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Performance Statements Auditing in the Commonwealth — Outcomes from the 2023–24 Audit Program

Type: Performance statements audit

Report number: 25 of 2024-25

Portfolios: Across entities

Entities: Across entities

Date tabled: 19 February 2025

Audit Summary : show

Executive summary

1. Performance information is important for public sector accountability and transparency as it shows how taxpayers’ money has been spent and what this spending has achieved. The development and use of performance information is integral to an entity’s strategic planning, budgeting, monitoring and evaluation processes.

2. Annual performance statements are expected to present a clear, balanced and meaningful account of how well an entity has performed against the expectations it set out in its corporate plan. They are an important way of showing the Parliament and the public how effectively Commonwealth entities have used public resources to achieve desired outcomes.

The needs of the Parliament

3. Section 5 of the Public Governance, Performance and Accountability Act 2013 (PGPA Act) sets out the objects of the Act, which include requiring Commonwealth entities to provide meaningful performance information to the Parliament and the public. The Replacement Explanatory Memorandum to the PGPA Bill 2013 stated that ‘The Parliament needs performance information that shows it how Commonwealth entities are performing.’¹ The PGPA Act and the Public Governance, Performance and Accountability Rule 2014 (PGPA Rule) outline requirements for the quality of performance information, and for performance monitoring, evaluation and reporting.

4. The Parliament’s Joint Committee of Public Accounts and Audit (JCPAA) has a particular focus on improving the reporting of performance by entities. In September 2023, the JCPAA tabled its Report 499, Inquiry into the Annual Performance Statements 2021–22, stating:

As the old saying goes, ‘what is measured matters’, and how agencies assess and report on their performance impacts quite directly on what they value and do for the public. Performance reporting is also a key requirement of government entities to provide transparency and accountability to Parliament and the public.²

5. Without effective performance reporting, there is a risk that trust and confidence in government could be lost (see paragraphs 1.3 to 1.6).

Entities need meaningful performance information

6. Having access to performance information enables entities to understand what is working and what needs improvement, to make evidence-based decisions and promote better use of public resources. Meaningful performance information and reporting is essential to good management and the effective stewardship of public resources.

7. It is in the public interest for an entity to provide appropriate and meaningful information on the actual results it achieved and the impact of the programs and services it has delivered. Ultimately, performance information helps a Commonwealth entity to demonstrate accountability and transparency for its performance and achievements against its purposes and intended results (see paragraphs 1.7 to 1.13).

The 2023–24 performance statements audit program

8. In 2023–24, the ANAO conducted audits of annual performance statements of 14 Commonwealth entities. This is an increase from 10 entities audited in 2022–23.

9. Commonwealth entities continue to improve their strategic planning and performance reporting. There was general improvement across each of the five categories the ANAO considers when assessing the performance reporting maturity of entities: leadership and culture; governance; reporting and records; data and systems; and capability.

10. The ANAO’s performance statements audit program demonstrates that mandatory annual performance statements audits encourage entities to invest in the processes, systems and capability needed to develop, monitor and report high quality performance information (see paragraphs 1.18 to 1.27).

Audit conclusions and additional matters

11. Overall, the results from the 2023–24 performance statements audits are mixed. Nine of the 14 auditees received an auditor’s report with an unmodified conclusion.³ Five received a modified audit conclusion identifying material areas where users could not rely on the performance statements, but the effect was not pervasive to the performance statements as a whole.

12. The two broad reasons behind the modified audit conclusions were:

completeness of performance information — the performance statements were not complete and did not present a full, balanced and accurate picture of the entity’s performance as important information had been omitted; and
insufficient evidence — the ANAO was unable to obtain enough appropriate evidence to form a reasonable basis for the audit conclusion on the entity’s performance statements.

13. Where appropriate, an auditor’s report may separately include an Emphasis of Matter paragraph. An Emphasis of Matter paragraph draws a reader’s attention to a matter in the performance statements that, in the auditor’s judgement, is important for readers to consider when interpreting the performance statements. Eight of the 14 auditees received an auditor’s report containing an Emphasis of Matter paragraph. An Emphasis of Matter paragraph does not modify the auditor’s conclusion (see Appendix 1).

Audit findings

14. A total of 66 findings were reported to entities at the end of the final phase of the 2023–24 performance statements audits. These comprised 23 significant, 23 moderate and 20 minor findings.

15. The significant and moderate findings fall under five themes:

Accuracy and reliability — entities could not provide appropriate evidence that the reported information is reliable, accurate and free from bias.
Usefulness — performance measures were not relevant, clear, reliable or aligned to the entity’s purposes or key activities. Consequently, they may not present meaningful insights into the entity’s performance or form a basis to support entity decision making.
Preparation — entity preparation processes and practices for performance statements were not effective, including timeliness, record keeping and availability of supporting documentation.
Completeness — performance statements did not present a full, balanced and accurate picture of the entity’s performance, including all relevant data and contextual information.
Data — inadequate assurance over the completeness, integrity and accuracy of data, reflecting a lack of controls over how data is managed across the data lifecycle, from data collection through to reporting.

16. These themes are generated from the ANAO’s analysis of the 2023–24 audit findings, and no theme is necessarily more significant than another (see paragraphs 2.12 to 2.17).

Measuring and assessing performance

17. The PGPA Rule requires entities to specify targets for each performance measure where it is reasonably practicable to set a target.⁴ Clear, measurable targets make it easier to track progress towards expected results and provide a benchmark for measuring and assessing performance.

18. Overall, the 14 entities audited in 2023–24 reported against 385 performance targets in their annual performance statements. Entities reported that 237 targets were achieved/met⁵, 24 were substantially achieved/met, 24 were partially achieved/met and 82 were not achieved/met.⁶ Eighteen performance targets had no definitive result.⁷

19. Assessing entity performance involves more than simply reporting how many performance targets were achieved. An entity’s performance analysis and narrative is important to properly inform stakeholder conclusions about the entity’s performance (see paragraphs 2.37 to 2.44).

Connection to broader government policy initiatives

20. Performance statements audits touch many government policies and frameworks designed to enhance government efficiency, effectiveness and impact, and strengthen accountability and transparency. This is consistent with the drive to improve coherence across the Commonwealth Government’s legislative and policy frameworks that led to the PGPA Act being established.⁸ The relationship between performance statements audits and existing government policies and frameworks is illustrated in Figure S.1.

Figure S.1. Relationship of performance statements audits to government policies and frameworks

Source: ANAO analysis.

The future direction of annual performance statements audits

21. Public expectations and attitudes about public services are changing.⁹ Citizens not only want to be informed, but also to have a say between elections about choices affecting their community¹⁰ and be involved in the decision-making process, characterised by, among other things, citizen-centric and place-based approaches that involve citizens and communities in policy design and implementation.¹¹ There is increasing pressure on Commonwealth entities from the Parliament and citizens demanding more responsible and accountable spending of public revenues and improved transparency in the reporting of results and outcomes.

22. A specific challenge for the ANAO is to ensure that performance statements audits influence entities to embrace performance reporting and shift away from a compliance approach with a focus on complying with minimum reporting requirements or meeting the minimum standard they think will satisfy the auditor.¹² A compliance approach misses the opportunity to use performance information to learn from experience and improve the delivery of government policies, programs and services.

23. Performance statements audits reflect that for many entities there is not a clear link between internal business plans and the entity’s corporate plan. There can be a misalignment between the information used for day-to-day management and governance of an entity and performance information presented in annual performance statements. Periodic monitoring of performance measures is also not an embedded practice in all Commonwealth entities. These observations indicate that some entities are reporting measures in their performance statements that may not represent the highest value metrics for running the business or for measuring and assessing the entity’s performance (see paragraphs 4.32 to 4.35).

Developments in the ANAO’s audit approach

24. Working with audited entities, the ANAO has progressively sought to strengthen sector understanding of the Commonwealth Performance Framework. This includes a focus on helping entities to apply general principles and guidance to their own circumstances and how entities can make incremental improvements to their performance reporting over time. For example:

in 2021–22, the ANAO gave prominence to ensuring entities understood and complied with the technical requirements of the PGPA Act and the PGPA Rule;
in 2022–23, there was an increased focus on supporting entities to establish materiality policies that help determine which performance information is significant enough to be reported in performance statements and to develop entity-wide performance frameworks; and
in 2023–24, there was an increased focus on assessing the completeness of entity purposes, key activities and performance measures and whether the performance statements present fairly the performance of the entity (see paragraphs 4.36 to 4.38).

Appropriate and meaningful

25. For annual performance statements to achieve the objects of the PGPA Act, they must present performance information that is appropriate (accountable, reliable and aligned with an entity’s purposes and key activities) and meaningful (providing useful insights and analysis of results). They also need to be accessible (readily available and understandable).

26. For the 2024–25 audit program and beyond, the ANAO will continue to encourage Commonwealth entities to not only focus on technical matters (like selecting measures of output, efficiency and effectiveness and presenting numbers and data), but on how to best tell their performance story. This could include analysis and narrative in annual performance statements that explains the ‘why’ and ‘how’ behind the reported results and providing future plans and initiatives aligned to meeting expectations set out in the corporate plan.¹³

27. It is difficult to demonstrate effective stewardship of public resources without good performance information and reporting. Appropriate and meaningful performance information can show that the entity is thinking beyond the short-term. It can show that the entity is committed to long-term responsible use and management of public resources and effectively achieving results to create long lasting impacts for citizens (see paragraphs 4.39 to 4.45).

Linking financial and performance information

28. The ‘Independent Review into the operation of the PGPA Act’¹⁴noted that there would be merit in better linking performance and financial results, so that there is a clear line of sight between an entity’s strategies and performance and its financial results.¹⁵

29. Improving links between financial and non-financial performance information is necessary for measuring and assessing public sector productivity. As a minimum, entities need to understand both the efficiency and effectiveness of how taxpayers’ funds are used if they are to deliver sustainable, value-for-money programs and services. There is currently limited reporting by entities of efficiency (inputs over outputs) and even less reporting of both efficiency and effectiveness for individual key activities.

30. Where entities can demonstrate that more is produced to the same or better quality using fewer resources, this reflects improved productivity.

31. The ANAO will seek to work with the Department of Finance and entities to identify opportunities for annual performance statements to better link information on entity strategies and performance to their financial results (see paragraphs 4.46 to 4.51).

Cross entity measures and reporting

32. ANAO audits are yet to see the systemic development of cross-sector performance measures as indicators where it has been recognised that organisational performance is partly reliant on the actions of other agencies. Although there are some emerging better practices¹⁶, the ANAO’s findings reveal that integrated reporting on cross-cutting initiatives and linked programs could provide Parliament, government and the public with a clearer, more unified view of performance on key government priorities such as:

Closing the Gap;
women’s safety;
housing;
whole-of-government national security initiatives; and
cybersecurity.

33. Noting the interdependence, common objectives and shared responsibility across multiple government programs, there is an opportunity for Commonwealth entities to make appropriate reference to the remit and reporting of outcomes by other entities in annual performance statements. This may enable the Parliament, the government and the public to understand how the work of the reporting entity complements the work done by other parts of government.¹⁷

34. As the performance statements audit program continues to broaden in coverage, there will be opportunities for the ANAO to consider the merit of a common approach to measuring performance across entities with broadly similar functions, such as providing policy advice, processing claims or undertaking compliance and regulatory functions. A common basis for assessing these functions may enable the Parliament, the government and the public to compare entities’ results and consider which approaches are working more effectively and why (see paragraphs 4.52 to 4.56).

Audits of the Financial Statements of Australian Government Entities for the Period Ended 30 June 2024

Type: Financial statement audit

Report number: 22 of 2024-25

Portfolios: Across Entities

Entities: Across Entities

Date tabled: 6 February 2025

Audit Summary : show

Executive summary

The Australian National Audit Office (ANAO) publishes an annual audit work program (AAWP) which reflects the audit strategy and deliverables for the forward year. The purpose of the AAWP is to inform the Parliament, the public, and government sector entities of the planned audit coverage for the Australian Government sector by way of financial statements audits, performance audits, performance statements audits and other assurance activities. As set out in the AAWP, the ANAO prepares two reports annually that, drawing on information collected during financial statements audits, provide insights at a point in time of financial statements risks, governance arrangements and internal control frameworks of Commonwealth entities. These reports provide Parliament with an independent examination of the financial accounting and reporting of public sector entities.

These reports explain how entities’ internal control frameworks are critical to executing an efficient and effective audit and underpin an entity’s capacity to transparently discharge its duties and obligations under the Public Governance, Performance and Accountability Act 2013 (PGPA Act). Deficiencies identified during audits that pose either a significant or moderate risk to an entity’s ability to prepare financial statements free from material misstatement are reported.

This report presents the final results of the 2023–24 audits of the Australian Government’s Consolidated Financial Statements (CFS) and 245 Australian Government entities. The Auditor-General Report No. 42 2023–24 Interim Report on Key Financial Controls of Major Entities, focused on the interim results of the audits of 27 of these entities.

Consolidated financial statements

Audit results

1. The CFS presents the whole of government and the General Government Sector financial statements. The 2023–24 CFS were signed by the Minister for Finance on 28 November 2024 and an unmodified auditor’s report was issued on 2 December 2024.

2. There were no significant or moderate audit issues identified in the audit of the CFS in 2023–24 or 2022–23.

Australian Government financial position

3. The Australian Government reported a net operating balance of a surplus of $10.0 billion ($24.9 billion surplus in 2022–23). The Australian Government’s net worth deficiency decreased from $570.3 billion in 2022–23 to $567.5 billion in 2023–24 (see paragraphs 1.8 to 1.26).

Financial audit results and other matters

Quality and timeliness of financial statements preparation

4. The ANAO issued 240 unmodified auditor’s reports as at 9 December 2024. The financial statements were finalised and auditor’s reports issued for 79 per cent (2022–23: 91 per cent) of entities within three months of financial year-end. The decrease in timeliness of auditor’s reports reflects an increase in the number of audit findings and legislative breaches identified by the ANAO, as well as limitations on the available resources within the ANAO in order to undertake additional audit procedures in response to these findings

5. A quality financial statements preparation process will reduce the risk of inaccurate or unreliable reporting. Seventy-one per cent of entities delivered financial statements in line with an agreed timetable (2022–23: 72 per cent). The total number of adjusted and unadjusted audit differences decreased during 2023–24, although 38 per cent of audit differences remained unadjusted. The quantity and value of adjusted and unadjusted audit differences indicate there remains an opportunity for entities to improve quality assurance over financial statements preparation processes (see paragraphs 2.138 to 2.154).

Timeliness of financial reporting

6. Annual reports that are not tabled in a timely manner before budget supplementary estimates hearings decrease the opportunity for the Senate to scrutinise an entity’s performance. Timeliness of tabling of entity annual reports improved. Ninety-three per cent (2022–23: 66 per cent) of entities that are required to table an annual report in Parliament tabled prior to the date that the portfolio’s supplementary budget estimates hearing commenced. Supplementary estimates hearings were held one week later in 2023–24 than in 2022–23. Fifty-seven per cent of entities tabled annual reports one week or more before the hearing (2022–23: 12 per cent). Of the entities required to table an annual report, 4 per cent (2022–23: 6 per cent) had not tabled an annual report as at 9 December 2024 (see paragraphs 2.155 to 2.166).

Official hospitality

7. Eighty-one per cent of entities permit the provision of hospitality and the majority have policies, procedures or guidance in place. Expenditure on the provision of hospitality for the period 2020–21 to 2023–24 was $70.0 million. Official hospitality involves the provision of public resources to persons other than officials of an entity to achieve the entity’s objectives. Entities that provide official hospitality should have policies, and guidance in place which clearly set expectations for officials. There are no mandatory requirements for entities in managing the provision of hospitality, however, the Department of Finance (Finance) does provide some guidance to entities in model accountable authority instructions. Of those entities that permit hospitality 83 per cent have established formal policies, guidelines or processes.

8. Entities with higher levels of exposure to the provision of official hospitality could give further consideration to implementing or enhancing compliance and reporting arrangements. Seventy-four per cent of entities included compliance requirements in their policies, procedures or guidance which support entity’s obtaining assurance over the conduct of official hospitality. Compliance processes included acquittals, formal reporting, attestations from officials and/or periodic internal audits. Thirty-one per cent of entities had established formal reporting on provision of official hospitality within their entities (see paragraphs 2.36 to 2.56).

Artificial intelligence

9. Fifty-six entities used artificial intelligence (AI) in their operations during 2023–24 (2022–23: 27 entities). Most of these entities had adopted AI for research and development activities, IT systems administration and data and reporting.

10. During 2023–24, 64 per cent of entities that used AI had also established internal policies governing the use of AI (2022–23: 44 per cent). Twenty-seven per cent of entities had established internal policies regarding assurance over AI use. An absence of governance frameworks for managing the use of emerging technologies could increase the risk of unintended consequences. In September 2024, the Digital Transformation Agency (DTA) released the Policy for the responsible use of AI in government, which establishes requirements for accountability and transparency on the use of AI within entities (see paragraphs 2.67 to 2.71).

Cloud computing

11. Assurance over effectiveness of cloud computing arrangements (CCA) could be improved. During 2023–24, 89 per cent of entities used CCAs as part of the delivery model for the IT environment, primarily software-as-a-service (SaaS) arrangements. A Service Organisation Controls (SOC) certificate provides assurance over the implementation, design and operating effectiveness of controls included in contracts, including security, privacy, process integrity and availability. Eighty-two per cent of entities did not have in place a formal policy or procedure which would require the formal review and consideration of a SOC certificate.

12. In the absence of a formal process for obtaining and reviewing SOC certificates, there is a risk that deficiencies in controls at a service provider are not identified, mitigated or addressed in a timely manner (see paragraphs 2.57 to 2.66).

Audit committee member rotation

13. Audit committee member rotation considerations could be enhanced. The rotation of audit committee membership is not mandated, though guidance to the sector indicates that rotation of members allows for a flow of new skills and talent through committees, supporting objectivity. Forty-six per cent of entities did not have a policy requirement for audit committee member rotation.

14. Entities could enhance the effectiveness of their audit committees by adopting a formal process for rotation of audit committee membership, which balances the need for continuity and objectivity of membership (see paragraphs 2.16 to 2.21).

Fraud framework requirements

15. The Commonwealth Fraud Control Framework 2017 encourages entities to conduct fraud risk assessments at least every two years and entities responsible for activities with a high fraud risk may assess risk more frequently. All entities had in place a fraud control plan. Ninety-seven per cent of entities had conducted a fraud risk assessment within the last two years. Changes to the framework which occurred on 1 July 2024 requires entities to expand plans to take account of preventing, detecting and dealing with corruption, as well as periodically examining the effectiveness of internal controls (see paragraphs 2.16 to 2.21).

Summary of audit findings

16. Internal controls largely supported the preparation of financial statements free from material misstatement. However, the number of audit findings identified by the ANAO has increased from 2023–24. A total of 214 audit findings and legislative breaches were reported to entities as a result of the 2023–24 financial statements audits. These comprised six significant, 46 moderate, 147 minor audit findings and 15 legislative breaches. The highest number of findings are in the categories of:

IT control environment, including security, change management and user access;
compliance and quality assurance frameworks, including legal conformance; and
accounting and control of non-financial assets.

17. IT controls remain a key issue. Forty-three per cent of all audit findings identified by the ANAO related to the IT control environment, particularly IT security. Weaknesses in controls in this area can expose entities to an increased risk of unauthorised access to systems and data, or data leakage. The number of IT findings identified by the ANAO indicate that there remains room for improvement across the sector to enhance governance processes supporting the design, implementation and operating effectiveness of controls.

18. These audits findings included four significant legislative breaches, one of which was first identified since 2012–13. The majority (53 per cent) of other legislative breaches relate to incorrect payments of remuneration to key management personnel and/or non-compliance with determinations made by the Remuneration Tribunal. Entities could take further steps to enhance governance supporting remuneration to prevent non-compliance or incorrect payments from occurring (see paragraphs 2.72 to 2.137).

Financial sustainability

19. An assessment of an entity’s financial sustainability can provide an indication of financial management issues or signal a risk that the entity will require additional or refocused funding. The ANAO’s analysis concluded that the financial sustainability of the majority of entities was not at risk (see paragraphs 2.167 to 2.196).

Reporting and auditing frameworks

Changes to the Australian public sector reporting framework

20. The development of a climate-related reporting framework and assurance regime in Australia continues to progress. ANAO consultation with Finance to establish an assurance and verification regime for the Commonwealth Climate Disclosure (CCD) reform is ongoing (see paragraphs 3.20 to 3.24).

21. Emerging technologies (including AI) present opportunities for innovation and efficiency in operations by entities. However, rapid developments and associated risks highlight the need for Accountable Authorities to implement effective governance arrangements when adopting these technologies. The ANAO is incorporating consideration of risks relating to the use of emerging technologies, including AI, into audit planning processes to provide Parliament with assurance regarding the use of AI by the Australian Government (see paragraphs 3.25 to 3.33).

22. The ANAO Audit Quality Report 2023–24 was published on 1 November 2024. The report demonstrates the evaluation of the design, implementation and operating effectiveness of the ANAO’s Quality Management Framework and achievement of ANAO quality objectives (see paragraphs 3.34 to 3.39).

23. The ANAO Integrity Report 2023–24 and the ANAO Integrity Framework 2024–25 were also published on 1 November 2024 to provide transparency of the measures undertaken to maintain a high integrity culture within the ANAO (see paragraphs 3.44 to 3.46).

Cost of this report

24. The cost to the ANAO of producing this report is approximately $445,000.

Administration of the Pharmaceutical Benefits Scheme

Type: Performance audit

Report number: 19 of 2024-25

Portfolios: Health and Aged Care; Services Australia

Entities: Department of Health and Aged Care; Services Australia

Date tabled: 17 December 2024

Audit Summary : show

Summary and recommendations

Background

1. The Pharmaceutical Benefits Scheme (PBS) is an Australian Government scheme that subsidises the cost of a wide range of medicines for Australian residents and eligible overseas visitors. The PBS is enabled by the National Health Act 1953 (NHA) which regulates the listing, prescribing, pricing, charging and payment of subsidies for the supply of medicines and medicinal preparations as pharmaceutical benefits. The PBS Schedule, made under the National Health (Listing of Pharmaceutical Benefits) Instrument 2024, lists medicines subsidised under the PBS and outlines requirements for the provision of these medicines.

2. The objective of the PBS is to provide Australians with timely, reliable and affordable access to necessary and cost-effective medicines. The Department of Health and Aged Care (Health) is responsible for PBS policy and has a bilateral agreement with Services Australia to deliver PBS-related services and payments.

Rationale for undertaking the audit

3. The PBS is intended to ensure that Australians have timely, reliable and affordable access to medicines. The budgeted expenditure for the PBS for the 2024–25 financial year is $19.5 billion. This performance audit was conducted to provide assurance to Parliament that the PBS is being administered effectively.

Audit objective and criteria

4. The objective of the audit was to assess the effectiveness of the administration of the PBS.

5. To form a conclusion against the audit objective, the following high-level criteria were adopted:

Has Health established appropriate governance and oversight arrangements for the PBS?
Has Health established appropriate arrangements to manage the cost of the PBS?
Have Health and Services Australia established effective arrangements to manage the delivery of PBS services and payments?

Conclusion

6. Health’s and Services Australia’s administration of the PBS is partly effective. While arrangements for managing the cost of the PBS are largely effective, there were deficiencies in arrangements for whole-of-program management and administering the delivery of PBS services and payments.

7. Health’s governance and oversight arrangements for the PBS are partly appropriate. Instruments for delegating statutory powers for administering the PBS have irregularities and anomalies. Health’s PBS Program Management Plan could be improved by including more detail on Health’s management arrangements for the PBS. Health has a largely appropriate bilateral arrangement with Services Australia to oversee its delivery of PBS services and payments. Health’s performance measurement framework for the PBS does not adequately measure and report on program outcomes. Health’s risk management focuses on shared administration risks with Services Australia and has not considered broader strategic risks to the PBS. While mechanisms are in place for stakeholder engagement on the PBS, Health has not conducted an analysis of stakeholder engagement needs or developed an overarching stakeholder engagement plan.

8. Health’s arrangements to manage the cost of the PBS are largely appropriate. Arrangements were in place to assess the cost-effectiveness of individual PBS medicines and manage the cost of listed medicines. Arrangements have been established to manage pharmacy remuneration through successive Community Pharmacy Agreements (CPAs), negotiated with the pharmacy industry, which Health supported through impact analysis for the eighth CPA signed in June 2024. Health has established processes for managing patient out-of-pocket costs and monitoring and forecasting the overall cost of the PBS. Health has not established arrangements to automate patient access to the Safety Net or engaged in horizon scanning analysis to anticipate potential future costs of new and novel medicines.

9. Health and Services Australia’s arrangements to manage the delivery of PBS services and payments are partly effective. Processes and systems for PBS claims processing are not fully effective at ensuring that legislative requirements for PBS claims are met, as Services Australia is not ensuring that PBS suppliers certify claims in accordance with legislative timeframes. While payment integrity is reviewed, it is not subject to performance monitoring or reporting. Payment timeliness is monitored, and targets are regularly met. The results are not included in Services Australia’s Annual Performance Statement. The provision of authority approvals is based on an automated system. There were differences in approval rates between authority applications made online and by phone, and Services Australia’s performance target for reporting on answering authority calls in its Annual Performance Statements does not align with the performance target agreed with Health in bilateral agreements. PBS Safety Net card claims and patient refunds are reliant on manual processes and timeliness performance measures have not been consistently met.

Supporting findings

Governance and oversight

10. Instruments that delegate powers and functions for administering the PBS have irregularities and anomalies. While Health has developed a Program Management Plan for the PBS, it does not adequately cover arrangements for managing PBS costs, stakeholder engagement and whole-of-program performance measurement. Health’s support to independent statutory bodies with responsibilities for the PBS could be improved by developing governance documentation for the Pharmaceutical Benefits Advisory Committee. (See paragraphs 2.3 to 2.24)

11. Health and Services Australia have established a Bilateral Management Arrangement, which includes bilateral agreements and bilateral governance arrangements that relate to the delivery of PBS services and payments.

PBS-related program agreements were fit for purpose, with clear objectives and defined roles and responsibilities. All protocols supporting the bilateral arrangement were reviewed and updated between November 2023 and September 2024.
While bilateral governance meetings have not occurred at the most senior levels, there has been regular engagement between the two entities at lower levels. Governance committees relevant to the PBS began considering risk, performance reporting, and updates to bilateral agreements in late 2023. (See paragraphs 2.25 to 2.35)

12. Health has one external performance measure for the PBS, which is not outcome focused and does not provide meaningful performance information to the Parliament or the public. Health receives monthly reporting from Services Australia on bilateral performance measures. It has not used this data to oversee Services Australia’s service delivery. Health does not provide any regular performance reporting on the PBS to the minister or its executive committee. (See paragraphs 2.36 to 2.54)

13. Health has not undertaken appropriate risk assessments or developed appropriate risk management plans for the PBS at the divisional or program level. Its risk assessments and plans do not adequately cover key program activities for which Health is responsible. Health’s shared risk management plan with Services Australia covers risks relating to the services and payments Services Australia delivers for the PBS. From late 2023, bilateral governance bodies began discussing operational risks relevant to the PBS. (See paragraphs 2.55 to 2.69)

14. Health’s arrangements for stakeholder engagement for the PBS include the provision of information through websites, invitation of written submissions from stakeholders on specific PBS issues, agreement-making with industry bodies, and hosting regular stakeholder engagement forums. These arrangements have not been informed by a systematic analysis of stakeholder engagement needs or an overarching stakeholder engagement plan or strategy. (See paragraphs 2.70 to 2.83)

Managing the cost of the PBS

15. Arrangements for assessing medicine cost-effectiveness outlined in the Guidelines for preparing submissions to the Pharmaceutical Benefits Advisory Committee have been followed. Health has complied with administrative procedures for listing medicines on the Schedule and agreeing medicine prices with sponsors. Health has negotiated deeds of agreement with medicine sponsors (covering special pricing arrangements and risk-sharing agreements) to minimise the cost of PBS medicines to government. Statutory price reductions are in place to decrease the cost of listed medicines. Medicines are delisted from the Schedule by medicine sponsors with no regular delisting process performed by Health. (See paragraphs 3.3 to 3.53)

16. The Australian Government has negotiated Community Pharmacy Agreements (CPAs) with the pharmacy sector to determine pharmacy remuneration for dispensing PBS medicines since 1990. CPAs offer flexibility to include terms such as the remuneration adjustment mechanism to mitigate unexpected expenditure for the Australian Government. The choice to negotiate a CPA rather than allowing remuneration to be set by an independent tribunal was not supported by adequate impact analysis for the seventh CPA. Health prepared an Impact Analysis for the eighth CPA, signed in June 2024, which supported continuation of pharmacy remuneration setting through a CPA. (See paragraphs 3.54 to 3.74)

17. Health has used monitoring data to model the impact of proposed changes to patient co-payment amounts and Safety Net thresholds on patient out-of-pocket costs. Based on this modelling, Health has provided advice to government on proposals to help patients achieve greater cost-savings through these mechanisms. Health has not established arrangements to automatically determine eligibility for the Safety Net. Health has estimated that 640,000 patients become eligible for the Safety Net each year but do not apply, foregoing $100 million in medicine subsidies. (See paragraphs 3.75 to 3.95)

18. Health has established arrangements for modelling the overall cost of the PBS and the impact of new medicine listings, and it provides advice to the government and Parliament through the annual Budget processes.

Health has established a system to model PBS expenditure based on the current legislative requirements, which it uses to model the impact of new and amended medicine listings.
Reporting on PBS expenditure is available through an annual report and reporting on Services Australia’s website.
Health has not performed horizon scanning analysis to forecast PBS expenditure and identify potential policy changes. (See paragraphs 3.96 to 3.113)

Delivery of services and payments

19. Almost all claims (99.9 per cent) made by PBS suppliers are submitted through Services Australia’s Online Claiming for PBS system, which automatically assesses claims against legislative rules before processing advance payments. Due to an absence of controls to ensure advance payments to PBS suppliers are certified within statutory timeframes, over one-third of approved PBS suppliers have uncertified claims totalling $1.514 billion (as at 30 June 2024). Payment integrity is reviewed but is not subject to performance monitoring or reporting. Payment timeliness is monitored, and targets are regularly reported as met, but it is not included in public reporting. (See paragraphs 4.3 to 4.30)

20. A system to manage authority-required approvals has been established that is consistent with Health and Services Australia’s respective responsibilities under the PBS bilateral agreement. There are differences in approval rates depending on the method used by an applicant to apply for an authority. Reported results for the timeliness of authority approvals against performance measures set out in bilateral arrangements have largely not met targets. Services Australia reports in its Annual Performance Statement on the achievement of a performance measure target of answering authority calls within 15 minutes. This does not align with the target of answering authority calls, on average, in less than 30 seconds. (See paragraphs 4.31 to 4.52)

21. Services Australia has established processes and systems to manage PBS Safety Net and patient refunds. Both systems are reliant on paper-based application forms which are submitted by post and manually processed by Services Australia. The reliance on manual processing means that performance is sensitive to staffing numbers, which has meant timeliness performance measures have not been consistently met. Services Australia’s quality checking process for Safety Net claims does not provide accurate data on the reasons for rejecting Safety Net card applications to inform education or compliance activities. (See paragraphs 4.55 to 4.78)

Recommendations

Recommendation no. 1

Paragraph 2.8

The Department of Health and Aged Care and Services Australia work to review and update relevant delegation instruments to address irregularities and anomalies.