Establishment, Implementation and Administration of the Quarantined Heritage Component of the Local Jobs Stream of the Jobs Fund
The objective of this audit was to assess the efficiency and effectiveness of the establishment, implementation and administration of the quarantined heritage component of the Local Jobs stream of the Jobs Fund. A particular focus was on the establishment of program objectives and the extent to which approved grants have demonstrably contributed to the cost-effective achievement of those objectives. The audit approach has been influenced by recent audits of grants administration which have emphasised the importance of transparent and accountable grant decision-making processes to the cost effective achievement of stated program objectives, and having regard for recent government decisions to enhance the framework applying to the administration of grants.
1. As part of its response to the global financial crisis, on 17 March 2009 the Government agreed to the establishment of an integrated $650 million Jobs Fund, consisting of three streams. Reflecting commitments previously made to the Australian Greens in the context of securing passage (on 13 February 2009) of the $42 billion Nation Building and Jobs Plan legislation, $60 million of the Jobs Fund was quarantined under the Local Jobs stream for heritage-related projects. In line with the stimulus objectives of the Jobs Fund, the heritage component was to be completed by 30 June 2010.
2. Although the various streams of the Jobs Fund had their own particular focus, in each case the primary objective was to support and create jobs and employment opportunities in communities affected by the global recession and for disadvantaged job seekers through the funded projects. This was reflected in one initial set of guidelines encapsulating all three funding streams being published in April 2009. These guidelines stated that, to be considered for funding under any of the streams, a project needed to meet at least one of four target areas1, as well as meeting each of three gateway criteria:
- projects must be in areas experiencing high unemployment, a significant rise in unemployment or vulnerability;
- projects must be viable and ready to start; and
- heritage component funding would not extend past 30 June 2010.
3. For the heritage component, the employment objectives of the Jobs Fund were to be achieved through the delivery of projects that also provided positive heritage outcomes. To this end, the guidelines identified four issues (criteria) that would be considered in assessing heritage outcomes. The guidelines further provided for projects to be identified for consideration under the heritage component through two funding rounds as follows:
- to enable $6 million to be expended by 30 June 2009, projects funded in 2008 09 would be identified, assessed and recommended by the department responsible for administering the heritage component. The guidelines further stated that this would apply to projects that were ‘ready to start immediately on securing funding and meet the spirit of the Jobs Fund criteria’; and
- projects considered in a 2009–10 funding round were to be sourced in two ways—applications submitted through a common gateway process in response to the first Jobs Fund open call for proposals; and targeted approaches to relevant community organisations and state, territory and local governments. Under the guidelines, candidate projects identified in 2009–10 through both the common Jobs Fund application process and a targeted approach to heritage stakeholders were still required to meet the gateway criteria and target areas set out in the guidelines in order to be considered for funding.
Administration of the heritage component
4. Administration of the Jobs Fund was shared across agencies. The Department of Education, Employment and Workplace Relations (DEEWR) was the lead agency and central point for the submission of applications, and also administered some of the funding. For the majority of the life of the program, administration of the quarantined heritage component was the responsibility of the then Department of the Environment, Water, Heritage and the Arts. In September 2010, that department became the Department of Sustainability, Environment, Water, Population and Communities (DSEWPaC). Between April and December 2009, the then Minister for the Environment, Heritage and the Arts (Environment Minister) made all decisions in relation to which projects would be funded under the heritage component.2
5. The objective of the audit was to assess the efficiency3 and effectiveness of the establishment, implementation and administration of the heritage component of the Local Jobs stream of the Jobs Fund, with a particular focus on the establishment of program objectives and the extent to which approved grants have demonstrably contributed to the cost-effective achievement of those objectives.
6. The audit examined the program against relevant policy and legislative requirements for the expenditure of public money and the enhanced grants administration framework progressively introduced from December 2007, culminating in the issuing in July 2009 of the Commonwealth Grant Guidelines (CGGs).4
7. The quarantining of $60 million of the Jobs Fund for heritage-related projects represented a substantial (and unexpected) program for this area of government, and was seen by the responsible department as an opportunity to address a funding backlog for a range of heritage assets. To this end, an integral element of the department’s implementation approach involved drawing on external heritage expertise and stakeholders to identify and assess candidate projects.
8. At the conclusion of the two funding rounds, 191 projects were contracted to provide positive heritage outcomes in relation to a range of National Heritage-listed places; historic properties managed by the National Trust; heritage places of local, state or national significance; and natural heritage projects focussed on places listed in, or being assessed for inclusion in, the World Heritage List. The $58.2 million in contracted funding represented a significant Australian Government investment in these heritage assets.
9. While delivering positive heritage benefits, the responsible department’s implementation of this component of the Local Jobs stream of the Jobs Fund had insufficient regard to the Government’s policy objective of giving priority to employment outcomes and did not meet appropriate standards of governance for a grant program of this nature.
10. Although achieving heritage outcomes was an important aspect of the program objective, the primary purpose of the Jobs Fund, as reflected in the program guidelines approved by the Government, was to fund projects that would support and create jobs and employment opportunities in areas experiencing high unemployment or significant rises in unemployment or vulnerability. However:
- the department focused on the selection of projects that would achieve positive heritage outcomes with considerably less attention being given to whether candidate proposals would provide desirable employment outcomes in the areas of identified greatest need. The result was that projects that did not demonstrably meet the unemployment gateway criterion were nevertheless recommended and approved for funding. Such an approach is not in accordance with the grants administration framework (which requires decision-makers to be satisfied that approved grants are consistent with the program guidelines and other relevant policies)5;
- while a sound approach was planned for obtaining and analysing relevant data in order to assess the extent to which the program generated employment through the contracted projects, the responsible department did not follow-through on its planned approach. As a result, there is no reliable data available on actual employment outcomes achieved through heritage component projects; and
- delays with contracted projects commencing and progressing were masked by payments being made in advance of need, due to the department seeking to pay as much of the program funds as it could before the originally budgeted program end date of 30 June 2010. The Jobs Fund gateway criteria had required that funding not be awarded to projects that were not ready to start and/or could not be completed by 30 June 2010.
11. In respect to the department’s focus on heritage outcomes, prior to the decision to establish the Jobs Fund, the responsible department had obtained the then Environment Minister’s agreement to arrangements for implementing the quarantined heritage funding as a stand-alone heritage-based program. Throughout the subsequent inter-departmental process of developing the common Jobs Fund program guidelines, the responsible department indicated a preference that the heritage component not be implemented through the application process being developed for use across the Jobs Fund, and the associated stimulus-focussed gateway criteria. This reflected the department’s view that good heritage projects did not necessarily exist primarily in areas of high unemployment. However, the Government decision to include the heritage funding within the integrated Jobs Fund, and to give primacy in the program objective and threshold funding criteria to achieving timely and targeted employment outcomes, did not result in the responsible department ensuring that its approach to implementing the program faithfully reflected the decisions that Ministers collectively had taken. This represented a failure in the department’s program governance.
12. More broadly, while the heritage component of the Jobs Fund was implemented in a timely manner that reflected the budgetary timeframe established for the program as part of the Government’s package of stimulus measures6, there were a number of significant shortcomings evident in the responsible department’s implementation and administration of the program. This, in part, reflected that the relevant area of the department had limited experience in the design and implementation of grant selection processes, particularly of this magnitude. It also means that the department is unable to demonstrate that each of the projects funded through the two funding rounds were both eligible and the most meritorious in terms of the program guidelines and published selection criteria (including those relating to assessing projects’ heritage outcomes). In particular:
- effective governance arrangements were not developed and applied in respect to the role played by external parties and advisory panels in identifying and/or assessing candidate projects. Of note was that there was a general lack of documentation held by the responsible department concerning the processes by which candidate proposals were identified through external parties (particularly for the 2008–09 funding round), and of relevant departmental and advisory panel deliberations leading to shortlisting decisions and funding recommendations under each round. In addition, not all candidate projects were referred to the relevant advisory panel for advice, including projects that were nevertheless ultimately proposed to the Minister;
- assessment methodologies, including rating scales, were not developed in line with the published program guidelines, and were not in any event consistently applied. Further, the rating scales that were used provided little differentiation in terms of the relative merits of candidate projects; and
- clear funding recommendations (identifying which projects should be awarded funding) were included in the two briefings provided to the Minister for the 2008–09 round. This was not the case in relation to four of the five briefings provided in respect to the 2009–10 round. The department also did not effectively support its Minister to satisfy the obligation on decision-makers to record the basis for grant approvals. Key factors in this latter situation included the lack of documented assessments for each candidate project against the gateway and heritage criteria. The Minister was also not provided with advice in respect to the assessed relative merits of competing projects in relation to either the published gateway and heritage criteria or projects’ respective overall value for money.
13. Earlier in 2012, ANAO completed a cross-portfolio audit of the administration of the various grant reporting obligations. That report made three recommendations aimed at enhancing the quality of advice provided to Ministers when they are the decision-makers for grant programs, and compliance with the associated reporting obligations.7 As evidenced by the findings of this audit of the administration of the heritage component, those recommendations are particularly relevant to DSEWPaC. Having regard to earlier advice from DSEWPaC about steps it has taken to improve its grants administration8, ANAO has also made two recommendations concerning DSEWPaC’s:
- use of advisory panels and/or peak bodies to identify and/or assess candidates for funding under future grant programs; and
- assessment of applications to future competitive, merit-based grant programs.
14. A recurring theme in ANAO’s audits of grants administration is the importance of agencies (and Ministers) implementing programs in a manner which accords with government policy decisions and published program guidelines, and treats all applicants equitably—the community reasonably expects this. There was ample guidance and experience available for agencies to draw on to guide the design and implementation of grant programs to avoid the numerous shortcomings of the kind highlighted by this audit. In particular, it is important that agencies charged with responsibility for administering programs, including programs required to be implemented expeditiously, invest sufficiently in their governance arrangements and processes to achieve sound outcomes that are consistent with government policies and other requirements.
Advisory panels and peak bodies (Chapter 2)
15. Reflecting the responsible department’s clear focus on maximising the heritage outcomes achieved through this one-off funding allocation, an integral element of the implementation approach adopted was to draw on external heritage expertise and stakeholders. This was also seen by the department as assisting to efficiently identify the ‘shovel ready’ projects necessary for the program to be implemented within the required timeframes.
16. This focus on engaging external expertise and stakeholders in the selection process was reflected in the original implementation arrangements approved by the responsible Minister in March 2009. However, the program guidelines published in April 2009, following the Government’s decision that the quarantined heritage funding would be delivered through the Jobs Fund, identified a more limited involvement by external organisations than originally envisaged by the department in advising its Minister.
17. Nevertheless, the implementation of both rounds of the heritage component continued to reflect, in large part, the original arrangements rather than those ultimately approved by government and reflected in the published program guidelines. In addition, the approach taken to engaging external parties to participate in the project identification and assessment process could have been improved, particularly in relation to clarity about the role that was to be performed and documenting the subsequent implementation of that role. Further, although there is evidence of awareness within the department of the need to address potential or declared conflicts of interest, no management policies or procedures were developed or implemented in that respect.
Selection of projects in 2008–09 (Chapter 3)
18. In its implementation of the 2008–09 round of the heritage component, the department was focused on meeting the requirement to spend $6 million of program funding by 30 June 2009. This goal was achieved, with all recommendations being provided to the responsible Minister and funding decisions made by mid-May 2009.
19. The 30 June 2009 deadline ultimately identified for expending an initial $6 million was less than five months after the Government’s 12 February 2009 agreement to provide the quarantined funding, and just over two months after the Jobs Fund guidelines were finalised. In such circumstances, it is important that agencies carefully consider how project selection processes can be expedited, while ensuring the parameters set down in the guidelines are implemented in a manner that supports both procedural consistency and cost-effective administration.
20. In this context, although proposals for consideration in 2008–09 were sought through a two-stage targeted invitation process, rather than an open call for submissions, it remained a competitive process. However, there were significant shortcomings in the approach taken to implementing the 2008–09 round that were inconsistent with sound practice for competitive grant programs. In particular:
- the assessment and selection methodology adopted was not consistent in some important respects with the published program guidelines but, rather, reflected arrangements developed by the department prior to the Government deciding that the heritage funding would be administered as part of an integrated Jobs Fund;
- there is a general lack of documentation (and therefore accountability) concerning the processes by which candidate proposals were identified;
- the process for shortlisting projects for formal consideration was not established in advance, and the department did not record an assessment of each candidate project against relevant criteria;
- the assessment of the formal proposals submitted in respect to shortlisted projects did not enable the department to inform its Minister as to the relative merits of each project in relation to the published program guidelines, or the value for money these projects offered in terms of their expected employment benefits; and
- although including a clear recommendation as to which projects should be awarded funding, the written advice provided to the Minister as the decision-maker did not outline his obligations under the financial framework when approving grants, and similarly did not clearly outline the criteria against which each project had been assessed or the results of such an assessment.
Assessment of applications for funding in 2009–10 (Chapter 4)
21. The conduct of a competitive grant selection process for the funding available under the quarantined heritage component in 2009–10 presented a number of significant challenges to the department. In particular:
- the relevant area of the department had limited experience in the design and implementation of grant selection processes, particularly of this magnitude; and
- given the economic stimulus nature of the program, the timeframe available to obtain and assess candidate proposals was short.
22. These circumstances contributed to various anomalies and inconsistencies arising in the processes by which candidate proposals were identified, with some applications being denied the opportunity to compete for the available funding. These circumstances also contributed to shortcomings in the assessment of competing candidates. In particular:
- the documented assessment methodology was not consistent with the published guidelines in that it did not appropriately differentiate between the nature of the threshold Jobs Fund eligibility criteria and the heritage assessment criteria;
- the rating scales that were to be applied were not clearly established;
- documented guidance for assessors in completing the assessment templates and assigning ratings was also not developed, with considerable inconsistency being evident in the completed assessments. In particular, for a significant proportion of projects, there was no documented assessment against the individual published heritage assessment criteria and/or the Jobs Fund gateway criteria and target areas;
- a methodology for determining overall ratings against each group of criteria (that is, the Jobs Fund eligibility criteria and the heritage assessment criteria respectively), and as an overall combined assessment was not established; and
- the approach taken to documenting assessments against both sets of criteria became increasingly short-hand and opaque over the course of the assessment process.
23. Of particular note in this respect was that projects that had not been assessed as demonstrably meeting the Jobs Fund eligibility criteria were not excluded from funding consideration. As a result, a number of such projects were recommended and approved for funding. The assessment approach adopted by the department allowed priority to be given to heritage considerations over employment considerations. However, such an approach was not consistent with the Jobs Fund guidelines which required that funding only be awarded where the mandatory gateway criteria had been met, and is not in accordance with the grants administration framework (which requires decision-makers to be satisfied that approved grants are consistent with the program guidelines and other relevant policies).
Advice to decision-maker and funding decisions for 2009–10 (Chapter 5)
24. For the heritage component, the employment objectives of the Jobs Fund were to be achieved through the delivery of projects that also provided positive heritage outcomes. Accordingly, identifying the overall relative merit of each competing project required the department to bring together the outcome of the assessment against the published Jobs Fund threshold criteria and heritage assessment criteria; the views and perspectives of the various expert panels on heritage considerations; and consideration of whether the expected employment outcomes represented value for money.
25. The approach adopted by the department went some way towards addressing these various considerations. Specifically, the outcomes of the gateway and heritage assessments were combined to provide an overall rating for each project, but the rating scale used provided little differentiation in terms of the relative merits of the 325 projects considered capable of being funded. Projects were then, more often than not, considered by the relevant heritage expert panel/s, for formulation of funding recommendations. As a result of the process followed, heritage considerations became the predominant factor in determining whether a project would be recommended to the responsible Minister for approval. In addition, the department did not establish a consistent means of assessing the overall value for money provided by each project in terms of the program objectives.
26. The funding recommendations were, in most cases, provided to the responsible Minister by way of letters from the chair of the relevant expert panel and a covering departmental brief (which, in each case, agreed with the panel’s recommendations). However, the benefits of bringing different perspectives and assessments to bear were offset by:
- different approaches being adopted to the formulation of funding recommendations in respect to each of the five funding categories, and procedures for re-allocating funding between categories not being established; and
- departmental records not clearly outlining why certain projects were recommended for funding and others were not.
27. Between August and December 2009, the Minister was provided with a series of five briefings recommending projects for funding consideration. In providing the first tranche of projects, the department advised the Minister that all recommended projects had met the Jobs Fund gateway and heritage criteria. However, this advice was either not supported by, or was inconsistent with, the documented assessment process under which an assessment against each criterion was not recorded for many projects. The subsequent four briefs providing projects for the Minister’s consideration did not address whether the recommended projects had met the published criteria, and did not advise the Minister of the assessment criteria that had been applied. In none of the briefs did the department advise the Minister as to how each project had been assessed against each of the published selection criteria, individually or in comparison to other projects. Nor was the Minister advised as to the overall value for money offered by each competing project in terms of expected employment and heritage benefits.
28. Over the course of 2009–10, the responsible Minister approved 162 of the 181 projects9 proposed in the various briefing packages provided by his department (of which 158 were contracted by the department). In this context, there were a number of aspects of the department’s briefing practices that were not consistent with requirements introduced by the Government with effect from 1 July 2009 (through the promulgation of the CGGs and amendment of the FMA Regulations). Of particular note was that, for four of the briefings, the responsible Minister was not provided with a clear recommendation that identified those projects the department considered should be awarded funding based on an assessment of their relative merits in terms of the published criteria, and those that it recommended be rejected. Reflecting this situation, there were no instances where the responsible Minister was required to report to the Finance Minister that he had approved funding for a project his department had recommended be rejected.
29. Against this background, the briefing approach taken did not appropriately support the Minister’s capacity to meet the obligation to record the basis for grant approvals in the context of a competitive grant program. This was compounded by the departmental briefs not advising the Minister on the requirements that arise when undertaking the role of decision-maker for a grant program.
30. The department excluded from further consideration those recommended projects that had not been approved within particular packages proposed to the Minister, but without obtaining or documenting advice from the Minister as to whether each such project was considered by the Minister to be unsuitable for further consideration should additional funds become available (as occurred on two occasions in relation to the large community projects category). This approach contributed to the lack of transparency regarding the basis on which certain projects had been selected for funding and others had not.
Delivery of financial stimulus (Chapter 6)
31. Once project approvals for each round had been finalised, the department worked expeditiously to develop and sign funding agreements, with very few delays occurring in agreements being finalised. The department’s performance in this regard was a significant improvement over that achieved under the other quarantined component of the Local Jobs stream, also budgeted to be completed by June 2010.
32. In addition, by the originally budgeted program end date of 30 June 2010 all but $3 million (five per cent) of contracted funding had been paid to proponents. This situation indicated that the program had largely provided the desired level of stimulus in the planned timeframe. However, this was not, in fact, the case. Rather, the high level of program expenditure by June 2010 was achieved by signing funding agreements with unrealistic project completion dates and then making project payments in advance of need.10
33. In this respect, there were significant delays in the delivery of projects, as is demonstrated by nearly half of the 191 contracted projects not being completed by the date originally specified in the relevant funding agreement. This included 75 projects (39 per cent) that were not completed by June 2010. By 30 June 2010, the department had paid a total of $32.7 million (92 per cent) of approved funding for those 75 projects, but the majority took an extended period to subsequently reach completion (or in one case termination without ever commencing). Final grant payments were not made until June 2011.
Employment and heritage outcomes (Chapter 7)
34. The department adopted a strong early focus on establishing an evaluation and reporting framework for the heritage component. The framework identified the program objectives against which performance would be evaluated and associated performance indicators.
35. The department’s evaluation and reporting framework recognised that the fundamental purpose of the Jobs Fund was to create and retain employment. In this context, whilst recognising that projects’ anticipated employment outcomes should be treated with some caution, the employment generated by funded projects was expected to be significant. However:
- shortcomings existed in the assessment of candidates for funding and, as a result, program funding was not focused on those areas identified as having the greatest employment stimulus needs11;
- notwithstanding the importance of Jobs Fund projects generating employment, funding agreements did not identify achievement of the expected employment outcomes that had informed the decision to award funding as a project milestone or required deliverable; and
- the department did not follow-through on its planned approaches to obtaining and analysing relevant data to assess the extent to which the program generated employment through funded projects.
36. In these circumstances, there is no reliable data available on actual employment outcomes achieved through heritage component projects.
37. The Heritage Minister’s Working Group had agreed that there was a need to demonstrate the ‘rate of return’ on investments made in heritage, including both the economic and social returns to the community. Reflecting this, the stated objectives of the evaluation and reporting framework developed for the heritage component were to provide a clear set of indicators of the economic and social contribution that had been made by the investment in heritage places through the Jobs Fund.
38. In that context, the department took a number of steps to evaluate in qualitative terms the achieved heritage outcomes. Of particular note was an external evaluation completed in August 2011. Overall, the evaluation concluded that the program was successful in achieving its heritage objectives and that continuation of a diverse heritage program would help to contribute to government heritage goals, and maintain the level of community engagement and interest that had been generated.
39. More specifically, based on the available data, the evaluation concluded that the 33 projects examined had been successful in meeting most of the heritage outcomes detailed in the program guidelines. The evaluation also concluded that it was too early to gauge the extent of the desired social and economic impacts (as noted at paragraph 37, the Heritage Minister’s Working Group had agreed this would be an important element in demonstrating the ‘rate of return’ on investments made in heritage). The evaluation report included suggestions to enable better measurement of the heritage impacts of any future funded projects, and made a number of recommendations relating to the framing and conduct of any future heritage grant programs. In September 2012, DSEWPaC advised ANAO that the department had accepted the recommendations made in the evaluation report and incorporated them where appropriate in subsequent related programs.
40. While the achieved heritage outcomes are to be acknowledged, the range of shortcomings in the responsible department’s application and assessment processes identified in Chapters 2, 3, 4 and 5 of this ANAO report mean that the documented selection process does not demonstrate that the most meritorious projects in terms of the published heritage selection criteria were funded through either the 2008–09 round or the 2009–10 round.
41. Having regard for the various administrative arrangements that have applied over time in relation to the heritage component and the Jobs Fund more broadly, the proposed audit report issued under section 19 of the Auditor-General Act 1997 was provided to DSEWPaC, DEEWR, the Minister who was responsible for all funding decisions taken in respect to the heritage component and the external heritage bodies and stakeholders that were involved in the project identification and assessment processes. Whilst no formal response to the draft report was received from the relevant Minister, DEEWR and external bodies, DSEWPaC provided the following summary response with the full response included at Appendix 1 of the audit report.
The department (DSEWPaC) agrees with the two audit recommendations and appreciates the opportunity to provide comment. DSEWPaC recognises the need to include relevant details in program guidelines, and ensure a rigorous approach to assessment parameters.
The key findings of the report largely relate to processes and events in the period from 2008 to mid 2010. Indeed, in 2010 the department itself identified the need to substantially strengthen many of its internal processes and governance arrangements. Since then, the department has considerably improved the development, and evaluation of its grant programs with the implementation of a new and more robust grants administration framework with dedicated resources.
In June 2011, DSEWPaC implemented a Grants Administration Framework, which comprises comprehensive administrative tools for staff to provide policy and legislative guidance and better practices on how granting activities should be properly developed and managed. The department’s Grant Management System (GMS) supports staff in the delivery of grant programs by including prescriptive processes around the application process, eligibility and merit assessment of grant applications.
To support improvements in its business processes, the department has upgraded its project management framework to contemporary industry standards, and has established contemporary risk management framework and reviews. The Portfolio Project Management Office was formally established in May 2012 to provide support, Project Governance guidelines, quality assurance and reporting services, training and mentoring services.
 The four target areas were: create jobs or retain people in jobs at risk due to the downturn; build skills for the future; build community infrastructure or improve community amenity which generates local jobs; and provide seed funding for social enterprises to start up, maintain or expand services, generating jobs and improving community services.
 Throughout the audit report, the department responsible for administering the heritage component at the relevant point in time is referred to as the ‘responsible department’ or ‘the department’; and the Minister responsible for the heritage component is referred to as the then Environment Minister, ‘the responsible Minister’ or ‘the Minister’.
 As an economic stimulus program, efficiency was assessed with particular attention to whether the selection and funding agreement processes were undertaken in a timely manner. This emphasis was consistent with the criterion adopted by the Government for the design of the stimulus packages established in response to the global financial crisis (see further at paragraph 6.1 of the audit report).
 Revised Finance Minister’s Instructions for the administration of grants issued in January 2009 applied to the design and establishment of the Jobs Fund, and to the approval of projects under the 2008–09 round of the heritage component. The approval of projects under the 2009–10 round occurred after 1 July 2009, the date that the CGGs and associated legislative and policy framework took effect.
 The guidelines had clearly targeted all components of the Jobs Fund to supporting and creating jobs in areas experiencing high unemployment or significant rises in unemployment or vulnerability. For the heritage component, consideration of the extent to which projects would provide positive heritage outcomes was to occur after a project had been assessed as meeting the overarching gateway criteria (and at least one of the four target areas) and, therefore, eligible for funding consideration. However, the responsible department did not exclude from further consideration projects that had not been demonstrably assessed as meeting the Jobs Fund threshold criteria. By way of comparison, projects that were assessed as not providing good heritage outcomes were excluded such that, in many cases, they were not assessed in terms of their contribution to the employment stimulus aspect of the program’s objectives.
 This was particularly the case in relation to the selection of 2008–09 projects (this process was completed within one month of the program guidelines being published). In addition, once funding decisions were made, the responsible department expeditiously developed and signed funding agreements for approved projects across both funding rounds.
 See further in ANAO Audit Report No.21 2011–12, Administration of Grant Reporting Obligations, Canberra, 24 January 2012.
 In the context of a related audit of the development and approval of grant program guidelines tabled in May 2012, DSEWPaC commented that: ‘DSEWPaC has a growing maturity in the development and evaluation of grant programs and since the audit’s reporting period has implemented a new and robust grants administration framework and dedicated resources to assist with this important activity. In June 2011, DSEWPaC implemented a framework which comprised comprehensive administrative tools for staff in order to provide policy and legislative guidance and better practice on how granting activities should be properly developed and managed.’
 The value of the grants proposed in relation to these 181 projects totalled $58.32 million, compared to the $45.54 million available in 2009–10, of which the Minister approved 162 projects for amounts totalling $45.76 million and the department contracted 158 projects for amounts totalling $45.47 million (as originally contracted), including one project that was contracted for an amount that considerably exceeded the amount identified in the Minister’s written record of approval (see footnote 149 of the audit report).
 For example, the funding agreements executed in relation to 127 projects (66 per cent) provided that the proponents would be entitled to receive between 80 per cent and 95 per cent of grant funds before physical work was required to have commenced on the relevant infrastructure project
 As a result, 43 per cent of the reported employment stimulus occurred in areas with strong or average labour markets rather than defined Priority Employment Areas or other areas with below average or poor labour markets.