs, issued under Regulation 7A of the FMA Regulations, represent the whole-of-government policy framework for grants administration and apply to all departments and agencies subject to the Financial Management and Accountability Act 1997 (FMA Act). The second edition of the CGGs was released in March 2013, with effect from 1 June 2013.
 These have included the Primary Care Infrastructure Grants program, examined in ANAO Audit Report No.44 2011–12 Administration of the Primary Care Infrastructure Grants Program; and the Health and Hospitals Fund program, examined in ANAO Audit Report No.45 2011–12 Administration of the Health and Hospitals Fund.
 A team based approach to primary health care would bring together general practitioners (GPs), nurses and allied health care professionals such as dietitians and physiotherapists. A team based approach differs from co-location, which simply puts various medical professionals within close proximity of each other.
 These included issues relating to land acquisition and development approvals, which at times contributed to delays in the rollout of clinics across the program.
 The decision was promulgated in Finance Minister’s Instructions dated 14 December 2007. The Instructions required guidelines to be developed for any new discretionary grant programs and for these guidelines to be considered by the ERC.
 The ANAO’s Better Practice Guide on grants administration suggests that ‘in establishing the form of application and selection process to be applied to a particular grant program, it is advisable for agencies to document consideration of the risks, costs and benefits of the available options’, ANAO Better Practice Guide—Implementing Better Practice Grants Administration, June 2010, Canberra, p. 60. The Commonwealth Grant Guidelines, which were introduced in July 2009 and applied to the second funding round, provide that ‘In the case of grant programs, unless specifically agreed otherwise, competitive, merit based selection processes should be used, based upon clearly defined selection criteria’. Commonwealth Grant Guidelines, op. cit., p. 29.
 Potential risks included the capability of the potential grant recipient to: develop a proposal meeting program objectives, manage the development approval and construction processes, and successfully operate the clinic once completed.
 Audit Report No.44 2011–12 Administration of the Primary Care Infrastructure Grants Program, Audit Report No.45 2011–12 Administration of the Health and Hospitals Fund.
 The ANAO also identified that there was scope to use cost per square metre calculations in the grant assessment process in Audit Report No.44 2011–12 Administration of the Primary Care Infrastructure Grants Program, p. 61.
 While 37 clinics were announced in the first round, the Commonwealth withdrew funding from the proposed Sorell clinic in Tasmania, leaving 36 clinics.
 DoHA has advised that a further clinic was open for business as at 31 May 2013.
 DoHA advised the ANAO that, to be classified as ‘early services’, these must be ‘additional to the services previously available to the community and form part of the services at the GP Super Clinic when it is operational’.
 ANAO Audit Report No.14 2007–08, Performance Audit of the Regional Partnerships Program, Volume 2, p.148.
 In this context, the ANAO’s 2002 Better Practice Guide—Administration of Grants noted that: ‘Even where the Government does take a specific decision regarding the establishment of a program, agencies should still consider whether further needs analysis would assist in targeting the areas or projects most in need of funding assistance, consistent with the Government’s objectives. For example, the Government may establish a program to improve regional Australia’s access to information technology. In these circumstances, the relevant agency should consider conducting analysis to determine those regions in greatest need or those services needed most’, p.8. The same sentiment is expressed in the ANAO’s 2010 Better Practice Guide—Implementing Better Practice Grants Administration: ‘it is advisable that agencies consider, as part of the implementation process, whether further needs analysis would assist in ensuring the available funding will be directed towards funding recipients or projects that will maximise the effectiveness of, and value for money achieved by, the program’, p. 21.
 The ANAO similarly observed in a previous grants administration audit that there was scope for DoHA to better assist the Health Minister through more comprehensive advice: ANAO Audit Report No.45 2011–12, Administration of the Health and Hospitals Fund, p. 86.
 The 2007 GP Super Clinics policy indicated that the clinic locations would be chosen by taking into account the factors.
 A number of media statements released by the ALP and the Government in the context of the 2007 and 2010 elections referred to whether selection processes would be competitive or not.
 In one first round location (Palmerston) the Minister did not decide that the funding would be a non-competitive process until late 2008: up until that point the funding process was unclear. In the second round, there were three occasions (Lower Hunter, Emerald, and Townsville (Northern Beaches)) where, following community consultation sessions, the Minister decided to change the process from competitive to non-competitive.
 Footnote 12 outlines a number of the potential risks.
 Following further contact from the proponent, the Minister subsequently agreed to provide funding of $220 000 for the proposal under the General Practice Infrastructure Training Support program.
 DWS status is determined by DoHA, using Australian Bureau of Statistics population data and Medicare Australia billing data. In general, an area is considered to be a DWS if it falls below the national average for the provision of medical services, indicating that it has unmet healthcare needs. See DOHA, DWS Fact Sheet, available at http://www.doctorconnect.gov.au/internet/otd/publishing.nsf/Content/dwsFactsheet [accessed April 2013].
 The framework was supported by parallel processes that allowed for risks to be identified, probity issues to be addressed and for associated financial administration and management issues to be considered. DoHA also provided support for the application process through local consultation processes at most GP Super Clinic locations. An interested parties list was created and used to notify potential applicants and provide access to Invitation to Apply (ITA) documentation via advertising competitive ITAs in the press and on the Department’s GP Super Clinics Website and tenders and grants webpage.
 In one case in the ANAO’s sample, the positioning and design of a GP Super Clinic which opened in 2010 has resulted in the main pedestrian access to a pre-existing GP practice being via the waiting area of the new GP Super Clinic.
 The Redcliffe clinic was originally expected to open around September 2011, but has yet to open.
 The funding recipient, the Redcliffe Hospital Foundation, was created under, and subject to specific Queensland legislation, and therefore required approval from the Queensland Government to take out loans that were intended to co–finance the construction of the Super Clinic.
 DoHA has advised that a further clinic was open for business as at 31 May 2013.
 DoHA, Minute to the Minister–Response to Cabinet Implementation Unit Assessment Report GP Super Clinics, 23 March 2011.