Campaign Advertising Review July 2009 - March 2010
As part of the ANAO's role in reviewing proposed advertising campaigns for compliance with the June 2008 Guidelines, the Auditor–General advised the JCPAA that the ANAO would provide regular summary reports on its advertising review activities to Parliament. Section 25 of the Auditor General Act 1997 provides for the tabling of such reports.
1. The Government has recently reviewed the arrangements for government advertising, and as a result has implemented revised guidelines and new administrative arrangements, with effect from 31 March 2010. The new arrangements include the appointment of a new review body, the Independent Communications Committee (ICC),1 to undertake reviews of proposed advertising campaigns previously performed by the Australian National Audit Office (ANAO).
2. Prior to these changes, government advertising campaigns were required to conform with Guidelines on Campaign Advertising by Australian Government Departments and Agencies issued in June 2008.2 The June 2008 Guidelines required that a Minister only launch an advertising campaign when:
- the Chief Executive Officer (CEO) of the agency undertaking the campaign had certified that the campaign complied with the June 2008 Guidelines and relevant government policies; and
- for campaigns with expenditure in excess of $250 000, the Auditor General had provided a report to the Minister on the proposed campaign's compliance with the June 2008 Guidelines.
3. From June 2008 to the end of March 2010, the Auditor-General, or his delegates, issued a total of 89 independent review reports on campaigns' compliance with the Government's June 2008 Guidelines.
4. The June 2008 Guidelines, which had regard to earlier recommendations of the Joint Committee of Public Accounts and Audit (JCPAA) and the Auditor-General, provided clarity regarding the role of CEOs as having the sole responsibility for certifying a proposed campaign's compliance with the Guidelines. The Auditor–General's role was to report to the responsible Minister on whether anything had come to his attention during the review of the CEO's certificate and information supporting the certificate, to suggest that the relevant campaign did not comply, in all material respects, with the requirements of the June 2008 Guidelines. The final decision to launch the campaign appropriately rested with the responsible Minister.
5. On 31 March 2010, the Government announced a number of changes to the previous framework, including:
- replacement of the June 2008 Guidelines with a revised set of guidelines, the March 2010 Guidelines;
- the establishment of the ICC, in place of the Auditor–General, to review proposed advertising campaigns over $250 000;
- a proposal that Government request the Auditor–General to consider annual performance audits in this area; and
- the abolition of the role of the Interdepartmental Committee on Communications (IDCC) in reviewing campaigns from a whole–of–government perspective.
6. Because the arrangements applying to government advertising reflect government policy rather than legislation, it is within the province of government to vary the applicable administrative arrangements. It is noteworthy, in this context, that both the guidelines and the review arrangements have been varied by the Government relative to its earlier policy platform. Only time will tell the extent to which these new arrangements will consolidate the gains made under the previous arrangements.
7. Given the continuing interest in this area of public administration, the ANAO will continue to schedule periodic performance audits of government advertising in its forward work program.
8. As part of the ANAO's role in reviewing proposed advertising campaigns for compliance with the June 2008 Guidelines, the Auditor–General advised the JCPAA that the ANAO would provide regular summary reports on its advertising review activities to Parliament. Section 25 of the Auditor General Act 1997 provides for the tabling of such reports.
9. This report follows Report No.2 2009–10, Campaign Advertising Review 2008–09, providing the ANAO's perspective on the operation of the Government's campaign advertising arrangements from July 2009 to the end of March 2010. In considering the experience of the ANAO in undertaking assurance reviews from June 2008 to the end of March 2010, the report also discusses key issues relevant to the operations of the June 2008 Guidelines.
10. During the period of the ANAO's role in reviewing government advertising campaigns, the operation of the arrangements for government advertising surrounding government advertising generally held up well, and continued to encourage sound administrative practices in agencies to support evidence-based compliance with the June 2008 Guidelines.3 Those agencies most advanced in the maturity of their administrative arrangements were able to efficiently provide the ANAO with the required documentation to evidence compliance with the June 2008 Guidelines.4
11. Agencies have continued to refine their approach leading to a much better understanding of the support required for the certificate provided by CEOs to demonstrate compliance with the June 2008 Guidelines. The ANAO's involvement encouraged better targeted and supported campaigns.
12. The ANAO also refined its approach through the provision of advice for agencies on the ANAO website, and a checklist of required material, tailored to each campaign. However, our reviews showed that there was the continued need for further policy guidance on some specific areas of the application of the June 2008 Guidelines. Those areas, as identified by the Auditor–General in correspondence to the Cabinet Secretary5 and the Chair of the JCPAA, included the need to provide greater clarity around: the requirements of the cost benefit analysis; the boundary between business as usual communication activities, and activities which were subject to the Guidelines; and the identification of those activities which fell within the campaign definition.
13. During 2009 and 2010 the JCPAA conducted an inquiry into the role of the Auditor-General in scrutinising government advertising. The Committee's inquiry, which is still ongoing at the time of preparation of this report, has emphasised a range of matters that are important in the administration of campaigns, including:
- the need to increase the focus on communicating with audiences from non English speaking backgrounds;
- the need for agencies to consider the communication needs of disadvantaged individuals or groups amongst the target audience;
- the need for agencies to consider the broader messages in the community, including media releases or private sector advertising, which may impact on the target audience's understanding of a program; and
- the need for greater clarity in the intended meaning of Guideline 3 of the June 2008 Guidelines: ‘material should not be directed at promoting party political interests', and that ‘material should be presented in a manner free from partisan promotion of government policy and political argument, and in objective language'.
14. Following the Government's review of the arrangements for government advertising, revised arrangements and a new set of guidelines were announced, on 31 March 2010. It is apparent that while the March 2010 Guidelines provide a greater level of specificity in some areas, other areas are less specific than before.6 This is particularly so in the case of Principle 1,7 which provides a broader scope in determining the suitable uses of government advertising campaigns, Principle 3,8 which provides less guidance in interpreting whether campaign materials promote party political interests, and Principle 4,9 which no longer requires a cost-benefit analysis to support the proposed campaign. As previously indicated to the Government, these changes represent a general softening in the application of requirements on agencies. Nevertheless, these are matters that rest with Government for decision.
15. To assist with the transition to the Government's new arrangements for government advertising, the ANAO has provided the ICC with the benefit of its experience and information regarding procedures employed, in order to assist the ICC in undertaking future reviews of government advertising.
Chapter 1: The Government Advertising Review process June 2008 to March 2010
16. Advertising is a legitimate element of government communication and information strategies, and has been used as a means of communicating directly with the public on matters of importance. The public nature of government advertising campaigns and the level of expenditure involved have ensured ongoing parliamentary scrutiny and public debate.
17. Chapter 1 provides background information on the government advertising review process from June 2008 to March 2010, and the ANAO's role in reviewing campaigns.
18. The roles of the Department of Finance and Deregulation (Finance) and the IDCC are also discussed. In addition, previous and recent reviews of government advertising arrangements, including an ongoing inquiry by the JCPAA on the role of the Auditor–General in scrutinising government advertising, are covered in this chapter.
19. On 31 March 2010 the Government announced changes to the government advertising framework which included a new review body, the ICC, to replace the role of the Auditor–General in reviewing proposed advertising campaigns. The revised March 2010 Guidelines are discussed in this chapter.
Chapter 2: ANAO Government Advertising Review activities 2009-10
20. From 1 July 2009 to 31 March 2010, the ANAO provided 31 review reports to responsible Ministers on proposed government advertising campaigns. Tables in chapter 2 provide detail on each campaign, the responsible agency, the date the ANAO was first advised of the campaign, the ANAO review report date and the advised launch date, and the advised budget for each campaign.10
21. The chapter also covers instances where the ANAO was not required to issue a review report, and where the ANAO issued management letters to agencies regarding issues that arose as a result of, or during the course of, a review but which did not directly impact the final review conclusion.
1 The Independent Communications Committee consists of three former public servants appointed to the role by Government: Dr Allan Hawke, Ms Helen Williams and Ms Barbara Belcher.
2 For the purposes of this report, the Guidelines on Campaign Advertising by Australian Government Departments and Agencies, June 2008 will be referred to as the June 2008 Guidelines, and the Guidelines on Information and Advertising Campaigns by Australian Government Departments and Agencies, (March 2010) will be referred to as the March 2010 Guidelines. Both sets of Guidelines are produced and administered by the Department of Finance and Deregulation. The June 2008 and March 2010 Guidelines are reproduced as appendices to this report.
3 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.
4 With the exception of the cost benefit analysis, documents provided by agencies to show compliance with the June 2008 Guidelines were required for other accountability purposes (for example: contracts and other procurement documentation) or are part of the traditional set of documents developed to support campaigns (for example: developmental research, the communications strategy, media brief and the media buy).
5 The role of the Cabinet Secretary and Special Minister of State is undertaken concurrently. The Guidelines (both June 2008 and March 2010) refer specifically to the Cabinet Secretary, and therefore references in this report are to the Cabinet Secretary.
6 For example, what constitutes an advertising campaign is more clearly defined in the March 2010 Guidelines, although the definition also reduces the scope of what is considered an ‘advertising campaign'.
7 Principle 1 – campaigns should be relevant to government responsibilities.
8 Principle 3 – campaign materials should be objective and not directed at promoting party political interests.
9 Principle 4 – campaigns should be justified and undertaken in an efficient, effective and relevant manner.
10 The budget information is as advised to the ANAO. The ANAO did not collect data on the actual expenditure by agencies on advertising campaigns. Finance is responsible for reporting on the actual costs for each campaign.