Campaign Advertising Review 2008-09
As an element of the arrangements implemented to support the role of the ANAO in reviewing campaigns' compliance with the Guidelines announced on 2 July 2008, the ANAO advised the chair of the JCPAA that the ANAO will provide regular summary reports to Parliament. Section 25 of the Auditor-General's Act 1997 provides for the tabling of such reports.
1. On 2 July 2008, consistent with its policy platform, the Government announced the Guidelines on Campaign Advertising by Australian Government Departments and Agencies (the Guidelines) to govern the content and presentation of Commonwealth Government campaign advertising. Agencies subject to the Financial Management and Accountability Act 1997 (the FMA Act) are required to comply with the Guidelines, which require that a Minister only launch an advertising campaign when:
- the Chief Executive of the agency undertaking the campaign has certified that the campaign complies with the Guidelines and relevant government policies; and
- for campaigns with expenditure in excess of $250 000, the Auditor General has provided a report to the Minister on the proposed campaign's compliance with the Guidelines.
2. Prior to the November 2007 Federal Election, the Government's information activities were coordinated by the Special Minister of State, who chaired the Ministerial Committee on Government Communications (MCGC). The MCGC approved the design and implementation relating to major and sensitive information campaigns. The (then) Government's general administrative requirements in relation to the management of information campaigns were set out in the Guidelines for Australian Government Information Activities - Principles and Procedures, February 1995.
3. Campaign advertising has been subject to a number of audits and inquiries over the years:
- an Australian National Audit Office (ANAO) audit of Commonwealth Government information and advertising in Audit Report No.30 1994-95; 1
- the ANAO further examined aspects of the administration of government advertising in Audit Report No.12 of 1998-99;2
- the Joint Committee of Public Accounts and Audit (JCPAA) examined Audit Report No. 12 of 1998-993 and, amongst other things, recommended new guidelines for Commonwealth government advertising;
- the Senate Finance and Public Administration References Committee undertook an inquiry into government advertising and accountability, recommending, amongst other things, that the JCPAA draft guidelines be adopted;4 and
- an ANAO audit of the administration of contracting in relation to government advertising, Audit Report No. 24 of 2008-095, made four recommendations aimed at improving the administration of campaign advertising.
4. Given the continuing public interest, it is expected that the ANAO will continue to examine government advertising as part of our performance audit program in the future.
5. As an element of the arrangements implemented to support the role of the ANAO in reviewing campaigns' compliance with the Guidelines announced on 2 July 2008, the ANAO advised the chair of the JCPAA that the ANAO will provide regular summary reports to Parliament. Section 25 of the Auditor-General's Act 1997 provides for the tabling of such reports.
6. This report provides the ANAO's perspective on the operation of the government advertising framework over the first 12 months of operation. The report provides an overview of the current framework for government advertising, identifies the roles of the various agencies, including the ANAO, and provides information on the assurance review activity for government advertising campaigns conducted by the ANAO. In considering the experience of the ANAO in undertaking assurance reviews during the financial year, the report also discusses key issues identified by the ANAO during 2008–09.
7. The announcement by the Government of the Guidelines in July 2008, drawing on the earlier proposals from the JCPAA and the ANAO, was a positive step in articulating the principles and expectations to be applied by agencies6 in undertaking advertising campaigns.
8. Historically, one of the most challenging areas in relation to advertising campaigns has been achieving clarity in the roles of Ministers and their offices on the one hand, and agencies on the other. The involvement of Ministers and their offices under former arrangements in making key decisions in approving strategies and briefs, in selecting certain consultants, and in the approval of final creative material and media plans meant that the basis for decisions and the accountability for decisions were not always clear.7 In announcing the new Guidelines8, the Minister for Finance and Deregulation and the Cabinet Secretary and Special Minister of State noted that ‘Ministers will be briefed on the progress of campaign development, but responsibility for that development will be wholly undertaken by the commissioning department…'.9
9. Agencies have commenced, and are continuing to, transition their administrative arrangements to include consideration of the requirements of the Guidelines at the inception of their communications strategy planning. As a consequence, agency processes are increasingly focusing on the key elements of the Guidelines which require documented justification of campaigns on cost, need, and relevance to government responsibilities. Agencies must also specify the desired outcomes and have clarity around the specific target audience for the campaign, based on research. Further, research undertaken by agencies provides the basis for the subsequent monitoring of the achievement of identified objectives, and informed decisions concerning the ongoing need for the campaign. The end result is a more systematic approach to justifying and conducting government advertising campaigns.
10. The ANAO has observed agencies cooperating and sharing knowledge, based on their experiences, and providing examples of work and analyses they have undertaken during the preparation of campaigns.10
11. The involvement of the ANAO has often resulted in better targeted and supported campaigns. Through the assurance review, the ANAO has clearly signalled the standard of supporting evidence required from agencies to demonstrate adherence to the Guidelines, and has provided timely assurance to Ministers, Parliament and the public regarding agencies' performance in relation to the Guidelines. The ANAO's involvement requires agencies to provide evidence to demonstrate performance against the individual Guidelines, bringing a greater level of clarity as to the responsibilities of the agency in the development and implementation of campaigns than was previously the case.
12. Overall, the Guidelines are generally holding up well, and have been particularly useful in establishing the principles requried for relevant government advertising campaigns. However, there remains further room for agencies to adjust business processes to better align with the requirements of the Guidelines. Also, there are several areas where, in the light of experience, the Guidelines could be refined or supplemented by additional guidance. The ANAO has written to the Special Minister of State11 and the Chair of the JCPAA, to provide information on specific matters where the Guidelines could be refined or supplemented.
13. These matters include: greater use of developmental research to inform the communication strategy; providing greater clarity on the requirements of the cost benefit analysis; providing greater clarity around the boundary between business as usual communication activities and activities which are subject to the Guidelines; providing greater clarity on which advertising activities fall within the campaign advertising definition;12 and having agencies present campaign documentation on their websites.
14. There is also a need for some agencies to refine their administrative processes to ensure that all materials for a campaign, including material in languages other than English, are presented for ANAO review at the same time. The presentation of component parts of one campaign for review leads to multiple review reports, and a duplication of effort for both the agency concerned, and for the ANAO.
Key findings by chapter
Chapter 2 – The campaign advertising governance framework
15. The Department of Finance and Deregulation (Finance) is responsible for supporting the Cabinet Secretary in maintaining and reviewing the current Guidelines and for providing guidance to agencies that may be considering conducting advertising campaigns. The ANAO provides a report, for campaigns with expenditure in excess of $250 000, to the relevant Minister on the proposed campaigns' compliance with the Guidelines.
16. The review undertaken by the ANAO is not an audit, but is designed to provide limited assurance (through inquiry, observation and analysis of key documents and information) that the campaign is in compliance with the Government's Guidelines.
17. The benefit of the assurance review activity is that it provides timely feedback, and enables the agency to decide at an early stage to modify the campaign if required. It also complements the more comprehensive perspective achieved through the performance audit program. This approach is consistent with the ANAO's goal of improving public administration through assurance activities.
18. During 2009, the ANAO appeared before the JCPAA and Senate Finance and Public Administration Committees in relation to our review role in respect of the Guidelines. On these occasions Committee members have sought information relating to the ANAO's role, the level of assurance provided by the ANAO in relation to these reviews and our review methodology.
19. The JCPAA inquiry into the role of the Auditor-General in scrutinising government advertising has involved two public hearings to date (in March and May 2009), and further hearings are scheduled for later in 2009.
Chapter 3 – 2008-09 assurance review activity and review related matters
20. The ANAO has established a small team to undertake the assurance review of advertising campaigns. Some additional budget funding for this review activity was provided to the ANAO when the initiative was introduced.
21. As at 30 June 2009, 58 reports have been issued to responsible Ministers in respect of 28 discrete advertising campaigns conducted within 12 portfolios. One campaign, providing public information on a potential swine influenza pandemic event, was exempted from the Guidelines by the Cabinet Secretary.
22. During the course of a number of reviews, matters have arisen which have not directly impacted on the review's conclusions, but have highlighted agency processes or practices which could be improved. Where this is the case, a letter from the ANAO listing these matters is issued to the agency concerned. These matters have related to: the rigour of cost benefit analyses; the need to present material for review in a timely manner; timing of procurement processes; and administrative and control processes within agencies.
Chapter 4 – General governance framework issues
23. The ANAO and agencies have implemented arrangements to respond to the new requirements for government advertising, and processes are being refined in the light of experience. The ANAO has worked closely with Finance and relevant agencies in implementing the new approach to government advertising. Some agencies still have work to do to align their business processes to support effective compliance with the core requirements of the Guidelines, but a commitment to improve is evident.
24. A number of agencies have developed better practices during 2008-09, particularly in relation to: the establishment of sound internal quality assurance processes to assess compliance with the Guidelines; closely monitoring campaigns to determine the degree to which they are achieving their objectives; and providing campaign related material on agency websites. In addition, there has been a willingness on the part of agencies to share information, including key campaign review documents, to assist and guide other agencies less experienced in the campaign assurance process.
25. The Guidelines have been particularly useful in reinforcing a value for money approach for all government advertising campaigns. However, as noted at paragraphs 12 and 13, there are some areas where, in the light of experience, the Guidelines could be refined or supplemented by additional guidance; these matters have been brought to the attention of the Special Minister of State and to the Chair of the JCPAA.
1 Australian National Audit Office, ANAO Audit Report No.30 1994–95, Commonwealth Government Information and Advertising, Canberra.
2 Australian National Audit Office, ANAO Audit Report No.12 1998-99, Taxation Reform – Community Education and Information Programme, Canberra.
3 Joint Committee of Public Accounts and Audit, Guidelines for Government Advertising, Report No. 377, Parliament House, Canberra, 2000.
4 Senate Finance and Public Administration Committee, Government Advertising and Accountability, Canberra, 2005.
5 Australian National Audit Office, ANAO Audit Report No.24 2008–09, The Administration of Contracting Arrangements in relation to Government Advertising to November 2007, Canberra.
6 For the purposes of this report, the term ‘agencies' is to be taken as applying to those departments and agencies subject to the Financial Management and Accountability Act 1997.
7 Australian National Audit Office, ANAO Audit Report No. 24, op. cit.
8 The Business Planning Processes for Campaign Information and Advertising Activities issued by Department of Finance and Deregulation (Finance) in February 2009, complement the Guidelines by setting out the roles and responsibilities of the Cabinet Secretary, Ministers, and agencies, amongst others.
9 Tanner, the Hon Lindsay MP (Minister for Finance and Deregulation), and Faulkner, Senator the Hon John (Cabinet Secretary and Special Minister of State) 2009, New Advertising Guidelines, Joint Media Release, Parliament House, Canberra, 2 July 2009.
10 Australian National Audit Office, ANAO Audit Report No.24 2008–09, The Administration of Contracting Arrangements in relation to Government Advertising to November 2007, Canberra.
11 While the role of the Cabinet Secretary and Special Minister of State is undertaken concurrently, the Guidelines refer specifically to the Cabinet Secretary.
12 This includes the consideration of alternative advertising mediums including material either created specifically for, or displayed on, agency and specific purpose websites. Agency websites are usually informational based, websites that cover all of an agency's general business activities. Specific purpose websites are usually created for a program or as part of a communication campaign.