Introduction

1.1 Since its emergence in late 2019, coronavirus disease 2019 (COVID-19) has become a global pandemic that is impacting on human health and national economies. On 21 January 2020, the Australian Government declared COVID-19 as a listed human disease under the Biosecurity Act 2015 (Biosecurity Act).⁴ The World Health Organization (WHO) declared COVID-19 to be a ‘public health emergency of international concern’ on 30 January 2020.

1.2 From January 2020, the Australian Government commenced the introduction of a range of policies and measures in response to the emergence of COVID-19. On 18 March 2020, in response to the pandemic in Australia, the Governor-General of the Commonwealth of Australia declared that a human biosecurity emergency exists.⁵

1.3 The Australian Government’s health and economic response has included:

• travel restrictions, international border controls and quarantine arrangements;
• delivery of substantial economic stimulus, including financial support for affected individuals, businesses and communities; and
• support for essential services and procurement and deployment of critical medical supplies (including the national vaccine rollout).

1.4 With the release of the 2022–23 Budget on 29 March 2022, the Australian Government reported that it had committed $314 billion to economic response measures.⁶ In addition, as at April 2022, the Australian Government had committed more than $45 billion to the COVID-19 health response, including more than $8 billion related to COVID-19 vaccines and booster doses.

Development, approval and acquisition of COVID-19 vaccines

1.5 The Australian Government’s initial response to COVID-19 was contained in the Australian Health Sector Emergency Response Plan for Novel Coronavirus (COVID-19), which was published on 18 February 2020.⁷ The plan focussed on measures to reduce transmission, minimise the burden on health systems and ‘inform, engage and empower the public’. It also noted that ‘availability of a customised novel coronavirus vaccine would be the greatest tool in reducing the impact [of COVID-19]’ and committed the Australian Government to:

fast-track assessment and approval of a customised vaccine, should this become available; procure vaccines; develop a national novel coronavirus vaccination policy and a national novel coronavirus immunisation program; and communicate immunisation information on the program to the general public and health professionals.⁸

1.6 Australia has had mass vaccination campaigns since 1924. In 1997, the Australian, state and territory governments jointly established the National Immunisation Program (NIP)⁹, which currently provides free vaccination against 17 diseases for babies, young children, teenagers and older Australians.¹⁰ The NIP has achieved very high immunisation rates, particularly for children.

Development and approval of COVID-19 vaccines

1.7 From January 2020, research organisations and pharmaceutical companies worldwide began developing and testing COVID-19 vaccines at unprecedented speeds.¹¹ The vaccines developed ranged from viral vector and protein vaccines, such as the Oxford AstraZeneca viral vector vaccine (AstraZeneca), to new genetic vaccines, such as the mRNA Pfizer vaccine (Pfizer).

1.8 The Therapeutic Goods Administration (TGA), which forms part of the Department of Health and Aged Care (Health)¹², is Australia’s regulatory authority for therapeutic goods.¹³ The TGA assessed COVID-19 vaccines for safety, quality and effectiveness before they could be supplied in Australia.¹⁴ While achieving full registration for a therapeutic good such as a vaccine can take several years, where the TGA assesses that the benefit of early availability outweighs the risk inherent in the fact that additional data are still required, it can provisionally register the vaccine. All COVID-19 vaccines used in Australia have used the provisional registration process.¹⁵

1.9 Once the TGA approves use of a therapeutic good, it monitors the use of the product to identify potential safety issues. The TGA has monitored the COVID-19 vaccine to identify adverse effects since 22 February 2021 and published a weekly safety report on any issues identified.

Australia’s acquisition of COVID-19 vaccines

1.10 By mid-2020, many potential COVID-19 vaccine candidates had entered clinical trials and countries such as the United States began entering into advance purchase agreements with pharmaceutical companies.¹⁶

1.11 In August 2020, the Australian Government established the Science and Industry Technical Advisory Group (SITAG) to ‘support the Australian Government to make decisions about purchasing and manufacture of COVID-19 vaccines and treatments’. SITAG’s terms of reference state that its purpose is to provide advice on:

• the scientific validity of research into safety and efficacy of COVID-19 vaccine candidates;
• potential purchasing arrangements for COVID-19 vaccine candidates for Australia;
• the scientific validity of research into new therapeutics for COVID-19, including tests and treatments;
• potential purchasing arrangements for COVID-19 therapeutics for Australia;
• the viability of options for manufacturing and packaging COVID-19 vaccines and treatments in Australia;
• distribution and logistics associated with COVID-19 vaccine candidates; and
• other technical matters related to COVID-19 vaccines and treatments, as requested by the Chair.¹⁷

1.12 In August 2020, the Australian Government released Australia’s COVID-19 vaccine and treatment strategy, which committed the Australian Government to building a ‘diverse global portfolio of investments to seek to secure early access to promising vaccines and treatments’, using local manufacturing wherever possible.¹⁸ The criteria which were used to guide investment decisions were:

• availability of the vaccine candidate in 2021;
• experience in the technology platform;
• the track record of the company or partner company in vaccine development;
• complexities involved in the distribution and administration of the candidate (such as the temperature at which they must be stored and transported prior to administration¹⁹);
• the likely volume able to be secured in 2021;
• the clinical trial stage reached; and
• costs related to securing candidates.

1.13 Vaccine efficacy was not one of the factors taken into account in the initial selection of vaccines for purchase. This was because, at that time, none of the vaccines being considered had reached Phase 3 clinical trials where efficacy is tested.²⁰

1.14 Commencing in August 2020, Health presented SITAG with information about a number of vaccine candidates and sought its endorsement to proceed with negotiations with the five companies which produced the vaccines that were ultimately purchased (see Table 1.1). Health then sought the government’s approval to proceed with advance purchase agreements with the selected companies.

Table 1.1: Australia’s COVID-19 vaccine purchase agreements

Note a: Agreements include advance purchase agreements with vaccine manufacturers and agreements with nations to purchase additional vaccine stock.

Note b: The University of Queensland vaccine did not proceed past human trials in December 2020.

Note c: 513,630 Pfizer doses purchased from the COVAX facility.

Note d: 500,000 Pfizer doses were ‘swapped’ with Singapore in August 2021 and repaid in November 2021.

Note e: Four million Pfizer doses were ‘swapped’ with the United Kingdom in September 2021 and repaid in late 2021.

Note f: One million Moderna doses were purchased from European Union member states in September 2021.

Source: ANAO analysis of Health documents and press releases by the Minister for Health and Aged Care and the Prime Minister.

Australia’s COVID-19 vaccine rollout

1.15 Health has been responsible for managing Australia’s COVID-19 vaccine rollout.

1.16 Health published the Australian COVID-19 vaccination policy on 13 November 2020, which included key principles relating to the vaccine rollout.²¹ On 7 January 2021, based on advice from the Australian Technical Advisory Group on Immunisation (ATAGI), Health published Australia’s COVID-19 vaccine national roll-out strategy, which outlined a three-phase rollout strategy commencing with priority populations.²²

1.17 Australia’s COVID-19 vaccine rollout was launched on 22 February 2021 with the provision of the Pfizer vaccine to individuals in Phase 1a (which included quarantine, border and frontline healthcare workers and aged care and disability care residents and staff).²³ The AstraZeneca vaccine was made available from March 2021, with the first dose of AstraZeneca administered in Australia on 5 March 2021.

1.18 In early March 2021, reports began to circulate globally of a rare but potentially serious side-effect of AstraZeneca. ATAGI monitored these reports and published several updates. On 8 April 2021, ATAGI updated its advice, recommending the use of Pfizer as the preferred vaccine for eligible people under 50 years of age.²⁴ As a result, Health ‘recalibrated’ the rollout, including by changing the recommended age ranges for some population groups.

1.19 Until June 2021, the rollout was administered by a taskforce within Health. In June 2021, the Prime Minister appointed Lieutenant General John (JJ) Frewen DSC AM as the Coordinator General of Operation COVID Shield.²⁵ The Coordinator General assumed control of the taskforce and was directed by the Prime Minister to report directly to him and the Minister for Health and Aged Care, while working closely with the Secretary of Health.

1.20 By 31 December 2021, all people aged 12 years and above were eligible, and encouraged, to receive a COVID-19 vaccine. On 8 November 2021, the Australian Government began a vaccine booster program, for people to receive an additional dose of vaccine to provide additional protection. This was initially targeted to priority groups most at risk, such as the elderly and the immunocompromised. From 10 January 2022, the Australian Government expanded eligibility for the program to include those aged five to 11 years.²⁶

1.21 As at 30 June 2022:

• 60.3 million vaccine doses had been administered, 39.0 million of these by Australian Government providers such as pharmacies, general practitioners (GPs) and contracted providers; and
• 19.8 million people aged 16 or over (over 95 per cent) had received at least two vaccine doses.

1.22 Figure 1.1 is a timeline key events that occurred in the lead up to, and during, the vaccine rollout.

Figure 1.1: COVID-19 vaccine rollout key events, 1 August 2020–31 December 2021

Source: ANAO from Health documents.

Rationale for undertaking the audit

1.23 The COVID-19 pandemic and the pace and scale of the Australian Government’s response impacts on the risk environment faced by the Australian public sector. This performance audit was conducted under phase two of the ANAO’s multi-year strategy that focuses on the effective, efficient, economical and ethical delivery of the Australian Government’s response to the COVID-19 pandemic.²⁷

1.24 The distribution and delivery of COVID-19 vaccines have been one of the largest exercises in health logistics in Australian history. The COVID-19 vaccine rollout has required rapid and flexible planning, decision-making and implementation, to respond to the changing health, social and economic impacts of COVID-19, as well as the effective and timely acquisition and distribution of vaccines once they were created. The audit was conducted to provide independent assurance to the Parliament that Australia’s COVID-19 vaccine rollout was planned and implemented effectively. The audit was identified by the Joint Committee of Public Accounts and Audit as an audit priority of the Parliament.

Audit approach

Audit objective, criteria and scope

1.25 The objective of the audit was to assess the effectiveness of the planning and implementation of the COVID-19 vaccine rollout.

1.26 To form a conclusion against this objective, the following high-level criteria were adopted.

• Has the approach to planning Australia’s COVID-19 vaccine rollout been effective? (Chapter 2)
• Have effective governance arrangements been established to manage the COVID-19 vaccine rollout? (Chapter 3)
• Has the COVID-19 vaccine rollout been effectively implemented? (Chapter 4)

1.27 The scope of the audit did not include:

• the procurement of the vaccines selected for use in Australia;
• the administration of vaccinations by state and territory governments, including state and territory vaccine immunisation hubs;
• the safety or effectiveness of vaccines purchased by the Australian Government, or any other matters requiring clinical expertise;
• the administration of vaccines to Australian Government employees overseas (such as Department of Foreign Affairs staff); or
• the donation of vaccines by the Australian Government to countries in the Pacific and Southeast Asia.²⁸

1.28 The audit focused on the period from the first occurrence of COVID-19 in Australia until 31 December 2021. For that reason, there is limited examination of the implementation of the booster program, which began late in 2021, or the implementation of the rollout for children aged five to eleven, which did not begin until 2022.

Audit methodology

1.29 The audit involved:

• reviewing submissions and briefings to the Australian Government;
• reviewing Health’s documentation including meeting papers and minutes, policies, procedures and correspondence;
• analysing data held in systems used by Health;
• meetings with officers from relevant business areas within Health;
• reviewing 22 submissions and meeting with stakeholders in the health sector, state and territory governments and COVID-19 advisory groups²⁹; and
• reviewing 507 contributions received from organisations and individuals via the ANAO’s ‘contribute to this audit’ facility.

1.30 The audit was conducted in accordance with ANAO Auditing Standards at a cost to the ANAO of approximately $845,000.

1.31 The audit team members for this audit were Julian Mallett, Laura Trobbiani, Anne Kent, Sarah Koehler, Olivia Robbins, Elizabeth Wedgwood, Matthew Rigter, Alexander Wilkinson and Daniel Whyte.

2.1 As noted in paragraph 1.24, the distribution and delivery of COVID-19 vaccines have been one of the largest exercises in health logistics in Australian history. When an initiative is urgent, planning and implementation may need to occur quickly or in stages, prioritising critical foundations and building on them later. One of the most pressing priorities is to reduce risk by seeking expert implementation advice and experience as soon as possible in the delivery phase and adjusting policy and/or delivery settings as necessary.

2.2 This chapter examines whether rollout planning was conducted in a timely fashion and based on evidence. It also examines the assessment of risks to the rollout, the logistics and ‘channels’ used to deliver and administer vaccines, and whether a fit-for-purpose communication strategy was developed.

Was planning timely and informed by appropriate evidence?

2.3 On 7 August 2020, the Prime Minister announced that Australian governments³¹ had ‘strongly welcomed the Commonwealth Government’s COVID-19 Vaccine and Treatment Strategic Approach that provides a framework for securing early access to safe and effective vaccines and treatments’.³²

2.4 Australia’s COVID-19 vaccine and treatment strategy (the vaccine and treatment strategy), released on 18 August 2020, stated that the government was ‘working in five areas to deliver safe and effective COVID-19 vaccines and treatments’: research and development; purchase and manufacturing; international partnerships; regulation and safety; and immunisation administration and monitoring.³³

2.5 On 13 November 2020, Health published the Australian COVID-19 vaccination policy (the vaccination policy).³⁴ The vaccination policy set out ‘the key policy parameters and approach to providing COVID-19 vaccines’, including high-level information on:

• roles and responsibilities of the Australian, state and territory governments and other key stakeholders in a COVID-19 pandemic vaccination program;
• information on the vaccines purchased by the Australian Government;
• key features of the vaccination program, including how doses would be made available to priority population groups and where and how vaccination would take place;
• how vaccine safety would be monitored;
• how data would be collected and reported; and
• how information on COVID-19 vaccines and vaccination would be made available to consumers and clinicians.

Rollout planning to June 2021

2.6 The vaccine and treatment strategy (released on 18 August 2020) stated that ‘Australian Government agencies are working with states and territories on transportation, storage and distribution plans. This will ensure vaccines, syringes and needles can be moved and stored securely and distributed rapidly’. However, although Health advised that it had monthly meetings between July and November 2020 with states and territories about ‘COVID planning’, the evidence shows that detailed engagement with the states and territories on rollout planning did not begin until November 2020.

2.7 At a meeting of state and territory health authority chief executive officers (CEOs) on 6 November 2020³⁵, Health outlined a number of key principles and assumptions for the rollout, which were:

• the rollout would not initially be administered under the National Immunisation Program (NIP)³⁶;
• the rollout would be free for all Australian citizens, permanent residents, and most visa-holders³⁷;
• vaccination would not be mandatory, but encouraged and likely incentivised;
• vaccination would be rolled out on the basis of identified priority populations, linked to delivery schedules, with scope for outbreak response; and
• the Australian Government would oversee the rollout, with defined responsibilities for the Australian, state and territory governments and shared governance.

2.8 A document prepared for the meeting emphasised that ‘connectivity of implementation plans and clear responsibilities are crucial’ and stated that individual Jurisdictional Implementation Plans (JIPs) were intended to be developed between the Australian Government and each state and territory government. The aim was to have JIPs with all jurisdictions agreed by early December 2020.

2.9 Between 18 and 23 November 2020, Health held a series of bilateral meetings with each state and territory health authority to ‘design jurisdictional implementation plans that are aligned with the Vaccination Policy’. Topics discussed included:

• vaccination locations³⁸, workforce and training requirements;
• vaccine transport, delivery and storage;
• monitoring and reporting on vaccine stock, and minimising wastage;
• coordinating safety monitoring and surveillance of adverse events; and
• communication.

2.10 ‘Early indicative drafts’ of the JIPs were sent to each state and territory health authority on 29 November 2020. The ANAO saw evidence of a lengthy consultative and redrafting process during December 2020 and January 2021, with several versions of JIPs being circulated. The JIPs were agreed by state and territory governments in February 2021.³⁹

2.11 The JIPs repeated the respective responsibilities of the Australian, state and territory governments that had been stated in the vaccination policy (see paragraph 2.5). They also contained detailed information about the topics which had been discussed during the earlier bilateral meetings (see paragraph 2.9).

2.12 While some arrangements for the rollout could not be finalised until it was known which vaccines were available⁴⁰, the statement in the August 2020 vaccine and treatment strategy that ‘Australian Government agencies are working with states and territories on transportation, storage and distribution plans’ was not accurate. More than two and a half months elapsed between the release of the vaccine and treatment strategy (on 18 August 2020) and the first meeting between Health and state and territory health authority CEOs on 6 November 2020 at which Health first put forward the ‘proposed responsibilities for States and Territories’.

Determining priority populations

2.13 Both the vaccine and treatment strategy and the vaccination policy stated that ‘the Australian Technical Advisory Group on Immunisation (ATAGI) is preparing advice to support planning for the allocation and use of safe and effective vaccines’.⁴¹

2.14 ATAGI issued two sets of advice ‘aimed at supporting planning by the Australian Government in the development of a strategy for the procurement of COVID-19 vaccines and program delivery’. The preliminary advice (summarised in Table 2.1) was provided to the Australian Government in August 2020 and recognised that ‘when vaccines are available, supplies will initially be limited and priority groups for vaccination will need to be identified’ and that ‘prioritisation should be based on evidence influenced by the prevailing epidemiology when specific vaccines become available’.⁴² Following further considerations of the progress of clinical trials and international approvals, the advice was finalised and publicly released on 13 November 2020.

Table 2.1: ATAGI preliminary advice on priority population groups

Source: Department of Health, ATAGI – Preliminary advice on general principles to guide the prioritisation of target populations in a COVID-19 vaccination program in Australia [Internet], 13 November 2020.

2.15 On 24 December 2020, ATAGI provided the Australian Government with supplementary advice which added to its preliminary advice and more specifically identified which population groups should be accorded priority.⁴³ Based on ATAGI’s advice, Health prepared Australia’s COVID-19 vaccine national roll-out strategy (the rollout strategy)⁴⁴, which was released on 7 January 2021 and announced by the Prime Minister at a press conference on the same day.⁴⁵ Table 2.2 shows the rollout phases, priority populations and the estimated number of people in each population.

Table 2.2: Rollout strategy: priority populations (as identified by Health)

Source: Department of Health, Australia’s COVID-19 vaccine national roll-out strategy.

AstraZeneca recalibration

2.16 The initial stages of the rollout were heavily reliant on the AstraZeneca vaccine, with AstraZeneca comprising 80 per cent of the allocation of doses to sites over the first 12 weeks of the rollout.⁴⁶

2.17 As discussed at paragraph 1.18, in early March 2021, reports began to circulate internationally about a rare but potentially serious side-effect⁴⁷ of the AstraZeneca vaccine which appeared to be more prevalent in younger people. ATAGI monitored these reports and published several updates. On 8 April 2021, ATAGI updated its advice, recommending the use of Pfizer as the preferred vaccine for eligible people under 50.⁴⁸

2.18 In April 2021, Australian governments considered options for the ‘recalibration’ of the vaccine strategy. Issues discussed included limited current supplies of Pfizer, changes to aged-based eligibility, the rollout to remote communities and increasing negative community sentiment towards AstraZeneca.⁴⁹

2.19 On 22 April 2021, the Prime Minister announced that Australian governments had approved key changes to the COVID-19 vaccination rollout strategy.⁵⁰ Seven of the key changes are listed in Table 2.3. Health implemented some changes, such as vaccine eligibility, in April 2021 and implemented other changes between May and August 2021.

Table 2.3: ANAO assessment of Health’s implementation of key changes under the recalibrated rollout strategy

Note a: ATAGI continued to monitor national and international safety data around AstraZeneca and on 17 June 2021 updated its advice to recommend the use of Pfizer as the preferred vaccine for eligible people under 60.

Note b: Date implemented is recorded as the date when the change was implemented in at least one jurisdiction or channel as relevant.

Source: ANAO analysis of Health documentation.

2.20 Health also acquired additional Pfizer doses to address the potential vaccine shortfall, consistent with the recalibrated rollout strategy. Between April 2021 and September 2021, Health ordered an additional 25.5 million Pfizer doses for delivery in 2021. These doses were delivered from mid-August with the majority to be available from September 2021.⁵¹

2.21 The change in ATAGI advice on AstraZeneca resulted in limited supply of vaccines preferred for people under 60 until September 2021.⁵² Health adapted the plan for the vaccine rollout and implemented these changes in a timely manner. This included encouraging the use of existing stocks of AstraZeneca while waiting for Pfizer suppply to increase from September 2021.

Sectoral vaccination program implementation plans

2.22 As noted in Table 2.2, people in residential aged care, Aboriginal and Torres Strait Islander people over 55 years and people with disabilities were three of the priority groups for vaccination under Phases 1a and 1b. In addition, Health identified people from culturally and linguistically diverse (CALD) communities as a group which, while not identified by ATAGI as a priority population, might need greater assistance or support due to language and cultural issues.

2.23 Health developed specific vaccination program implementation plans for each of these groups in early 2021, which contained tailored sector-specific information as well as information about:

• Australian, state and territory government responsibilities (and other parties where relevant);
• workforce and training requirements;
• arrangements for safety monitoring and surveillance of adverse events⁵³;
• minimising wastage, monitoring stock and reporting; and
• communication to people in the sector.

2.24 The plans for aged care, Aboriginal and Torres Strait Islander people and CALD communities were published on Health’s website in February and March 2021. The plan for people with disabilities was not published.⁵⁴

Establishment of target dates in planning

2.25 The vaccine and treatment strategy and the vaccination policy (see paragraphs 2.4 and 2.5) did not contain any target dates or indication when the rollout would start or finish. At the time that these documents were published, it was not known when vaccines would become available. Jurisdictional Implementation Plans (see paragraphs 2.8 to 2.12) contained ‘indicative timelines’ for when the phases referred to in Table 2.2 would commence but not when they might be completed.

2.26 In late 2020 and early 2021, the Prime Minister, the Minister for Health and Aged Care and the Secretary of Health made a number of public statements and commitments about:

• when the rollout would commence;
• the date by which people could expect to be (or be given the opportunity to be) vaccinated; and
• when priority or vulnerable groups would be vaccinated.⁵⁵

2.27 Health did not include target dates for the rollout as part of its planning prior to June 2021. In March 2021, the COVID-19 vaccination program was the subject of an Implementation Readiness Assessment (IRA)⁵⁶ commissioned by the Department of Finance, which noted that achievement of the ‘policy commitment to complete the vaccination program by end October 2021’ was ‘highly unlikely’ and found:

the Program has adopted a just-in-time approach to planning, and has an acute focus on the next four weeks. The review team has seen only a high-level plan and no supporting detail for the medium term (until end October). Further, the vaccination deployment modelling beyond April is high level and incomplete. With the delivery of large quantities of vaccine by CSL (Seqirus) by end March, there is no justification for not having a model and delivery schedule for the entire program. The review team finds that the lack of this model and schedule is impeding preparations for future rollout, including by states and territories, that may require considerable lead times. The lack of a model and schedule for the medium term also means that it is not possible to have confidence in achievement of an end-October target.

2.28 The IRA’s recommendations included:

• Consider the use of intermediate objectives that demonstrate key public health outcomes prior to the October target. An example would be ‘all vulnerable Australian are protected’, as at the end of Phase 1a and 1b.
• Consider modifying the Program’s public objective to a more achievable version such as ‘all eligible Australians will be offered the vaccine and will have the opportunity to commence vaccination by end-October’.
• Develop a vaccination deployment model and associated plan for the next 8-12 months…

2.29 Health ‘noted’ these recommendations and its response was contained in an internal document which was not prepared until July 2021, after the establishment of Operation COVID Shield. The response to the recommendation on intermediate objectives read:

To support the recalibration following National Cabinet’s decision on April 16, the overarching narrative and guiding communications principles of the roll out have been revisited and the revised strategic approach supersedes the intent of this recommendation.

The revised approach includes focus groups for key cohorts, the exploration of partnerships to reach specific audiences and a refresh of the communications campaign. Vaccine Communications are also working closely with [the Department of the Prime Minister and Cabinet] to ensure the approach remains responsive to public sentiment. Key artefacts including Stakeholder Engagement and Communications Plan and External Communications Playbook have been revised.

2.30 Following the transition to Operation COVID Shield, lower-level targets were developed for some aspects of the rollout (see paragraph 2.37). Health’s reporting against these targets is discussed at paragraph 3.36 and achievement of targets is discussed in Chapter 4 and Appendix 4.

Rollout planning from June 2021 (Operation COVID Shield)

2.31 At a press conference on 4 June 2021, the Prime Minister announced the appointment of the Coordinator General of Operation COVID Shield, stating:

Lieutenant General Frewen will have direct operational control across numerous government departments for the direction of the national vaccination program and all of those working in that program, from communications to dealings with states, to the distribution and delivery of vaccines and all of these matters, and the ramp-up, the scale-up, the working with the GPs, pharmacists and others, this will all come under the direct control of Lieutenant General Frewen… I think that very direct command and control structure that has proved to be so effective in the past will add a further dimension and assistance as we step up in this next phase.⁵⁷

2.32 The ANAO sought Health’s comments on the reasons for the move to a ‘command and control’ model and how that differed from the previous arrangements. Health said:

Operation COVID Shield used a command and control structure to coincide with an influx of new supply, and a need to increase the size and speed of the rollout. The command and control structure included direct operation control of all relevant assets and resources across all Commonwealth Government departments and agencies engaged in the direction and implementation of the national COVID vaccination program. [Operation COVID Shield] introduced a military led planning team and an assessment cell to support the command and control structure of the operation. The plans and assessment cells differ from traditional structures as they span all of the areas of the taskforce and aim to consolidate planning and tracking across all branches with a direct report to Coordinator General, as opposed to decentralised planning normally undertaken within the branches.

Operation COVID Shield campaign plan

2.33 On 3 August 2021, the Coordinator General released the Op COVID Shield National COVID Vaccine Campaign Plan (the campaign plan)⁵⁸, which was stated to cover the period from 1 July 2021 to 31 December 2021. The plan described several challenges existing at that time, including:

• changed guidance from ATAGI in April 2021 (see paragraph 2.17) in relation to potentially dangerous side-effects associated with the AstraZeneca vaccine, which resulted in reduced confidence in the AstraZeneca vaccine and a surge in demand for the Pfizer vaccine;
• limited global supply of the Pfizer vaccine;
• delays in delivery to some priority groups due to global supply challenges, domestic supply shortfalls and ‘scale up’ challenges with vaccine administration service providers⁵⁹; and
• changes made by states and territories to agreed vaccine eligibility criteria.

The campaign plan was divided into three stages (shown in Figure 2.1) which were based on anticipated vaccine supply and linked to and balanced with the progressive introduction of administration channels (discussed further at paragraph 4.8).

Figure 2.1: Operation COVID Shield campaign plan stages

Source: Operation COVID Shield campaign plan (Department of Health).

2.34 To assist vaccination providers (including those for which the states and territories were responsible) with their own planning, in June 2021, Health published ‘COVID Vaccination Allocations Horizons’ which showed the notional allocations for each state and territory by vaccine and channel for July to August 2021 (Horizon 1), September 2021 (Horizon 2) and October to December 2021 (Horizon 3). Later editions of the ‘Horizons’ were published in July and September 2021, with allocations updated based on modelling of future supply.

2.35 With regard to priority populations, the campaign plan stated that:

There are populations that have circumstances that require unique consideration to ensure equity of access and confidence in the vaccine rollout. To safeguard the health and wellbeing of the Australian population, it is critical that these priority groups have access to vaccines and are supported in receiving them.

2.36 The ten priority populations identified in the campaign plan are listed in Table 2.4.

Table 2.4: Operation COVID Shield campaign plan: priority populations

Note a: This includes people who are homeless, those in prison, those requiring drug and alcohol support, those in mental health facilities and social housing.

Source: Department of Health Operation COVID Shield campaign plan.

Sub-plans

2.37 To support the campaign plan, Health developed a series of sub-plans, including ‘acceleration plans’, which focused on specific priority groups and sectors. While the content of the sub-plans varied according to topic, they generally set out specific tasks and lower-level target dates for priority groups and sectors and were more consistent with the intention of the recommendation in the March 2021 Implementation Readiness Assessment (see paragraph 2.27). Examples of sub-plans are shown in Table 2.5.

Table 2.5: Examples of Operation COVID Shield sub-plans

Note a: The sub-plan did not set a specific target: it outlined ‘efforts to ensure that regional and remote communities are able to reach 70% and 80% fully vaccinated targets in line with the general population’.

Source: ANAO from Health documents.

Were risks to the rollout identified and regularly reassessed?

2.38 Under the Public Governance Performance and Accountability Act 2013 (PGPA Act), the accountable authority⁶⁰ must establish and maintain appropriate systems of risk oversight, management, and internal control for the entity.⁶¹ The Commonwealth Risk Management Policy sets out the government’s risk management expectations for Australian Government entities in undertaking the business of government.⁶²

2.39 There was early awareness that vaccination of the entire Australian population would be attended by many risks. For example, advice provided to government in June 2020 observed that the most significant risk was that there may never be a COVID-19 vaccine. As it became clear that a number of potentially effective vaccines would likely be available, internal documents show that Health started considering rollout risks in the latter part of 2020.

2.40 The August 2020 vaccine and treatment strategy committed the government to building a ‘diverse global portfolio of investments to seek to secure early access to promising vaccines and treatments, using local manufacturing wherever possible’. Two of the vaccines initially selected for purchase, the University of Queensland vaccine and AstraZeneca, were intended to be manufactured in Australia. At the time that advance purchase agreements for COVID-19 vaccines were signed, none of the selected vaccines had reached Phase 3 clinical trials and hence achieved TGA approval (see paragraph 1.8), which is a pre-requisite for use in Australia. In September 2020, an internal Health document identified a risk that ‘Domestic manufacture [is] not possible because negotiated candidate is not approved, further reducing dose volume’. This risk was subsequently realised (see case study 1).

Note a: On 11 December 2020, the University of Queensland reported: ‘There is no possibility the vaccine causes infection, and routine follow up tests confirmed there is no HIV virus present. With advice from experts, CSL and UQ have worked through the implications that this issue presents to rolling out the vaccine into broad populations. It is generally agreed that significant changes would need to be made to well-established HIV testing procedures in the healthcare setting to accommodate rollout of this vaccine’.

Note b: AstraZeneca and Novavax had each indicated they could provide sufficient doses to cover the whole of the Australian population. The additional doses for both vaccines were announced on 11 December 2020. Negotiations for the additional doses of AstraZeneca and Novavax concluded on 24 December 2020, and 31 December 2020 respectively.

Risks and issues log

2.41 In December 2020, Health created a ‘risks and issues log’ which contained both a risk register and an issues log. With respect to risks, the log showed:

• the date that the risk was logged and who raised it;
• the risk owner and impacted workstream;
• the impacted stakeholder group⁶³;
• the risk name, description and impact (if it were to occur);
• the current risk level (likelihood and consequence);
• the control assessment and treatment plan (if necessary); and
• the target risk rating.

2.42 The issues log was similarly detailed. Its purpose was to record what action had been taken with respect to identified risks.

2.43 One of the risks identified in the risks and issue log was that ‘uptake is below desired levels due to consumer sentiment’.⁶⁴ This risk was also realised with the AstraZeneca vaccine (discussed at paragraphs 2.17 to 2.21).

2.44 The earliest version of the risks and issues log that the ANAO located (dated 15 January 2021) contained 79 risks. Some examples included:

• adverse event management — incomplete and inaccurate data;
• lack of suitably safe vaccine candidates;
• shortages of critical materials required for vaccinations;
• COVID-19 outbreak occurs impacting rollout; and
• immunisation workforce not sufficient, ready or appropriately skilled.

2.45 The latest version of the risks and issues log examined by the ANAO was dated 6 December 2021. It contained 301 risks, with risks added progressively throughout 2021.

2.46 Health instituted a process by which ‘top risks and issues’ were the subject of a ‘deep dive’ to assess the risk and consider whether any specific action was necessary. Risks rated ‘high’ or ‘extreme’ were then presented to a weekly meeting of the taskforce leadership group⁶⁵, which reviewed the proposed corrective action and whether it was satisfied with the outcome. The ANAO reviewed examples of this process and found there was robust consideration of key rollout risks.

2.47 The consistent use of a risk register and a documented process to respond to risks as they arose demonstrates good practice.

Were administration channels and logistics considered and established?

Administration channels

2.48 With more than 20 million people in Australia needing to be given at least two doses of vaccine⁶⁶, it was clear from the outset that as many administration channels as possible would need to be used.⁶⁷ The vaccination policy, published in November 2020, stated:

Vaccination sites will be agreed by the Australian Government and the States and Territories through their jurisdictional implementation plans. There are a number of likely vaccination locations. All vaccines must be administered in accordance with the relevant legislation, best practice, and the guidelines and recommendations the Australian Immunisation Handbook. Vaccination locations must facilitate the safety of vaccines, staff, and consumers; be adequately staffed with appropriately trained personnel; have the facilities and protocols in place to ensure data is reported in an accurate and timely way; and be able to manage high volumes of vaccinations.⁶⁸

2.49 Other factors that influenced decisions about administration channels were:

• the difficulty some people (such as the elderly and people with disabilities) would have in attending a location such as a general practice;
• availability of vaccines;
• distribution capacity of logistics providers;
• the remoteness of some smaller areas of population; and
• the necessity to keep some vaccines ultra-cold at all times from manufacture until administration.

2.50 Under long-standing arrangements, responsibility for the administration and funding of health care facilities in Australia is shared between the Australian and state and territory governments. For example, while in 2017–18, the Australian Government provided 39 per cent of funding for public hospitals⁶⁹, responsibility for their administration rests entirely with states and territories. Consequently, arrangements for establishing which locations would administer vaccines was one of the issues negotiated during the development of JIPs (see paragraph 2.9). Table 2.6 shows the administration channels that were used for the rollout and which government was responsible for the administration of vaccines for each.⁷⁰

Table 2.6: Vaccine administration channels: responsible governments

Source: Health.

2.51 While some administration channels were established specifically to cater to particular priority groups⁷¹, people in those groups were not limited to only those administration channels. If they were able to, or preferred to, they could use another administration channels (such as their own general practitioner). Table 2.7 links the priority groups with the administration channels shown in Table 2.6. The introduction of administration channels was staged based on the priority populations they were targeting and Health’s modelling of expected vaccine supply. The implementation of administration channels is discussed in Chapter 4.

Operational planning for in-reach services

2.52 Most administration channels listed in Table 2.7 utilised existing infrastructure and processes, such as vaccines being administered by GPs. Health needed to establish new arrangements for in-reach services to the residential aged care and residential disability sectors, which required detailed operational planning.

2.53 Following an approach to market in December 2020, in late January 2021 Health engaged two Vaccine Administration Service (VAS) providers to conduct in-reach visits to residential aged care facilities. Health issued the first work orders under these contracts in early February 2021 and the providers began administering vaccines at residential aged care facilities when the rollout began on 22 February 2021. These work orders included detailed operational requirements, such as site requirements and RACF locations. Health engaged additional VAS providers later in the rollout when it identified the current arrangements were at high risk of not meeting its target dates for this area. The additional VAS providers were engaged under similar arrangements, as discussed in paragraphs 4.37 and 4.47.⁷²

2.54 To plan the administration of vaccines to the residential disability sector, Health contracted a VAS provider (Aspen Medical) on 19 February 2021 to engage with key stakeholders and co-design the delivery model. This was provided to Health on 26 February 2021, and Health confirmed the model and approach for the rollout to the residential disability sector on 10 March 2021, more than one month later than for the residential aged care sector and after the rollout had commenced. On 1 April 2021, Health executed a work order with the same VAS provider used in the residential aged care rollout to provide in-reach services to the residential disability sector. Health engaged an additional VAS provider in May 2021, when existing arrangements proved to be insufficient. Health supplemented its arrangements for in-reach with operational policies and procedures, such as the excess dose policy.

2.55 The need to engage additional VAS providers later in the rollout indicates that Health underestimated the magnitude and complexity of the in-reach rollout to aged care and residential disability facilities. This issue is discussed further at paragraphs 4.35 and 4.47.

Logistics

2.56 In December 2020, Health entered into contracts with DHL and Linfox to co-design arrangements for the delivery of vaccines and ancillary consumables such as syringes throughout Australia. Logistical services contracts were signed with both providers in February 2021. Each provider was allocated responsibility for deliveries to particular geographical regions of states and territories. The providers were required to report to Health monthly on:

• cold chain compliance;
• data integrity;
• completeness and timeliness of deliveries;
• reporting and remediation of incidents; and
• lost, damaged or stolen vaccines and consumables.

2.57 Distribution and logistics services commenced in February 2021 for DHL and March 2021 for Linfox. Implementation of the logistics arrangements is discussed further at paragraphs 4.3 to 4.5.

Was a fit-for-purpose communication strategy for the COVID-19 vaccine rollout developed?

2.58 Public communication can include advertising campaigns⁷³, information campaigns and a variety of other media, information and marketing activities. Effective public communication is particularly important during a crisis such as the COVID-19 pandemic, as governments seek to convince the public to take prompt action to protect public health.

2.59 Health developed two strategies to guide communication of the COVID-19 vaccine rollout:

• the Communication strategy: COVID-19 vaccines and treatments (communication strategy), developed in October 2020, which outlined Health’s overarching strategy for communicating the vaccine rollout; and
• the COVID-19 Vaccines Campaign Advertising Campaign Strategy (advertising strategy), approved on 11 January 2021, which addressed the public relations and advertising for the rollout.

Communication strategy (October 2020)

2.60 Health developed a draft communication strategy for Australia’s COVID-19 vaccine and treatments strategy in October 2020. Health was unable to provide evidence that the draft strategy was approved. Health informed the ANAO that the strategy was a living document and was updated throughout the vaccine rollout.

2.61 To assess whether Health’s communication strategy was fit-for-purpose, the ANAO examined whether it:

• outlined its objectives and strategic approach;
• was evidence-based;
• identified its target audience; and
• considered risk.⁷⁴

Objectives and strategic approach

2.62 The objective of the communication strategy was to:

Provide timely, transparent and credible information to inform and educate the Australian public about the Government’s COVID-19 Vaccine and Treatments Strategy. This will build confidence in the regulatory processes for COVID-19 vaccines and treatments, keep Australian’s up to date on progress of and vaccine candidates, including international developments and local investment in research and ensure implementation plans for a national vaccination program are clearly communicated to support high uptake.

2.63 To achieve the communication strategy’s objective, Health developed six principles for communication:

• be the authoritative source of information;
• meet specific information needs;
• address known motivators;
• create genuine engagement with the health sector;
• take preventative measures; and
• support implementation.

2.64 The ANAO assessed that Health’s communication principles collectively addressed the principles for effective communication in public health outlined in the World Health Organisation’s (WHO’s) Strategic Communication Framework for effective communications.⁷⁵

2.65 Health’s communication strategy identified 16 communication channels to achieve its objective, including Australian Government websites, paid advertising, webinars and newsletters to health professionals⁷⁶, and outlined high level key messages to be used on these channels. The strategy also established four phases of activity which aligned with the phases of the vaccine rollout (see Table 2.8).

Table 2.8: Planned communication phases for the vaccine rollout

Note a: Phase 3 and Phase 4 of communications were consolidated into one phase in December 2020.

Source: Health.

Evidence-based

2.66 The development of the communication strategy was informed by market research on vaccines and COVID-19, including monitoring of public sentiment.⁷⁷ For the research conducted for the vaccine rollout, the focus groups contained a sample across age, gender, income, cultural and linguistic background and indigeneity. The research identified the public’s likelihood to get vaccinated as well as motivators and barriers for vaccination.

2.67 Health used information from market research to generate targeted messaging. For example, Health’s market research in December 2020 identified that, although support for vaccines was high, 30 per cent of Australians were hesitant to receive a COVID-19 vaccine. Health developed communication activities to target these hesitant Australians. This included regular media engagement by senior officials and advertising materials addressing barriers to vaccination.

2.68 The communication strategy identified key stakeholders to provide expert advice on communication materials and identify appropriate channels for target audiences. These stakeholders include health and community sector peak bodies and health advisory groups.

Target audience

2.69 The communication strategy identified the Australian public and the health sector as the primary audiences for information on the vaccine rollout. Health also identified specific populations to target including: culturally and linguistically diverse communities; Aboriginal and Torres Strait Islander people; people with a disability; older Australians; and hesitant segments of the Australian population.

Risk

2.70 The communication strategy considered communication and rollout risks.⁷⁸ The communication risks and their mitigations are shown in Table 2.9. The mitigations focused on communication activities.

Table 2.9: Summary of communication risks identified for the vaccine rollout and mitigations

Source: Health.

Advertising strategy (January 2021)

2.71 The advertising strategy was approved by the Australian Government on 11 January 2021 and supported the communications strategy by addressing advertising and public relations for the vaccine rollout. Consistent with the Australian Government Guidelines on Information and Advertising Campaigns by non-corporate Commonwealth entities (the guidelines) the Australian Government also approved amendments to the advertising strategy and the advertising concepts for each of the three phases of the advertising campaign.

2.72 The guidelines set out five principles and the approval and evaluation process which advertising by all non-corporate Commonwealth entities must comply with. The ANAO assessed that Health’s advertising for the vaccine rollout followed the process included in the guidelines and complied with principles one to four.⁷⁹ These four principles require advertising to be: relevant to government responsibilities; presented in an objective, fair and accessible manner; objective and not directed at promoting party political interests; and justified and undertaken in an efficient, effective and relevant manner.

2.73 Health did not include measures for success in the communication strategy but the supporting advertising strategy outlined how it would measure its success. Many of these measures of success tracked high level desired impacts, such as public sentiment towards COVID-19 vaccines. This allowed Health to also monitor communication more broadly.

3.1 Appropriate governance arrangements need to be established early in any emergency response or rapid implementation process to optimise their value. At the whole-of-government level, this can be achieved by mobilising standing governance and coordination arrangements outlined in crisis preparedness frameworks and plans. At the entity level, accountable authorities need to determine what is fit-for-purpose in the specific circumstances facing their entities and ensure that governance considers impacts on business-as-usual activities and changes to risk tolerance levels and risk control measures.

3.2 To assess whether Health established effective governance arrangements to manage the COVID-19 vaccine rollout, the ANAO examined whether: fit-for-purpose governance arrangements were established; key responsibilities were assigned; effective arrangements were put in place for monitoring and reporting progress; and fit-for-purpose stakeholder engagement was undertaken.

Were fit-for-purpose governance arrangements established and key responsibilities adequately assigned?

Health governance arrangements

3.3 As noted at paragraph 1.19, the administration of the vaccine rollout had two phases. Until June 2021, the rollout was administered by a taskforce within Health. In June 2021, the Prime Minister established Operation COVID Shield and appointed a Coordinator General for the rollout. An Office of the Coordinator General was created, with some reorganisation of responsibilities. This section deals with each phase separately.

Governance arrangements to June 2021

3.4 Health initially established a vaccine strategy taskforce in June 2020, headed by an officer at the Senior Executive Service (SES) Band 2 level (First Assistant Secretary). The structure is shown in Figure 3.1.

Figure 3.1: Initial Health high level organisation and governance chart to June 2021

Note a: SRO means Senior Responsible Officer.

Note b: The Chief Medical Officer is an officer of Health and is also the principal medical adviser to the Minister for Health and Aged Care.

Note c: PwC were contracted to establish and run a Program Delivery Office to assist with the central coordination and delivery of the rollout program.

Note d: The number of SES Band 1 officers increased over the rollout from 6 officers in February 2021 to 11 officers in June 2021.

Source: Health.

3.5 Within the taskforce, a total of seven workstreams were initially established, each headed by an SES Band 1 level officer (Assistant Secretary). The number of workstreams increased over time to nine in February 2021 and eleven in June 2021. The workstreams as at February 2021 and the responsibilities assigned to each workstream are shown in Table 3.1.

Table 3.1: Vaccine strategy taskforce workstreams assignment of responsibilities as at February 2021

Source: Health.

Operation COVID Shield governance arrangements after June 2021

3.6 At a press conference on 4 June 2021, the Prime Minister announced the appointment of the Coordinator General of Operation COVID Shield. He said:

Some years ago, you might recall, there was an operation called Operation Sovereign Borders, I put in place at that time with Prime Minister Abbott, a completely new organisational structure to for getting a whole of government effect on a very big problem. It worked on that occasion and I think moving that footing now will further improve how we’re working in the vaccination program. Lieutenant General Frewen will have direct operational control across numerous government departments for the direction of the national vaccination program and all of those working in that program, from communications to dealings with states, to the distribution and delivery of vaccines and all of these matters, and the ramp-up, the scale-up, the working with the GPs, pharmacists and others, this will all come under the direct control of Lieutenant General Frewen.

3.7 At a later press conference in February 2022, the Prime Minister said:

on the vaccination programme, if I had my time over, I would have put it under a military operation from the outset and not later in the year. But we’d all worked up the plan together. Going through cabinet, our cabinet, been through the National Cabinet and set out the timetables. We’d had the goal of ensuring that everyone who wanted a vaccine, could be offered one by October, the record that was achieved on the 25th of October. And as we went through those early months and we had the challenges that we have with the health department and us dealing with many, many issues, I took the decision to send in General Frewen and changed the way we did it and set up a change in the command structure, how logistics were managed, how it was planned, and it worked. But I wish we’d done that earlier, and that’s a lesson.

3.8 The Prime Minister’s comments suggest that the vaccine rollout governance arrangements that existed prior to the establishment of Operation COVID Shield were not considered fit for purpose.

3.9 In his letter of appointment in June 2021 to the Coordinator General, the Prime Minister said:

As Co-ordinator General, you will have direct operational control of all relevant assets and resources across all Commonwealth government departments and agencies engaged in the direction and implementation of the national COVID vaccination program. Among other things, you will be responsible for communication around the vaccine rollout, engagement with states and territories, distribution and delivery of vaccines, engagement with health providers including hospitals, GPs, Aboriginal Health Services and pharmacies, and engagement with key community stakeholders, business groups, and unions.

In performing these functions, you will be responsible directly to me and the Minister for Health. Accordingly, communications should be jointly addressed to both of us and coordination should occur with both of our offices simultaneously.

3.10 In terms of governance arrangements within Health, the Prime Minister also asked that the Coordinator General ‘work closely with both the Secretary of the Department of Health, Dr Brendan Murphy, and Australian Public Service Commissioner, Peter Woolcott AO, to ensure that you have the support you require’.⁸¹

3.11 The Coordinator General was supported by a taskforce which became known as the National COVID Vaccine Taskforce. Health advised the ANAO that the majority of staff were drawn from the previous taskforce. In discussion with the ANAO, the Coordinator General stated that he engaged with the ‘key players’ in Health to understand how the rollout was working and then developed the command structure he wanted. This is shown at Figure 3.2.

Figure 3.2: Operation COVID Shield organisation and governance chart after June 2021

Note: Light blue denotes decision-making; dark blue denotes advisory and green and orange denote working teams.

Note a: The Deputy Coordinator General was an SES Band 3 (Deputy Secretary) level officer who holds the necessary delegations from the Secretary of Health for financial approvals under the Public Governance, Performance and Accountability Act 2013 (PGPA Act).

Source: Health.

3.12 The Coordinator General retained a workstream structure. The revised workstreams were broadly similar in terms of responsibilities to workstreams in place before June 2021. Some workstreams were added to reflect the status of the rollout in June 2021 and others were added specifically relating to priority groups. In total, there were 19 workstreams grouped into three ‘themes’:

• coordinate: to develop the framework and governance for a coordinated approach between the Australian Government, jurisdictions and the private sector;
• motivate: to shape positive public sentiment and drive public action via targeted communications and incentives; and
• deliver: to establish the capacity to build on existing vaccination efforts with additional channels and ‘points of presence’, and ‘dynamic reallocation’ of supply across channels, to drive a ‘step up’ in vaccination supported by progressively increased supply.

3.13 The relationship between themes, workstreams and responsibilities is shown in Table 3.2.

Table 3.2: Operation COVID Shield: workstream assignment of responsibilities as at September 2021

Source: Health.

3.14 The number of workstreams increased markedly from seven shown in Table 3.1 to 19 shown in Table 3.2. There was a concomitant significant increase in the number of Senior Executive Service officers overseeing the rollout as shown in Table 3.3.

Table 3.3: Health taskforce and Operation COVID Shield: senior staffing

Note a: In the Taskforce, the Senior Responsible Officer was the department’s Associate Secretary who retired just prior to the establishment of Operation COVID Shield.

Note b: In Operation COVID Shield, the Coordinator General was a Lieutenant General which is approximately equivalent to an SES Band 3. As noted in Figure 3.2, the Deputy Coordinator General was also an SES Band 3 officer.

Note c: In the Taskforce, the SES Band 2 officer was the Program Director.

Note d: In Operation COVID Shield, the SES Band 2 officers comprised the ‘COVID-19 Vaccine Program Executive Leadership’.

Note e: Workstreams were headed by SES Band 1 officers. The number of officers does not match the number of workstreams because some officers were responsible for more than one workstream.

Source: ANAO from Health documents.

Australian, state and territory government governance

3.15 Due to the need for effective coordination between the Australian Government and state and territory governments, the peak governance mechanism for the rollout was the national cabinet, which had been established in March 2020, replacing the former Council of Australian Governments.

3.16 To support the implementation of the rollout there were a number of key coordination or engagement bodies comprising senior representatives of the Australian, state and territory governments. These are listed in Table 3.4.

Table 3.4: Key Australian and state and territory government coordination or engagement bodies

Note a: The Vaccine Operations Centre (VOC), located in Health, coordinated Australian and state and territory government efforts to manage the rollout. It also liaised with manufacturers and logistics providers and monitored vaccine distribution.

Note b: The National Centre for Immunisation Research and Surveillance (NCIRS) was established by Health in August 1997. Its purpose is to lead and support collaborative research and to advance immunisation policy and practice.

Source: Health.

Roles and responsibilities

3.17 The high-level responsibilities of the Australian, state and territory governments were set out in the Australian COVID-19 vaccination policy (the vaccination policy), which was published on 13 November 2020 (see Table 3.5). These responsibilities were also stated in the respective Jurisdictional Implementation Plans (see paragraph 2.11).

Table 3.5: Australian COVID-19 vaccination policy: Australian, state and territory government responsibilities

Source: Department of Health, Australian COVID-19 vaccination policy, 13 November 2020, available from https://www.health.gov.au/resources/publications/covid-19-vaccination-australian-covid-19-vaccination-policy [accessed 20 April 2022].

3.18 The vaccine policy also identified shared responsibilities for specific priority groups in the following terms:

In addition, the Australian, State and Territory governments will work together to ensure that the needs of the following groups are met: residential aged care and residential disability settings; Aboriginal and Torres Strait Islander people; culturally and linguistically diverse communities; and vulnerable groups. This will be done in consultation with relevant stakeholders including the Aboriginal and Torres Strait Islander Community Controlled Health Organisations (ACCHOs). The Australian, State and Territory governments will also work together to ensure doses of vaccine are distributed to where they are most needed, based on live information on need and uptake at vaccination locations.⁸²

3.19 Further detail about shared responsibilities of the Australian Government, state and territory governments and relevant non-government stakeholders were subsequently included in the Jurisdictional Implementation Plans (discussed at paragraph 2.8) and the sector-specific implementation plans (discussed at paragraph 2.22).

Were effective arrangements in place for monitoring and reporting progress on the vaccine rollout?

3.20 The November 2020 vaccination policy noted that the ‘effective and efficient roll-out of COVID-19 vaccine(s) will require significant coordinated data and reporting mechanisms’ to track the progress of the rollout. Health advised that it did not establish a framework to monitor and report on the progress of the vaccine rollout and that reporting developed as the rollout progressed.

Systems and data

3.21 Health used a number of key systems to manage and monitor the vaccine rollout.

• Australian Immunisation Register (AIR) — an existing database which records vaccinations. Only recognised vaccination providers⁸³ can input data to the AIR and a small number of fields are recorded.⁸⁴ Services Australia manages the AIR under a program agreement with Health.⁸⁵
• Vaccine Administration System (VAS) — an existing system used to order vaccines for the National Immunisation Program. VAS required manual input and was used to order and track the number of vaccines delivered through in-reach vaccine administration in the residential aged care and residential disability sectors.
• COVID-19 Vaccine Administration System (CVAS) — a new system that Health brought online on 8 March 2021 to manage the ordering, allocation, delivery and receipt of COVID-19 vaccines and record any wastage.
• Vaccine Data Solution (VDS) — a new system that Health brought online on 15 February 2021 to collate data from the above systems to produce reports on vaccine deliveries and immunisations.

3.22 These systems were configured to share data to provide reporting on the entirety of the vaccine rollout (see Figure 3.3).

Figure 3.3: COVID-19 vaccine rollout data and system flow

Source: ANAO analysis of Health documents.

Systems assurance

3.23 Health has outsourced the data collection and IT management for systems used in the vaccine rollout to other parties, including:

• Services Australia (AIR);
• Salesforce (VAS and CVAS);
• Accenture (reporting dashboards); and
• Amazon Web Services (CVAS).

3.24 Health is responsible under various Acts⁸⁶ for the confidentiality, privacy and security of the data collected using these systems and cannot outsource these responsibilities. Health does not have assurance that third parties have IT controls in place to ensure the confidentiality, integrity and availability of data.⁸⁷ Health relies on point of time assessments, contractual obligations and management statements from entities. These are not sufficient to demonstrate that IT controls have been implemented and were operating effectively over the vaccine rollout. This increases the risk that third party providers do not have appropriate IT controls in place over the security of this data. The ANAO did not assess the IT controls of the third parties.⁸⁸

Availability of data

3.27 The data that Health has used to monitor the progress of the vaccine rollout has increased over time. However, there have been gaps in the data relating to the vaccination status of some priority and target groups (see paragraph 3.30 for more detail).

• Health did not have accurate data on the vaccination rate of critical and high-risk workers, which were a priority group under Phase 1a of the vaccine rollout, as occupation data was not collected in the AIR.
• In July 2021 the Australian Government mandated residential aged care facilities report the vaccination status of their residents and workers and created a new dataset to address a gap in monitoring.⁸⁹

Accuracy of data

3.28 Auditor-General Report No.5 of 2021–22 Improving Immunisation Coverage found:

Health does not gain assurance about the quality of the data it uses for monitoring and reporting immunisation coverage and has not clarified responsibility for data quality [in the AIR].

3.29 Health has not formally reviewed the data entered into any of the systems listed in paragraph 3.21. This has resulted in undetected and undisclosed inaccuracies in the data, particularly in the AIR and CVAS systems which are distributed systems and require manual input from many users.⁹⁰

3.30 The most recent National Centre for Immunisation Research and Surveillance study on AIR data in 2018 identified an error rate of 14 per cent.⁹¹ In February 2021, prior to the vaccine rollout commencing, the Australian Government mandated that all COVID-19 vaccinations be reported in the AIR to improve the completeness of the data.⁹² While this may have improved the error rate, there is no evidence available to support this.

3.31 Despite known inaccuracies in the collection of data, Health has used the available data as the most reliable data source for planning and supporting the vaccine rollout. In its use of this data, Health has identified anomalies and rectified these through its providers. However, Health has not quantified the inaccuracies in its internal or external data processes in the period examined.

Other monitoring activities

3.32 Health advised the ANAO that all levels of the vaccine rollout were monitored and that it developed dashboards and reports for some operational areas to identify and action issues. For example, the residential aged care branch developed a dashboard to generate reporting. Health also used this dashboard to monitor vaccination rates of aged care workers and target corrective action at facilities or companies with low vaccination rates.

Reporting arrangements

Reporting to decision-makers

3.33 Health produced daily and weekly reports on the vaccine rollout for decision-makers, which addressed progress for all priority or targeted groups that Health was able to track (see paragraph 3.27 and Appendix 3).⁹³ Health also reported on the program management of the rollout, which included progress against milestones, such as on-boarding vaccine administration sites. Table 3.6 summarises the reports provided to decision makers in August 2021 when the vaccine rollout was at a peak time of activity.⁹⁴

Table 3.6: Number of regular reports on the progress of the vaccine rollout received by senior decision makers^a

Note a: Includes daily and weekly reports in August 2021.

Note b: Tailored reporting includes summary reports for specific audiences, such as the Prime Minister or Coordinator General of Operation COVID-19 Shield.

Source: ANAO analysis of Health documents and reporting.

3.34 Health frequently provided briefing for the Prime Minister and the Minister for Health and Aged Care. Between April 2020 and December 2021, Health provided 105 formal briefs related to the vaccine rollout to the Minister for Health and Aged Care and the Prime Minister. These formal briefs addressed issues requiring formal ministerial approval, such as requesting approval to request additional funding for vaccine advertising from the Prime Minister. The weekly program management report provided to the Minister for Health and Prime Minister also included the key risks to the rollout for the week and the status of key program milestones. For example, the 10 March 2021 report identified the slow rollout to residential aged care facilities as a key risk, and noted agreeing the contractual approach to VAS providers in residential disability settings was ‘at risk’.

3.35 Health’s reports on the vaccine rollout were often tailored to suit the specific audience. For example, Health provided a weekly update to the Prime Minister on the vaccine rollout, which was developed in April 2021 in response to feedback from the Prime Minister through his office, the Department of the Prime Minister and Cabinet and Health staff. As a result of feedback from these stakeholders, Health included additional data, and changed how some information was presented to better suit the intended audience.

Reporting against targets

3.36 As noted at paragraph 2.27, Health did not include high-level targets in its planning prior to June 2021. However, government ministers and senior officials made a number of public statements which committed to targets for the vaccine rollout. These targets included the Prime Minister’s statement on 7 January 2021 that he hoped that Australia would administer four million vaccines by the end of March 2021 and the Minister for Health and Aged Care’s statement on 5 November 2020 that all Australians who sought vaccination will be vaccinated within 2021 (see Appendix 4 for a list of the key public targets). Health did not clearly report against these targets to decision makers.

3.37 In August 2021, Health released the Op COVID SHIELD National COVID Vaccine Campaign Plan (the campaign plan), with the purpose to detail the mechanisms to achieve the vaccination targets in the National Plan to Transition Australia’s National COVID Response of 70 and 80 per cent double vaccinated.⁹⁵ Health also produced a number of sub-plans which included lower-level targets (discussed in paragraph 2.37).⁹⁶ From 10 August 2021, Health reported against these new targets in weekly reports to the Coordinator General and senior departmental officers. These reports were developed by an ‘assessments cell’ established by the Coordinator General in June 2021. Health made amendments to the rollout based on its progress against targets and issues identified during this process.

Public Reporting

3.38 Health also published regular data-focused updates on the vaccine rollout. This was guided by the Prime Minister’s commitment of 6 April 2021 to greater data transparency, the data available and public interest, and was consistent with the approach taken by other countries.⁹⁷ From 9 April 2021 the Australian Government published daily and weekly updates on the vaccine rollout on its website (see Figure 3.4).⁹⁸ The content included in these updates increased over time. This reporting did not assess progress against public targets for the vaccine rollout until 16 August 2021, when Health began reporting against the 70 and 80 per cent double vaccinated targets.

Was there fit-for-purpose stakeholder engagement?

Stakeholder engagement arrangements

3.39 Health identified that the COVID-19 vaccine rollout, as one of the largest national vaccination programs in Australia’s history, ‘has a stakeholder ecosystem that spans millions of Australians, thousands of external stakeholder groups and dozens of government bodies’. The time critical nature of the rollout meant that clear stakeholder governance was required to ensure resources were utilised effectively and stakeholders were engaged in a timely and appropriate manner.

3.40 In February 2021 Health documented its planned approach to stakeholder engagement, which included identifying stakeholders and establishing a clear stakeholder governance framework to support engagement effort.⁹⁹

3.41 Health identified stakeholders according to their needs, their influence on the program and the impact of the program on them. A broad range of stakeholders from government, medical and scientific fields, industry, and the community sectors were considered, categorised and prioritised (see Figure 3.5).

3.42 In addition to the stakeholders identified in Figure 3.5, Health also identified a range of state and territory engagement forums and primary care engagement forums (some of which, such as the Health CEOs/CHOs group, are mentioned in Table 3.4).

3.43 Of particular relevance for rollout governance were four advisory groups that were identified as key stakeholders for the vaccine rollout (the roles and membership of the four advisory groups are outlined in Table 3.7). These groups were established between March and October 2020 to provide advice and feedback to Health as part of the ongoing national response to COVID-19.

Table 3.7: Sector-specific advisory groups

Note a: The list of representatives in the table is not exhaustive but included to provide examples of the range of expertise.

Note: Working groups were established as a sub-committee of sector-specific advisory groups to focus on parts of the vaccine rollout. For example, the CALD advisory group established a vaccine working group and a communication working group.

Source: ANAO analysis of Health documentation.

3.44 Each advisory group was chaired by a senior officer from Health.¹⁰⁰ Terms of reference were established for each group, including details about the group’s role, membership and areas of expertise, regularity of meetings, meeting protocols, and related committees (as relevant).¹⁰¹

3.45 Meetings were held regularly during 2021, varying from monthly to several times a week as needed. During 2021, a total of 138 meetings were held across the four advisory groups, with the Aboriginal and Torres Strait Islander advisory group, for example, holding 51 meetings during 2021. The ANAO established that records were kept for meetings. Key meeting documents included agendas, meeting outcomes or minutes and communiques.

3.46 Health received advice from the advisory groups when planning the vaccine rollout. For example, in January 2021, advice on communication strategies was provided to Health by the aged care advisory group. In February 2021, the Aboriginal and Torres Strait Islander advisory group considered a paper on barriers and Aboriginal and Torres Strait Islander people’s concerns about vaccination. The advisory groups continued to provide advice to Health throughout the rollout, assisting Health to respond to issues in a timely manner.

ANAO requests to key stakeholders for feedback

3.47 In October 2021, the ANAO wrote to 38 organisations and individuals seeking their feedback on the rollout, including:

• representatives of advisory groups¹⁰²;
• all state and territory health departments;
• Primary Health Networks in each state and territory;
• major health peak bodies; and
• logistics providers.

3.48 Twenty-two responses were received, providing mixed feedback on the rollout overall.

• For example, one of the major peak bodies stated:

Australia’s vaccine rollout has not been perfect, but in general the [peak body] feels that the campaign was well planned and implemented — recognising that Australia was competing with the rest of the world for vaccines in what have been extraordinary times.

• By contrast, another stakeholder stated:

serious deficiencies have emerged in relation to the planning and execution of the COVID-19 vaccine rollout for people with disability in Australia.

3.49 It was clear from the feedback that many stakeholders had views about improvements that could be made and lessons that could be learned from the rollout in the event that another rollout becomes necessary in the future.

3.50 During the audit, Health drafted a document entitled Catalogue – learnings from the Covid vaccination rollout. The document was dated December 2021, was in draft form and stated:

it is also important to capture what our stakeholders learnt from the vaccination activities which were rolled out into the States and Territories. On-the-field experience is valuable and should be documented so if similar interventions were required in the future, they could be rolled out quickly and be more effective.

3.51 Although the document foreshadowed a publication date of 31 March 2022, Health advised on 22 March 2022 that it ‘is only an early draft, which was not progressed further. The Program Delivery Office has a lessons learned log as part of the management of the Program, this log will not be finalised until the program is closed’.

3.52 In May 2022, Health advised that it had commenced a Post Operations Review to consider the effectiveness of the vaccine rollout. The value of such a review is enhanced if it is broadly based. Health’s Stakeholder Engagement Framework states that Health is:

Committed to two-way open communication that involves listening to our stakeholders, keeping them informed and being clear about how their contributions are being used.

3.53 The framework also says that Health will ‘identify and enable the participation of those people and organisations who contribute to, influence, or are affected by our work.’

3.54 Given the range of comments that stakeholders contacted by the ANAO expressed about the rollout, the ANAO considers that it is critical that they be afforded the opportunity to be involved in a review of the rollout and that and that such an exercise be undertaken without delay, while lessons are fresh in people’s minds.

4.1 Vaccines are an important tool to reduce the risk from severe illness and death as a result of COVID-19, and were a key part of the Australian Government’s plan to minimise illness and fatalities while removing COVID-19 restrictions as set out in the National Plan to Transition Australia’s National COVID-19 Response released on 2 July 2021. On 31 January 2021, prior to the commencement of Australia’s vaccine rollout on 22 February 2021, the Minister for Health and Aged Care stated that ‘we aim to have the country vaccinated before the end of October’.¹⁰⁴

4.2 Rapid implementation will generally require entities to draw on the full range of human, physical and ICT resources available to them, and may involve entities looking externally for relevant resources. Misalignment between resources and needs at the rollout stage creates a significant risk to the delivery of expected outcomes in the required time period. This chapter examines whether Health effectively: implemented vaccine logistics arrangements and administration channels to administer vaccines to the Australian population; administered vaccines to targeted populations as planned; and communicated information on the vaccine rollout.

Have the logistics and administration channels been effective in vaccinating the Australian population?

Logistics

4.3 The Australian Government has been responsible for the transport of vaccines and related consumables to storage and administration sites within each state and territory.¹⁰⁵

4.4 As discussed in paragraph 2.56, Health engaged DHL and Linfox in February 2021 as the logistics providers for the vaccine rollout.¹⁰⁶ Both logistics providers self-reported that they consistently delivered more than 99 per cent of vaccines and consumables within the timeframes set by Health. Health advised that it agreed with the logistics providers’ self-assessments in the period examined.

4.5 Health advised the ANAO that it monitored the timeliness and wastage levels of logistics providers during the vaccine rollout and used this information to resolve issues (vaccine wastage is discussed in paragraphs 4.15 and 4.16). In March 2021 Health identified issues with one of the logistics providers relating to delivery delays, cold chain breaches and poor responsiveness to Health’s requests. In response, Health reduced the deliveries allocated to the provider until it gave evidence it had addressed the identified issues.¹⁰⁷

Distribution of vaccine stock

4.6 In early 2021, Health had limited vaccine supply and did not have precise forecasts on when supply would arrive.¹⁰⁸ Figure 4.1 shows Health delivered vaccines to administration sites in a timely manner once they became available. Not all doses received by Health were immediately delivered. Health held some vaccines in contingency to ensure it could provide second doses if there were supply shocks. The number of vaccines held in contingency varied over time. The initial contingency with the Pfizer vaccine was calculated as the amount required for second doses.

Figure 4.1: Cumulative vaccine supply received by Health compared to vaccines delivered to administration sites

Note: Vaccine supply refers to deliveries of vaccines received by Health from both international and domestic manufacturers.

Source: ANAO analysis of Health documents.

Administration channels

4.7 Once vaccines were received by the Australian Government, Health administered vaccines through a variety of vaccine administration channels. Some administration channels were used to target priority groups and others were aimed at the general population (see Table 2.7). All administration channels other than state and territory clinics were managed by Health.¹⁰⁹ To support the safe administration of vaccines, all administration channels had to meet the site requirements for COVID-19 vaccination clinics developed by Australian Technical Advisory Group on Immunisation (ATAGI).¹¹⁰

4.8 As the rollout progressed and more people became eligible, additional administration channels were brought online. Health advised that as at 31 December 2021, there were 10,154 active vaccine administration providers.¹¹¹ Figure 4.2 shows that the majority (60 per cent) of vaccines were administered by Australian Government channels. This was mainly through primary care administration channels.

Figure 4.2: Monthly vaccines administered by Australian Government and state and territory administration channels in 2021

Note: Australian Government administration channels include general practitioners, community pharmacists, Aboriginal Community Controlled Health Organisations, Commonwealth Vaccination Clinics, in-reach and the Royal Flying Doctor Service.
The data used to develop this and other figures in this chapter was largely derived from Health’s systems and subject to data quality issues raised in paragraphs 3.29 and 3.30. The ANAO does not have assurance on the completeness and accuracy of this data. This was the best data available during the vaccine rollout and was used by Health to make decisions. Therefore, the ANAO has used this to assess the effectiveness of the rollout. The ANAO confirmed that Health’s processes to extract data from its systems to provide to the ANAO were appropriate. Health updated this data retrospectively where required and as a result the figures used by ANAO may vary from Health’s reporting.

Source: ANAO analysis of Health data.

Primary care

4.9 Primary care includes general practitioners (GPs), community pharmacies, Aboriginal Community Controlled Health Organisations (ACCHOs) and Commonwealth Vaccination Clinics (CVCs). Fifty-seven per cent of vaccines were administered by primary care channels in 2021.

4.10 Health brought primary care sites online in a staggered approach, beginning with CVCs and ACCHOs to improve access in remote and regional areas. Potential GP and pharmacy sites were identified through multiple opt-in expression of interest processes.¹¹² Sites were on-boarded in a phased approach based on readiness, the density of priority populations in the area, and geographic coverage.

4.11 The vaccine rollout released public messages early, which was consistent with the Australian Government’s strategy for the COVID-19 response (the communication of the vaccine rollout is discussed in paragraphs 4.66 to 4.76). The Prime Minister frequently addressed the media to announce policy changes shortly after decisions were made in meetings with state and territory leaders. As a result, some policy changes relating to the vaccine rollout were announced publicly before they were communicated to operational staff and key stakeholders. Stakeholders in the primary care sector advised the ANAO that coordination bodies and individual primary health administrators were not always prepared to implement the changes or respond to patients’ questions. Primary care stakeholders advised this reduced public trust and created other difficulties for administration providers.¹¹³

In-reach services

4.12 Health ran in-reach vaccination clinics for residential aged care facilities and residential disability facilities from February 2021, which accounted for three per cent of vaccines administered.¹¹⁴ As discussed in paragraphs 2.52 to 2.55, the in-reach administration channel primarily used contracted Vaccine Administration Service (VAS) providers who travelled to facilities to administer vaccines to recipients. Health advised that from August 2021, primary care providers were also able to provide in-reach vaccinations.

4.13 During in-reach visits, residents were vaccinated first and, if there were any vaccines remaining, they could be offered to staff and any other people on site (such as family of residents) to minimise wastage.¹¹⁵ Residential aged care facilities (RACFs) and residential disability facility in-reach clinics were scheduled based on geographic and logistics considerations such as cold chain requirements. In-reach vaccination clinics primarily used Pfizer as Health wanted VAS providers to only use one vaccine.¹¹⁶

Other administration channels

4.14 The Australian Government established additional vaccine channels to improve access to vaccines, increase uptake and target priority groups. These channels administered less than one per cent of doses in the vaccine rollout and included:

• a workplace vaccination program (Health established a pool of immunisation providers able to provide on-premise vaccination at workplaces, which workplaces could choose to engage);
• in-reach clinics for remote and very remote communities through the Royal Flying Doctor Service; and
• priority group specific vaccination hubs (Health established hubs for aged care and residential disability care workers, and other essential workers to increase vaccine uptake).

Vaccine wastage

4.15 The World Health Organisation (WHO) defines vaccine wastage as ‘the sum of vaccines discarded, lost, damaged or destroyed.’¹¹⁷ The WHO states that 15 per cent is an acceptable indicative wastage rate for multi-dose vials as part of a vaccine campaign.¹¹⁸ Noting Australia’s well-developed infrastructure for administering vaccines, the ANAO used the National Immunisation Program’s (NIP’s) acceptable wastage rate of 10 per cent for new vaccines as a guide. Table 4.1 shows that the highest cumulative rate of vaccine wastage during 2021 was within the NIP’s 10 per cent acceptable wastage rate (9.2 per cent). Table 4.1 also shows that in late 2021, as vaccine supply increased and demand decreased, the rate of vaccine wastage also increased.

4.16 In addition to its indicative wastage rate for multidose vials, the WHO recommends a maximum acceptable wastage of one per cent for unopened vials. This unopened vial wastage often occurs in the transport or storage of vaccines. The wastage rate for logistics (0.04 per cent) was below the WHO’s acceptable wastage rate for unopened vials. This was likely impacted by the strict processes Health required logistics providers to comply with to ensure vaccines were stored within the required temperature ranges to minimise wastage.¹¹⁹

Allocation of vaccines across jurisdictions

4.17 To provide equitable access to vaccines for all states and territories, the Australian COVID-19 Vaccination Policy (the vaccination policy) stated that the Australian Government would allocate vaccines based on the proportion of the eligible population in the state or territory and vaccine supply. The vaccination policy also noted additional doses could be allocated to address COVID-19 outbreaks.¹²⁰

4.18 Health advised the ANAO that it determined weekly allocations to states and territories based on the proportionality principle outlined in the vaccination policy and that it used the population proportions in Table 4.2.

Table 4.2: Proportion of Australian population in states and territories used to determine COVID-19 vaccine allocations

Note a: These proportions were calculated on Australian Bureau of Statistics (ABS) data. Health advised it originally used 2020 ABS data and updated this to the 2021 data used in this table once released in September 2021.

Source: Health and ABS.

4.19 As there were no supply constraints for AstraZeneca from April 2021, Health advised the ANAO that it focussed on assessing the proportionality of allocations of mRNA vaccines (Pfizer and Moderna) from this point on. Figure 4.3 shows that cumulative allocations of mRNA vaccines were initially not proportional to population. However, from September to November 2021, as the supply of mRNA vaccines increased, Health rebalanced cumulative allocations to within 0.6 percentage points of each jurisdiction’s proportion of the Australian population.¹²¹ Health advised the ANAO that the deviations from population proportions in the earlier stages of the rollout (to September 2021) were due to differences in the proportion of priority populations relative to total population in each jurisdiction¹²², logistical constraints¹²³ and the occurrence of outbreaks.

Figure 4.3: Percentage point difference between proportion of population and proportion of cumulative mRNA vaccines allocated to states and territories

Source: ANAO analysis of Health data.

4.20 During the rollout, Health established processes to allocate additional vaccines to address issues, such as COVID-19 hotspots¹²⁴, and maximise the use of available vaccines. These processes are summarised in Table 4.3.

Table 4.3: Vaccine allocation processes used in addition to the per capita allocations

Note a: This was particularly used for AstraZeneca vaccines, which were consistently under-ordered from mid-May 2021.

Note b: Health did not approve all requests for early access to vaccines made by the states and territories.

Note c: Additional vaccines secured refers to vaccines secured in addition to purchase agreements with vaccine manufactures. In 2021 the Australian Government purchased or arranged vaccine swap arrangements with the Republic of Poland, Singapore and the United Kingdom.

Note d: Health communicated these processes, excluding securing additional doses, to the states and territories.

Source: ANAO analysis of Health documents.

Responding to COVID-19 outbreaks

4.21 The Australian Government used the allocation processes described in Table 4.3 to help control COVID-19 outbreaks. State and territory governments were able to request additional doses (outside of the agreed weekly allocation) in response to increasing COVID-19 cases from May 2021. Health established a process to assess these requests based on the need, timeframe for delivery, and impact on future vaccine stock levels if approved.

4.22 Health advised the ANAO that from May 2021, additional doses of AstraZeneca and Pfizer vaccines were formally requested on 12 occasions by four states and territories experiencing COVID-19 community transmission.

• Victoria requested additional doses on five occasions from May 2021.¹²⁵ Three of the requests were for additional AstraZeneca doses (185,000 in total), and two requests were for additional Pfizer doses (106,990 in total). Health advised the ANAO that all of the requests were approved, and the Pfizer doses were approved using the ‘bringing forward’ process. The AstraZeneca doses were provided from existing stock as supply was not restricted.
• New South Wales requested additional doses on four occasions from June 2021.¹²⁶ Three of the four requests (ranging from 183,690 to 500,000 doses per request) were approved by Health. One request (made on 2 July 2021) was rejected due to a lack of vaccine Pfizer supply (additional Pfizer doses not being available on top of what had already been allocated). Health advised the ANAO that the additional vaccine doses were provided using the ‘bringing forward’ process. The AstraZeneca doses were provided from existing stock as supply was not restricted.
• Queensland requested additional Pfizer doses on two occasions in July and August 2021.¹²⁷ Health advised the ANAO that both requests were approved, and the doses were provided using the ‘bringing forward’ process.
• Australian Capital Territory requested additional Pfizer doses on one occasion in August 2021.¹²⁸ Health advised the ANAO that the request was approved, and the doses were provided using the ‘bringing forward’ process.

4.23 The ANAO requested that Health provide documentation to support these processes. However, Health could not provide complete records, including evidence of requests, assessments, responses, and repayment of doses provided using the ‘bringing forward’ process. Consequently, the ANAO could not provide assurance that all requests for additional doses to respond to outbreaks were considered and approved using consistent processes.

4.24 In addition to the ‘bringing forward’ process, on 15 August 2021, the Prime Minister announced that the Australian Government had purchased an additional 1,000,350 Pfizer doses from the Republic of Poland.¹²⁹ Of these doses, 530,010 were prioritised to New South Wales areas with high COVID-19 numbers.¹³⁰ The decision to prioritise News South Wales, by allocating it 53 per cent of the additional doses, was made by the Prime Minister based on advice from the Chief Medical Officer.

Vaccine administration outcomes

International benchmarks for the vaccine rollout

4.25 The Australian Government began the vaccine rollout on 22 February 2021. This met the target in the Minister for Health and Aged Care’s media release of 5 November 2020, that the rollout would begin in the first quarter of 2021, and later targets for the rollout to begin in either March or late February (see Appendix 4 for a list of key government targets for the vaccine rollout). As shown in Figure 4.4, Australia’s vaccine rollout began later than other countries such as the United Kingdom and the United States.

Figure 4.4: International comparison of percentage of population fully vaccinated since the vaccine rollout began

Note: The population fully vaccinated is based on public reporting and can vary between countries if this is the proportion of the total population or eligible population. For Australia this is the proportion of the population 12 years and over.
The international benchmarks were selected to provide a variety of geographic regions, number of COVID-19 cases, and populations, with at least one country comparable to Australia in each category.

Source: ANAO analysis of Health data and international data from Our World in Data, Coronavirus (COVID-19) Vaccinations [Internet], Global Change Data Lab, available from https://ourworldindata.org/covid-vaccinations [accessed 15 April 2022].

4.26 Figure 4.5 shows Australia’s vaccine rollout followed a similar trend to other countries with relatively low COVID-19 case numbers (New Zealand and Thailand) in the first four months of their respective vaccine rollouts.

Figure 4.5: International comparison of percentage of population fully vaccinated since first vaccine administered

Note: Month one since first vaccine administered for the United States, United Kingdom, Canada and Singapore was January 2021. For Australia, New Zealand and Thailand this was March 2021. Month 10 since the rollout began for Australia was 31 December 2021.
The milestone of the population being fully vaccinated is based on public reporting and can vary between countries, including if this is the proportion of the total population or eligible population. For Australia this is the proportion of the population 12 years and over.

Source: ANAO analysis of Health data and international vaccination data from Our World in Data, Coronavirus (COVID-19) Vaccinations [Internet], Global Change Data Lab, available from https://ourworldindata.org/covid-vaccinations [accessed 15 April 2022].

Vaccine administration to the Australian public

4.27 The Australian Government set a number of targets for the vaccine rollout in 2021, which changed over time (see Appendix 4 for a list of the key public targets and ANAO’s assessment of whether Health achieved them). Table 4.4 shows that Health met three out the nine key public targets for the vaccine rollout to the Australian population.

Table 4.4: ANAO’s assessment of Health’s performance against key public targets for the vaccine rollout to the Australian population

Note a: The ANAO was unable to make an assessment whether all people who sought vaccination received a vaccine.

Source: ANAO analysis of Health data, transcripts and press releases by the Prime Minister, Minister for Health and Aged Care and Hansard records.

4.28 Figure 4.6 shows the Australian population reached 80 per cent double vaccinated in November 2021. As summarised in Table 4.4, this met the National Plan to Transition Australia’s National COVID Response target of 80 per cent of the Australian population double vaccinated, which was referenced in the August 2021 Op COVID SHIELD National COVID Vaccine Campaign Plan. However, this did not meet the Minister for Health and Aged Care’s target to ‘have the country vaccinated before the end of October’¹³¹, as was anticipated in the March 2021 Implementation Readiness Assessment (see paragraph 2.27).

Figure 4.6: Australian vaccination rate over 2021 for the population aged 12 and over

Note: The ANAO calculated the vaccination rate based on the eligible population at 31 December 2021, which included all people aged 12 years or over. Children aged 5 to 11 years were eligible to get vaccinated from 10 January 2021. Health assessed if it met this target using the vaccination rate of people aged 16 and over. The ANAO assessed 80 per cent of people aged 16 and above were doubled vaccinated on 2 November 2021.
The ANAO calculated vaccination rates using 2021 ABS data on the Australian population as at June 2021. This was used to calculate vaccination rates for all figures unless otherwise stated.

Source: ANAO analysis of Health and ABS data.

4.29 Figure 4.6 also shows the beginning of the vaccine booster program in November 2021, which has continued into 2022. As at 28 March 2022, 68 per cent of eligible Australians had received a vaccine booster dose.

Was the implementation of the vaccine rollout to priority groups effective?

4.30 The vaccination policy stated that the vaccine rollout should provide equitable protection from COVID-19 for all people living in Australia.¹³² As discussed in paragraph 2.15, the COVID-19 National Vaccine Rollout Strategy (the vaccine rollout strategy) set out prioritised access to vaccines based on risk of transmission and adverse effects. This section assesses the effectiveness of the vaccine rollout to priority groups.

4.31 As discussed in paragraph 3.36, the Australian Government set a number of targets for the vaccine rollout, including for some priority groups (see Appendix 4 for a list of key targets). Table 4.5 shows Health did not meet any of the five key public targets it set for the vaccine rollout to priority groups.

Table 4.5: ANAO’s assessment of Health’s performance against key public targets for the vaccine rollout to priority groups

Note a: The ANAO was unable to make an assessment on this due to the lack of data on the cohort.

Source: ANAO analysis of Health data, transcripts and press releases by the Prime Minister, Minister for Health and Aged Care and Hansard records.

Phase 1a priority groups

Priority occupation groups

4.32 Health administered vaccines consistent with the prioritisation in the vaccine rollout strategy discussed in paragraph 2.15 and Table 2.2. States and territories led the administration of vaccines to quarantine, border, and frontline healthcare workers eligible under Phase 1a and monitored the progress of this. Critical and high-risk workers were serviced through both primary care, state and territory clinics, and in occupation-specific sites. Health did not have accurate data on the vaccination rates of these groups.¹³³

Residential aged care facility residents

4.33 Health administered vaccines to residents of residential aged care facilities (RACFs) principally through in-reach vaccinations (see paragraph 4.12). Health committed to providing first and second dose clinics for 2,573 eligible RACFs¹³⁴, which contained approximately 186,350 residents. Health also ran ‘roving’ clinics for residents who were previously unable to be vaccinated or had chosen not to, and, from 8 November 2021, booster clinics.

4.34 The Minister for Health and Aged Care stated in a media release on 16 February 2021 that he anticipated the vaccine rollout to RACF residents would take approximately six weeks, indicating that this priority population would be completed by early April 2021. On 20 April 2021 Health stated it was confident the rollout to RACF residents would be completed in May 2021. Figure 4.7 shows second dose vaccine clinics for RACF residents were completed for 99 per cent of RACFs by June 2021.

Figure 4.7: Percentage of Residential Aged Care Facilities receiving in-reach first and second dose clinics for residents

Note: Of the 2,573 RACFs, Health did not record the date that first and second dose clinics were conducted for five. These were excluded from the total.

Source: ANAO analysis of Health data.

4.35 Health documents indicated the rollout of vaccines to RACFs was slower than planned for a number of reasons.

• There were delays in scheduling visits to RACF sites. Health’s reporting showed the VAS providers it contracted had difficulty scheduling visits and engaging with facilities, which caused confusion and uncertainty at some facilities.
• The Vaccine Administration System used by Health to order and register vaccinations required manual processes that caused delays and errors in the data.
• Health contracted a limited workforce of the VAS providers (which were also contracted to deliver the residential disability rollout).
• One VAS provider contracted by Health early in the rollout underperformed. This poor performance included governance and logistics issues resulting in cancellations of clinics at short notice.

4.36 As the rollout progressed, Health improved governance and reporting processes for the RACF rollout. For example, in March 2021 Health established processes for Primary Health Networks (PHNs)¹³⁵ to engage with RACFs to identify residents who were not vaccinated during in-reach clinics and connect them with vaccine services. Health also worked with PHNs and VAS providers to improve coordination and to schedule roving clinics to improve vaccination rates.

4.37 As discussed in paragraph 2.53, Health expanded its contracts with existing VAS providers and engaged additional VAS providers in February, March and April 2021 to address the insufficient workforce from the providers it initially contracted.

4.38 By 10 January 2022, 87 per cent of residents in RACFs had received two doses of a COVID-19 vaccine, as a result of the in-reach visits shown in Figure 4.7.

Residential aged care facility workers

4.39 Health made a decision in February 2021 to vaccinate aged care staff separately from residents due to lessons learnt from international vaccine rollouts.¹³⁶

4.40 From 15 June 2021, residential aged care providers were required to report on the vaccination status of their workers; and all residential aged care workers were required to receive at least a first dose of a COVID-19 vaccine by 17 September 2021.¹³⁷ Further, to encourage workers to get vaccinated, in July 2021 Health established a grant program to compensate workers for travel costs and lost shifts.¹³⁸ On 17 September 2021 the Minister for Health and Aged Care reported in a media release that 76.9 per cent of residential aged care workers were double vaccinated (this compared to 44 per cent of the Australian population). Health advised that as at 11 May 2022, 98.9 per cent of residential aged care facility workers were double vaccinated.

Residential disability facility residents and staff

4.41 The rollout to the residential disability sector began on 22 February 2021. As with the aged care cohort, Health also offered a first and a second dose in-reach vaccination clinic for residential disability facility residents and staff.¹³⁹ Residential disability facilities included both recipients of National Disability Insurance Scheme (NDIS) support and non-NDIS recipients, as not all people with a disability receive NDIS support.¹⁴⁰

4.42 On 20 April 2021 the Secretary of Health advised the Senate Select Committee on COVID-19 that Health aimed to have vaccinated vulnerable people, including residential disability residents, by the middle of 2021. By 20 September 2021 Health had held second dose clinics at 71 per cent of residential disability sites, compared to 100 per cent of residential aged care facilities.¹⁴¹ The vaccination rate of NDIS residential disability residents did not reach 80 per cent double vaccinated until 9 November 2021 (see Figure 4.8).¹⁴² This was approximately the same time as the Australian population aged 16 years and over (2 November 2021), even though residential disability workers and residents were eligible to get vaccinated six months earlier than the majority of Australians aged 16 years and over.

Figure 4.8: Vaccination rate of NDIS recipients aged 16 and above living in residential disability facilities between May and December 2021

Note: Analysis based on regular reports between 25 May and 23 December 2021. The vaccination rate was calculated based on the total number of NDIS recipients in residential accommodation on 17 October 2021.
Data matching between the AIR and National Disability Insurance Agency did not have a common unique identifier and could lead to false matches. Services Australia removed these as they were identified. New processes were also developed to improve data accuracy throughout the rollout. This can result in unexpected variations in the data.

Source: ANAO analysis of Health data.

4.43 As at 11 November 2021, 79 per cent of NDIS screened applicants to work with people with a disability¹⁴³ were double vaccinated. By 23 December 2021, 87 per cent of NDIS screened applicants were double vaccinated.

4.44 Health engaged with the National Disability Insurance Agency and Services Australia to access and improve data on the vaccination status of NDIS recipients (which represented a large proportion of the residential disability population). This improved Health’s ability to monitor the rollout in the residential disability sector. To administer vaccines safely, Health also required all VAS providers to complete training on managing residential disability facility residents’ concerns and behaviours.

4.45 Similar to the vaccine rollout to RACFs, Health documents indicated the rollout of vaccines to residential disability facility residents was slower than planned due to a number of issues.

• As discussed at paragraph 2.54, Health did not finalise operational planning and engage in-reach VAS providers until after the rollout started.
• As at 21 September 2021, there were 6,311 residential disability facilities with varying numbers of residents. These facilities could support residents with a broad spectrum of disabilities, including physical or developmental.¹⁴⁴ This made safely administering vaccines and obtaining valid consent difficult.
• The distributed nature of the sector and lack of complete and accurate data on the vaccination rate of residents and workers made it difficult to plan and monitor the rollout.¹⁴⁵
• Health initially engaged VAS providers with a limited workforce. As with the residential aged care rollout, this limited the number of sites that the VAS providers could visit.
• Health prioritised the deployment of contracted VAS providers to aged care facilities due to the higher risk of severe outcomes of COVID-19.¹⁴⁶ This delayed deployment to residential disability facilities.

4.46 Most of these issues were identified as risks during the joint planning process undertaken by Health in February 2021 with one of the VAS providers. However, they were not adequately addressed, which impacted the speed of the rollout of vaccines to residential disability facility residents.

4.47 Health did not engage sufficient VAS providers with sufficient capacity to deliver the in-reach administration channel early in vaccine rollout. Health advised that in the early stages of the vaccine rollout, the high demand for vaccine administrators created challenges for the operational readiness of the contracted VAS providers. As discussed in paragraph 2.53, Health engaged additional VAS providers later in the rollout to increase the number of in-reach clinics. Health also arranged additional in-reach visits by primary care (such as GPs) from August 2021 and established vaccination hubs for persons with a disability and residential disability workers from 3 May 2021.

4.48 On 21 September 2021, Health approved a Disability Phase 1a Rollout Plan to accelerate the residential disability rollout with the target to offer first and second dose clinics to all residential disability sites by 31 October 2021.¹⁴⁷ Health advised that it met this target on 2 November 2021. ¹⁴⁸Due to the poor quality of the data provided the ANAO was not able to make an independent assessment of this. This plan included a number of activities to encourage residents and staff to get vaccinated. For example, Health introduced a grant program for facilities to encourage them to transport residents to an out-of-home vaccination site and residential disability worker vaccination hubs. Health also redirected VAS providers from residential aged care to residential disability facilities to schedule additional in-reach clinics.

Phase 1b priority groups

Aboriginal and Torres Strait Islander people

4.49 Aboriginal and Torres Strait Islander people aged 50 and over were eligible to receive AstraZeneca from 22 April 2021 (unless they were eligible under a Phase 1a priority group category).¹⁴⁹ The balance of the Aboriginal and Torres Strait Islander population was eligible to receive a vaccine from 8 June 2021. Aboriginal and Torres Strait Islander people could access vaccines through Aboriginal Community Controlled Health Organisations (ACCHOs), which were engaged to provide localised and culturally safe vaccinations.¹⁵⁰

4.50 Figure 4.9 shows that the vaccination rate of Aboriginal and Torres Strait Islander people was consistently lower than that of the non-Indigenous Australian population throughout the rollout. In a media release on 14 September 2021, the Minister for Health and Aged Care stated that Health was ‘committed to seeing Aboriginal and Torres Strait Islander vaccination rates meet if not exceed the national target [of 80 per cent double vaccinated].’ Health did not reach this target in 2021. Seventy-two per cent of the eligible Aboriginal and Torres Strait Islander population was double vaccinated by 31 December 2021 compared to 97 per cent of the non-Indigenous Australian population.

Figure 4.9: Aboriginal and Torres Strait Islander and non-Indigenous vaccination rates for people aged 12 years and over in 2021

Note: The ANAO calculated Indigenous and non-Indigenous vaccination rates using the ABS’s 2021 population estimates based on 2016 census data. The ABS published data on age groups on five-year cohorts, including ages 10–14 years. The ANAO estimated the population of the 12–14 age group, was 60 per cent of the 10–14 year population group.

Source: ANAO analysis of Health data.

4.51 Health advised the ANAO that the lower vaccination rate was influenced by several factors including:

• the predominant use of AstraZeneca in regional and remote areas until May 2021 where 62.6 per cent of the Aboriginal and Torres Strait Islander population live (compared to 27.3 per cent of the non-Indigenous population)¹⁵¹ — the discovery in March 2021 of very rare but potentially fatal side effects of the AstraZeneca vaccine (discussed in paragraph 2.17) increased hesitancy for this vaccine;
• religious based hesitancy and misinformation targeted at Aboriginal and Torres Strait Islander people;
• a lack of urgency to get vaccinated — until August 2021, there had been no significant outbreaks and limited COVID-19 community transmission in Aboriginal and Torres Strait Islander communities, which contributed to complacency and no rush to get vaccinated; and
• delays in family decision-making — the Indigenous Governance Toolkit states ‘Decisions in Indigenous nations, communities or groups are usually made through extensive collective discussion and consultation.’¹⁵² Health advised the ANAO that the separation of Aboriginal and Torres Strait Islander people into age-based eligibilities made family decision-making more difficult and may have delayed vaccine uptake.

4.52 Health ran targeted communication activities for Aboriginal and Torres Strait Islander people with the intention of addressing vaccine hesitancy and increasing uptake (discussed further in paragraph 4.74). Health identified primary care sites to provide coverage in regional and remote areas, including those servicing Aboriginal and Torres Strait Islander communities. Health also prioritised ACCHOs to receive doses of Pfizer to provide an alternative for those hesitant to receive AstraZeneca.

4.53 From 14 September 2021, Health began targeted activities to accelerate the COVID-19 vaccine rollout for Aboriginal and Torres Strait Islander people in 30 priority areas through tailored vaccination channels and activities.¹⁵³ This included running home visits and pop-up clinics in the identified areas.¹⁵⁴ These targeted activities were in response to the low vaccination rate of Aboriginal and Torres Strait Islander people relative to the broader Australian population.

4.54 The gap in vaccination rates between Aboriginal and Torres Strait Islander people and the Australian public did not begin to decrease until December 2021 when the non-Indigenous vaccination rate plateaued. The vaccination gap between the populations was 33.8 per cent in November 2021 and 31.3 per cent in December 2021.

Non-residential disability

4.55 Adults with a disability who did not live in a residential disability facility were eligible to receive a vaccine in Phase 1b on 22 March 2021. All NDIS recipients aged 16 and over were eligible to receive a vaccine from 8 June 2021. Figure 4.10 shows that the vaccination rate for NDIS recipients remained lower than the rate for the broader Australian population, despite earlier eligibility to receive a vaccine.

Figure 4.10: Vaccination rate of all NDIS recipients aged 16 or over in 2021 compared to the Australian population

Note: Health accessed regular data on the number of National Disability Insurance Scheme recipients who are either single or double vaccinated from 25 May 2021.
The percentage of the Australian population fully vaccinated is based on the proportion of the population aged 16 years and over to align with the cohort for NDIS recipients in residential disability included in reports.

Source: ANAO analysis of Health documents.

4.56 People with disabilities may have a range of access or sensory requirements¹⁵⁵ for vaccination sites, such as wheelchair ramps. Health and the state and territory governments ran vaccination hubs designed for people with a disability and other priority groups to promote the safe uptake of vaccines. Health advised that the first Australian Government vaccination hub for people with a disability occurred on 4 May 2021.

4.57 On 15 October 2021, Health approved the Acceleration of Vaccination to NDIS participants and NDIS screened Workers Plan (the acceleration plan), which had a target of achieving 80 per cent ‘fully vaccinated’ by 31 October 2021. Health reached the acceleration plan’s target of 80 per cent of eligible NDIS recipients double vaccinated on 12 December 2021.

Age-based eligibility

4.58 The Australian Government prioritised the vaccination of people aged 70 and over (not in residential aged care facilities) as part of Phase 1b of the vaccine rollout¹⁵⁶, and people aged 50–69 years as part of Phase 2a of the vaccine rollout. In the April 2021 recalibration, Health introduced two additional cohorts in order to stagger eligibility — adding people aged 40–49 years within Phase 2a, and people aged 16–39 years within Phase 2b. Following TGA approval and ATAGI advice in July and August 2021, people aged 12–15 years were eligible to receive a vaccine from 13 September 2021. Age-based groups were serviced through vaccination channels available to the Australian public including primary care and state and territory clinics. There were no specific channels targeted to age cohorts. Health advised all age groups were able to access the eligibility checker and vaccine clinic finder to advise if they were eligible for receive a vaccine and, if so, where appointments were available.¹⁵⁷

4.59 Figure 4.11 shows older age groups were vaccinated earlier in the rollout consistent with their earlier eligibility.

Figure 4.11: Rate of double vaccination by age cohort in 2021

Note: People aged 50 years or older were eligible to receive AstraZeneca from 3 March 2021. All age groups could receive any vaccine from 30 September 2021.
People in an age group may have been eligible to receive a vaccine earlier as part of another priority group, such as border and quarantine workers.

Source: ANAO analysis of Health data.

Other targeted groups

Culturally and linguistically diverse communities

4.60 As discussed in paragraph 2.22, culturally and linguistically diverse (CALD) communities were not a priority group to receive a vaccine under the national vaccine rollout strategy. Health accessed population level data on the CALD rollout from the Multi-Agency Data Integration Program from June 2021.¹⁵⁸

4.61 In August 2021, people with a recorded measure of cultural and linguistic diversity¹⁵⁹ had a lower uptake for vaccination than the national average. As at 21 November 2021, 91 per cent of people aged 12 and over had received at least one vaccine dose. In comparison:

• 84 per cent of people born overseas (excluding the United Kingdom, Ireland or New Zealand) had received at least one dose;
• 83 per cent of people who speak a language other than English at home had received at least one dose; and
• 81 per cent of people with low English proficiency had received at least one dose.

4.62 Health shared information on the CALD vaccination rates with the CALD Communities Advisory Group (see Table 3.7), PHNs and the states and territories from 2 November 2021. Health also ran targeted communication activities to attempt to increase vaccination in CALD communities (discussed further in paragraph 4.74).

Regional and remote locations

4.63 Health relied on primary health channels to increase vaccine coverage in regional and remote locations.¹⁶⁰ Health engaged the Royal Flying Doctor Service to support locations with limited access to primary care and hospital vaccination sites, and to transport vaccines when required. Initially, the rollout in regional and remote locations used AstraZeneca because the ultra-cold transport and storage requirements of Pfizer made its use more difficult. However, publicity about the potential adverse side-effects of AstraZeneca led to vaccine hesitancy and reduced uptake. Consequently, on 19 April 2021 Health made all remote or very remote communities eligible to receive any vaccine to encourage uptake.

4.64 As vaccination rates increased across Australia, as at 31 December 2021, there were still a number of regional and remote areas with lower vaccination rates the Australian average. Factors influencing this included:

• limited healthcare workforce capacity in regional and remote areas to administer vaccines, which made it more difficult for recipients to easily access vaccines; and
• difficulty transporting vaccines to remote locations while maintaining cold chain requirements.

4.65 Throughout the rollout, Health on-boarded primary care sites to expand coverage of vaccine sites in remote and regional locations (see paragraph 4.10). As discussed in paragraph 4.52, Health also targeted activities to promote vaccine uptake to Aboriginal and Torres Strait Islander residents in remote and regional areas.

Has communication about the vaccine rollout been effective?

Consistency with communications strategy

4.66 As noted at paragraph 2.63, Health’s Communication strategy: COVID-19 vaccines and treatments (communication strategy) outlined six principles to achieve its high-level objective. Table 4.6 shows Health’s communication activities largely addressed these principles (detailed analysis is shown at Appendix 5).

Table 4.6: ANAO’s assessment of Health’s implementation of communication principles

Source: ANAO analysis of Health documents.

4.67 Health implemented communication activities which fully addressed five of its principles, and largely addressed its principles for ‘meets specific information needs’. Health’s communication activities did not recognise the economic significance of a COVID-19 vaccine in advertising materials or key messages, which was included under their principle to ‘meet specific information needs’. Health’s market research identified that economic concerns were not a strong driver for vaccine uptake in 2021, and as such focused messaging on the health benefits of vaccines.

4.68 As noted at paragraph 3.38, Health published a large range of information on the progress of the vaccine rollout on its website throughout the COVID-19 pandemic.¹⁶¹ From 9 April 2021 this included daily public updates and regular weekly updates. The information communicated in these updates increased over time (see Figure 3.4) as a result of public interest, availability of data and the Prime Minister’s public commitments to increasing data transparency.

4.69 Health used the communication channels identified in its communication strategy (see paragraph 2.60) to communicate information on the vaccine rollout. Health started communication for Phase 1 on 22 January 2021 before the vaccine rollout began and followed the four phases identified in the communication strategy (see Table 2.8).

4.70 Health implemented the mitigation strategies against the communication risks identified in the communication strategy (see Table 2.9). Health did not identify any additional communication risks to the vaccine rollout. As discussed in paragraph 2.46, Health identified and managed whole-of-rollout risks through separate processes.¹⁶²

Effectiveness of Health’s communication activities

4.71 Health began monitoring sentiment and intent to vaccinate from late 2020 (see paragraph 2.66). Health used this sentiment monitoring to track the effectiveness of vaccine rollout communications against the objectives of the COVID-19 Vaccines Campaign Advertising Campaign Strategy (advertising strategy) and communication strategy (see paragraph 2.73). As at June 2022, Health had not conducted its planned final evaluation of the effectiveness of the advertising strategy as the campaign is ongoing.

4.72 Figure 4.12 shows that over time the proportion of people likely to get vaccinated, or who had already been vaccinated, decreased from 73 per cent in March 2021 to 63 per cent in June 2021 (following the changes in ATAGI advice on AstraZeneca), then increased to 93 per cent in December 2021.

Figure 4.12: Likelihood to get the COVID-19 vaccine and vaccination status

Note: Likelihood to vaccinate was determined from participants rating from 1–10 to ‘You previously noted that you have not yet had the first dose of the COVID-19 vaccine. How likely are you to get it now that it is available?’ A response of 0–1 was assessed as very unlikely, 2–3 as unlikely, 4–6 as neither likely or unlikely, 7–8 as likely and 9–10 as very likely.

Source: ANAO analysis of Department of Heath documents.

4.73 During the vaccine rollout Health adjusted its advertising strategy and activities in response to monitoring and evaluation (see case study 2).

Communication to target groups

4.74 As discussed in 2.69, the communication strategy identified CALD communities, Aboriginal and Torres Strait Islander people, people with a disability, older Australians and demographics with a high level of vaccine hesitancy and target groups for communication. Table 4.7 summarises the key communication activities targeted to these groups.

Table 4.7: Examples of population specific communication activities in 2021^a

Note a: This is not a comprehensive list of all targeted communication activities undertaken throughout the vaccine rollout. Health advised it undertook additional activities.

Note b: Not all materials or media were translated into all languages.

Source: ANAO analysis of Health documents.

4.75 Forty-nine per cent of all Australians recalled seeing, hearing or reading vaccine campaign advertising materials in December 2021. However, Figure 4.13 shows recognition was lower for advertising targeting CALD communities (21 per cent) and Aboriginal and Torres Strait Islander people (31 per cent).¹⁶³

Figure 4.13: Recognition of vaccine rollout advertising targeted to Aboriginal and Torres Strait Islander people and CALD communities compared to recognition of advertising materials by the Australian public

Note: All public advertising refers to the recognition of any advertising materials on the vaccines rollout. CALD targeted advertising includes all media communication through non-English media. Indigenous targeted advertising includes material shown in Indigenous media.
The sample size for Indigenous advertising recognition was consistently smaller than the CALD sample and the contractor noted ‘results by month should be treated with caution due to low sample size’.

Source: ANAO analysis of Department of Heath documents.

4.76 Stakeholders from the Aboriginal and Torres Strait Islander health sector advised the ANAO that, despite the activities listed in Table 4.7, communication was not appropriately targeted to Aboriginal and Torres Strait Islander communities in the early stages of the vaccine rollout.¹⁶⁴ Similarly, the final report from Public Hearing 12 of the Royal Commission into Violence, Abuse Neglect and Exploitation of People with Disability stated, although Health developed ‘easy read’ materials which met the technical criteria for accessibility, the materials were not understandable to people with an intellectual disability.¹⁶⁵

Appendix 1 Entity response

Appendix 2 Improvements observed by the ANAO

1. The existence of independent external audit, and the accompanying potential for scrutiny improves performance. Improvements in administrative and management practices usually occur: in anticipation of ANAO audit activity; during an audit engagement; as interim findings are made; and/or after the audit has been completed and formal findings are communicated.

2. The Joint Committee of Public Accounts and Audit (JCPAA) has encouraged the ANAO to consider ways in which the ANAO could capture and describe some of these impacts. The ANAO’s 2021–22 Corporate Plan states that the ANAO’ s annual performance statements will provide a narrative that will consider, amongst other matters, analysis of key improvements made by entities during a performance audit process based on information included in tabled performance audit reports.

3. Performance audits involve close engagement between the ANAO and the audited entity as well as other stakeholders involved in the program or activity being audited. Throughout the audit engagement, the ANAO outlines to the entity the preliminary audit findings, conclusions and potential audit recommendations. This ensures that final recommendations are appropriately targeted and encourages entities to take early remedial action on any identified matters during the course of an audit. Remedial actions entities may take during the audit include:

• strengthening governance arrangements;
• introducing or revising policies, strategies, guidelines or administrative processes; and
• initiating reviews or investigations.

4. During the course of the audit, the ANAO did not observe changes in Health’s approach to the vaccine rollout.

Appendix 3 Monitoring data availability

Appendix 4 ANAO assessment of Health’s performance against key public targets

Appendix 5 ANAO assessment of Health’s communication activities