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Type: Performance audit
Report number: 10 of 2024-25
Portfolios: Employment and Workplace Relations
Entities: Australian Skills Quality Authority
Date tabled:
Audit Summary : show
Summary and recommendations
Background
1. Fraud against Australian Government entities and corrupt conduct by Australian Government officials are serious matters that can constitute criminal offences. Fraud and corruption undermine the integrity of and public trust in government, including by reducing funds available for government program delivery and causing financial and reputational damage to defrauded entities.1
2. The Australian Government defines fraud as:
Dishonestly obtaining (including attempting to obtain) a gain or benefit, or causing a loss or risk of loss, by deception or other means.2
3. Fraud against the Australian Government can be committed by government officials or contractors (internal fraud) or by parties such as clients of government services, service providers, grant recipients, other members of the public or organised criminal groups (external fraud).3 The Australian Government’s requirements for fraud control apply to both internal and external fraud risks. The 2024 Commonwealth Fraud and Corruption Control Framework states that:
Fraud and corruption are risks that can undermine the objectives of every Australian Government entity in all areas of their business, including delivery of services and programs, policy-making, regulation, taxation, procurement, grants and internal procedures.4
Australian Skills Quality Authority
4. The Australian Skills Quality Authority (ASQA) is the Australian Government agency responsible for the regulation of around 90 per cent of vocational education and training (VET) providers operating in Australia. ASQA’s purpose is ‘to ensure quality VET, so that students, industry, governments and the community can have confidence in the integrity of national qualifications issued by training providers’.5
Rationale for undertaking the audit
5. Fraud against Australian Government entities reduces available funds for public goods and services and causes financial and reputational damage to the Australian Government.6 All Commonwealth entities are required to have fraud control arrangements in place to prevent, detect and respond to fraud. From 1 July 2024, this requirement also extends to corruption.7 This audit is intended to provide assurance to the Parliament regarding the fraud control arrangements in ASQA.
Audit objective and criteria
6. The objective of the audit was to assess the effectiveness of ASQA’s fraud control arrangements as the national regulator of the vocational education and training sector.
7. To form a conclusion against this objective, the following high-level criteria were adopted.
- Have appropriate arrangements been established to oversee and manage fraud risks?
- Have appropriate mechanisms been established to prevent fraud and promote a culture of integrity?
- Have appropriate mechanisms been established to detect and respond to fraud?
- Has the Australian Skills Quality Authority appropriately prepared for the commencement of the revised Commonwealth Fraud and Corruption Control policy in July 2024?
Conclusion
8. ASQA has established partly effective fraud control arrangements. ASQA’s Fraud Control Plan 2022–2024 and Fraud Control Policy focus on internal fraud risks and do not consider the entity’s regulatory fraud environment. ASQA has undertaken minimal steps to align with the Commonwealth’s revised Fraud and Corruption Control Framework which came into effect on 1 July 2024.
9. ASQA has not established appropriate arrangements to manage fraud risk. Fraud control arrangements are based on a fraud control policy that was developed in 2013 and does not reflect current Commonwealth legislative and policy requirements. ASQA’s Fraud Control Plan 2022–2024 does not consider its regulatory fraud control environment, and there is no process to test regulatory fraud controls systematically and regularly. The Fraud Control Plan 2022–2024 contains an overlap of roles and responsibilities of key officials.
10. ASQA has established largely appropriate mechanisms to prevent fraud and promote integrity across its internal and regulatory environments. This includes channels to promote fraud awareness and integrity internally through training, fraud qualifications and professional development, and engagement including social media and sector alerts. Within its regulatory environment, ASQA has established outreach mechanisms to the VET sector that address fraud awareness. ASQA has not appropriately assessed the effectiveness of these mechanisms.
11. ASQA has recently established detection controls, including a tip-off line and information-sharing relationships with external agencies. ASQA has not assessed the effectiveness of these detection controls. ASQA has established an investigatory process for regulatory fraud but does not measure its outcomes or effectiveness.
12. ASQA has taken minimal steps to align with the revised Commonwealth Fraud and Corruption Policy through the development of an updated draft Fraud and Corruption Control Policy and Plan for 2024–2026. ASQA has not prepared an implementation plan and there is no evaluation plan for the new or revised controls. ASQA’s new Fraud and Corruption Control Policy and Plan 2024–2026 has minimal updates from the Fraud Control Policy and Plan 2022–2024 and does not include regulatory fraud or corruption controls.
Supporting findings
Oversight and management of fraud risks
13. ASQA’s fraud control framework is based on a fraud control policy that was developed in 2013 and does not reflect current Commonwealth legislative and policy requirements, or the changes the entity has undergone in the 10 years since the policy was developed. ASQA’s Fraud Control Plan 2022–2024 does not consider the entity’s regulatory fraud control environment, and associated fraud control activities. ASQA has developed a regulatory model which details ASQA’s regulatory and compliance approach. The regulatory model does not specifically address fraud. ASQA’s fraud control plan includes an overlap of responsibilities between key officials. (See paragraphs 2.2 to 2.23)
14. ASQA’s Fraud Control Plan 2022–2024 identified one external fraud risk. The Plan identified seven internal fraud risks, six of which were reviewed during the period covered by the plan. ASQA undertook risk assessments in 2023 and 2024 within its regulatory environment using its environmental scan tool which identified fraud risk relating to visa fraud. The outcomes of risk assessments were not provided to ASQA’s internal audit function. (See paragraphs 2.24 to 2.39)
15. ASQA’s Fraud Control Plan 2022–2024 addresses internal fraud risks and controls and one external fraud risk relating to false or misleading information. The Plan does not address ASQA’s role as the national regulator for the VET sector and its associated regulatory fraud control environment. The Fraud Control Plan 2022–2024 contains controls commensurate with the identified internal fraud risks. Limited testing of controls occurred once in 2023, and mechanisms to test the internal fraud controls on a regular basis have not been established. (See paragraphs 2.40 to 2.48)
Fraud prevention and integrity culture
16. Internal preventative controls align with the risks identified in the entity’s Fraud Control Plan 2022–2024. Regulatory preventative measures include sector alerts and participation in the Fraud Fusion Taskforce. ASQA has not tested the effectiveness of its internal or regulatory fraud prevention controls (including its controls for managing identity fraud), or its documented procedures for preventing, detecting and responding to fraud. (See paragraphs 3.2 to 3.20)
17. ASQA promotes a fraud awareness culture within the entity through annual mandatory fraud awareness training and utilising internal communication channels, including CEO messages emailed to all staff. As at April 2024, the reported completion rate for ASQA’s mandatory fraud awareness training was 84 per cent. ASQA also undertakes outreach programs through mechanisms such as sector alerts and social media alerts to promote fraud awareness. (See paragraphs 3.21 to 3.27)
18. Officials with fraud control responsibilities at ASQA have opportunities for ongoing professional development through training, such as that provided by the Commonwealth Director of Public Prosecutions. ASQA officials engaged in fraud control activities hold relevant qualifications, including the Certificate IV in Government (Investigation) and Diploma in Government (Investigation). (See paragraphs 3.28 to 3.35)
Fraud detection and response
19. ASQA’s detection controls include mechanisms such as a tip-off line and information sharing arrangements with external agencies which provide an appropriate detection framework. There is no documented or consistent process for monitoring and evaluating the effectiveness of these detective controls. (See paragraphs 4.2 to 4.25)
20. ASQA has established mechanisms to investigate and respond to fraud but does not measure its performance, including the effectiveness and efficiency of its fraud response. There were no consistent documented processes and procedures for the operation of ASQA’s investigation capability. ASQA has referred matters to external agencies as part of their information sharing mechanisms. In early August 2024 there were two instances where ASQA referred fraud matters to the Commonwealth Director of Public Prosecutions. One fraud matter was discussed with the Australian Federal Police in 2023–24. (See paragraphs 4.26 to 4.37)
21. ASQA’s Annual Report 2022–23 includes its Accountable Authority’s certification on fraud control confirming that the CEO was satisfied that ASQA has appropriate prevention, detection, investigation, reporting and data collection procedures and processes in place. This certification in the annual report was not supported by evidence. ASQA has established reporting channels with other Commonwealth entities to report fraud and has provided information to the Australian Institute of Criminology as required, and has not kept records of the information provided. (See paragraphs 4.38 to 4.46)
Preparation for the revised Commonwealth Fraud and Corruption Control Framework
22. ASQA does not have an implementation plan for the revised Commonwealth Fraud and Corruption Control Policy. ASQA has an updated Fraud and Corruption Control Policy and Plan 2024–2026. As at July 2024, this document is still in draft and does not address ASQA’s regulatory fraud control environment. (See paragraphs 5.2 to 5.8)
23. ASQA has not established a plan to evaluate the implementation of new or revised fraud and corruption controls. (See paragraphs 5.9 to 5.10)
Recommendations
Recommendation no. 1
Paragraph 2.15
The Australian Skills Quality Authority ensures roles and responsibilities covered in its fraud control arrangements are current and commensurate with existing governance arrangements.
Australian Skills Quality Authority response: Agreed.
Recommendation no. 2
Paragraph 2.47
The Australian Skills Quality Authority updates its Fraud Control Policy and Plan to cover the full extent of its functions including its regulatory activities, supported by risk assessments that clearly address fraud risk and contain robust mitigation strategies.
Australian Skills Quality Authority response: Agreed in-part.
Recommendation no. 3
Paragraph 4.24
The Australian Skills Quality Authority documents its processes for monitoring and evaluating the effectiveness of its fraud controls across prevention and detection.
Australian Skills Quality Authority response: Agreed.
Summary of entity response
24. The proposed audit report was provided to ASQA. ASQA’s summary response is provided below, and its full response is included at Appendix 1. Improvements observed by the ANAO during the course of this audit are listed in Appendix 2.
ASQA places a high value on review and improvement and welcomes the role that ANAO plays in providing independent insights supporting performance improvement. ASQA is already taking action to improve clarity of roles and responsibilities, and document our processes for monitoring and evaluating the effectiveness of fraud controls across prevention and detection to ensure that our internal controls are fit for purpose to protect the entity from these risks. Giving consideration to the audit findings, ASQA will now finalise our Fraud and Corruption Policy and Plan 2024-2026 under the revised Commonwealth Fraud and Corruption Control Framework, which came into effect during this audit in July 2024.
We note that the Commonwealth Fraud and Corruption Control Framework provides a system of governance and accountability across entities for protecting public resources from fraud and corruption. In its role as the National Regulator of VET ASQA is focused on protecting vulnerable students and taking action against non-genuine providers, and to scrutinise those who are in the business of managing or operating RTOs. This has a broader public purpose to prevent harms including those that might arise from external fraud that are not directed at or directly detrimental to the Commonwealth, but to students, employers or industry. This fact has implications for ASQA’s consideration of Recommendation 2 of this report.
Key messages from this audit for all Australian Government entities
25. Below is a summary of key messages, including instances of good practice, which have been identified in this audit and may be relevant for the operations of other Australian Government entities.
Group title
Program design
Key learning reference
Type: Performance audit
Report number: 49 of 2023-24
Portfolios: Education
Entities: Australian Research Council
Date tabled:
Audit Summary : show
Summary and recommendations
Background
1. The Department of Finance’s Resource Management Guide 206 defines a ‘corporate credit card’ as a credit card used by Commonwealth entities to obtain goods and services on credit.1 Credit cards are used by Commonwealth entities to support timely and efficient payment of suppliers for goods and services.2 For the purposes of the Public Governance, Performance and Accountability Act 2013 (PGPA Act), credit cards include charge cards (such as VISA, Mastercard, Diners and American Express cards) and vendor cards (such as travel cards and fuel cards).
2. The Australian Research Council (ARC) reported 140 staff in 2021–22 and 167 staff in 2022–23. Forty-three staff (30.7 per cent) in 2021–22 and 49 staff (29.3 per cent) in 2022–23 held corporate credit cards. Credit card expenditure in 2021–22 was $226,860.22 (from 441 transactions) and in 2022–23 was $411,957.31 (from 1,417 transactions). Total credit card expenditure over the two financial years was $638,817.53 (from 1,858 transactions). The number of transactions increased between the two financial years, due to the influence of the COVID-19 pandemic, which limited staff travel and hospitality during 2021–22. Credit card and travel expenditure represented 5.16 per cent and 16.93 per cent of ARC’s supplier expenses in 2021–22 and 2022–23.3
Rationale for undertaking the audit
3. The misuse of corporate credit cards, whether deliberate or not, has the potential for financial losses and reputational damage to government entities and the Australian Public Service. The Australian Public Service Commission (APSC) states that:
establishing a pro-integrity culture at the institutional level means setting a culture that values, acknowledges and champions proactively doing the right thing, rather than purely a compliance-driven approach which focuses exclusively on avoidance of wrong doing.4
4. In describing the role of Senior Executive Service (SES) officers, the APSC states that the SES ‘set the tone for workplace culture and expectations’, they ‘are viewed as role models of integrity’ and ‘are expected to foster a culture that makes it safe and straightforward for employees to do the right thing’.5 The New South Wales Independent Commission Against Corruption identifies organisational culture and expectations as a key element in preventing corruption and states:
[T]he way that an agency’s senior executives, middle managers and supervisors behave directly influences the conduct of staff by conveying expectations of how staff ought to act. This is something that affects an agency’s culture.6
5. Deliberate misuse of a corporate credit card is fraud. The National Anti-Corruption Commission Integrity Outlook 2022/23 identifies fraud, which includes the misuse of credit cards, as a key corruption and integrity vulnerability.7 The Commonwealth Fraud Risk Profile indicates that credit cards are a common source of internal fraud risk. Previous audits have identified issues in other entities relating to positional authority for approving credit card transactions8 and ineffective controls to manage the use of corporate credit cards.9 This audit was conducted to provide the Parliament with assurance that the ARC is effectively managing corporate credit cards in accordance with legislative and entity requirements.
6. This audit is one of a series of compliance with credit card requirements that apply a standard methodology. The four entities included in the ANAO’s 2023–24 compliance with credit card requirements audit series are the:
- Australian Research Council;
- Federal Court of Australia;
- National Disability Insurance Agency; and
- Productivity Commission.
Audit objective and criteria
7. The objective of the audit was to assess the effectiveness of the ARC’s management of the use of corporate credit cards for official purposes in accordance with legislative and entity requirements.
8. To form a conclusion against the objective, the ANAO examined:
- whether the ARC has effective arrangements in place to manage the issue, return and use of corporate credit cards; and
- whether the ARC has implemented effective controls and processes for corporate credit cards in accordance with its policies and procedures.
Conclusion
9. The ARC was largely effective in managing the use of corporate credit cards for official purposes in accordance with legislative and entity requirements. Better implementation of preventive and detective controls could improve the ARC’s assurance over its corporate credit card use.
10. The ARC’s arrangements for managing the issue, return and use of corporate credit cards were largely effective. Documentation of policies and procedures could be improved and the ARC has not tested all risk controls related to credit cards. The ARC did not respond to parliamentary questions on notice with accurate information on credit card use.
11. The implementation of the ARC’s preventive and detective controls was partly effective in controlling risk. Controls were not always implemented in accordance with policy. Although the ARC had identified 10 instances of non-compliance that did not align with policies and procedures in 2021–22 and 2022–23, the ANAO identified 83. Positional authority risks were not directly addressed and there was no analysis of usage trends to improve the effectiveness of controls. The ARC has documented processes for managing non-compliance. This does not include detail on the processes for managing repeated instances of non-compliance.
Supporting findings
Arrangements for managing corporate credit cards
12. Risks related to credit card misuse are contained in the ARC’s Fraud Control Plan. Credit card compliance is reviewed through an annual CEO compliance review and a compliance survey every four months. There are opportunities for the ARC to improve the identification and management of controls around duplicate transactions. (See paragraphs 2.4 to 2.24)
13. The ARC’s policies and procedures for the issue, return and use of credit cards included coverage of requirements within accountable authority instructions and other policies. There is scope to improve documentation of policies and procedures. Policies and procedures were not reviewed and updated in line with the ARC’s timeframes. Language in the documents could be strengthened. (See paragraphs 2.25 to 2.43)
14. The ARC Credit Card Procedure and acquittal form provide details for acquittal. The cardholder agreement form outlines the credit card usage requirements. The ARC provides mandatory Fraud Awareness and Commonwealth Resource Management Framework e-learning to all staff and access to relevant webinars on fraud and scams. (See paragraphs 2.44 to 2.45)
15. The ARC has arrangements for monitoring and reporting on the issue, return and use of credit cards. The finance team monitors statements and acquittals on an ongoing basis and can produce reports on issue, return and use of cards through the HSBC Online Portal, as required. The ARC reports on credit card use as part of the annual CEO compliance review and monitors credit card compliance. The ARC reported on credit card issue and use when requested by Parliament, which included an overstatement for two questions on notice. (See paragraphs 2.46 to 2.54)
Controls and processes for corporate credit cards
16. Preventive controls implemented by the ARC could be strengthened by consistency in documentation. Documentation of expenditure type and credit card limits in the initial application process is not completed in line with policies and procedures. There is no process in place to periodically review cardholders with monthly credit limits above the policy-defined limits. Cancellation practice did not align with policies and procedures. (See paragraphs 3.4 to 3.20)
17. ARC reviews, acquits and verifies transactions manually each month. The supporting evidence required for all expenditure is not consistently provided to the delegate for approval. The ARC’s process for tracking travel approvals is inconsistent. The ARC implemented an Official Hospitality and Gifts Policy in June 2023. The ARC has not directly addressed positional authority risk. (See paragraphs 3.21 to 3.45)
18. The ARC has a process to manage instances of non-compliance, however this process under-identified instances of non-compliances during 2021–22 and 2022–23. The ARC identified 10 instances of non-compliance that did not align with policies and procedures, compared with the ANAO’s identification of 83. The ARC has not established preventive and detective processes to periodically analyse usage trends to detect patterns across its corporate credit card and Diners Club virtual card expenditure. The policy and procedure require immediate reporting of credit card misuse; it does not include detail on the processes for managing repeated instances of non-compliance. (See paragraphs 3.46 to 3.54)
Recommendations
Recommendation no. 1
Paragraph 3.34
The Australian Research Council resolve inconsistencies between policies and procedures and actual practice.
Australian Research Council response: Agreed.
Recommendation no. 2
Paragraph 3.41
The Australian Research Council should consider positional authority risk directly, including for key roles, like the Chief Executive Officer (CEO); and if suitable, implement transparency measures, such as regularly report on these expenses to the Audit Committee Chair.
Australian Research Council response: Agreed.
Recommendation no. 3
Paragraph 3.51
The Australian Research Council review credit card transactions, to identify trends, such as trends in use and non-compliance, and their impact on policies and review and take corrective action. This work could include:
- periodic review of usage patterns to assess whether there is an ongoing business case for a credit card; and
- analysing patterns of credit card spending to develop ongoing improvements to methods for monitoring the effectiveness of the acquittal process.
Australian Research Council response: Agreed.
Summary of entity response
19. The proposed audit report was provided to the ARC. The ARC’s summary response is reproduced below. Its full response is included at Appendix 1. Improvements observed by the ANAO during the course of the audit are at Appendix 2.
The Australian Research Council (ARC) welcomes the Australian National Audit Office’s (ANAO) report and accepts the recommendations made for the agency.
The report finds that the ARC is effective overall in managing the use of corporate credit cards in accordance with legislative and entity requirements and the issue, return and use of corporate credit cards. The ANAO’s review of all credit card transactions for the audit period (2021–22 to 2022–23) also revealed no instances of fraud or deliberate misuse.
The report does identify areas for improvement and makes three recommendations where the ARC can take steps to further strengthen its policies, processes, and controls. The ARC agrees with, and will take steps to implement, these recommendations.
Key messages from this audit for all Australian Government entities
20. This audit is part of a series of audits that apply a standard methodology to corporate credit card management in Commonwealth entities. The four entities included in the ANAO’s 2023–24 corporate credit card management series are the:
- Australian Research Council;
- Federal Court of Australia;
- National Disability Insurance Agency; and
- Productivity Commission.
21. Key messages from the ANAO’s series of credit card management audits will be outlined in an Insights product available on the ANAO website.
Type: Financial statement audit
Report number: 42 of 2023-24
Portfolios: Across Entities
Entities: Across Entities
Date tabled:
Audit Summary : show
Type: Performance audit
Report number: 32 of 2023-24
Portfolios: Education
Entities: Australian Institute for Teaching and School Leadership
Date tabled:
Audit Summary : show
Summary and recommendations
Background
1. As of 2022, Australia’s school education system was made up of 9,614 schools, attended by four million students, and staffed by 307,228 teaching staff (full time equivalent, including principals).1 There were also 90,028 prospective teachers enrolled in Initial Teacher Education (ITE) courses.2
2. The Australian Institute for Teaching and School Leadership Limited (AITSL, or the company) was established in 2010 to lead the promotion of excellence in teaching and school leadership on behalf of the Australian Government and state and territory governments, with an initial focus on national standards and professional development resources.3
3. As of December 2023, AITSL is responsible for administering 10 national standards and frameworks, which inform teacher regulation, professional development and career pathways, codify agreed common approaches to regulation between states and territories, and provide assistance and support for teachers and school leaders in areas of identified need.4 In 2022–23, AITSL had 81 employees (not including board directors), and received $17.1 million in revenue, including $10.3 million from the Australian Government (Table 1.1).
Rationale for undertaking the audit
4. AITSL was established ‘to provide national leadership for the Commonwealth, state and territory governments in promoting excellence in the profession of teaching and school leadership’.5 As of December 2023, AITSL is responsible for administering 10 national standards and frameworks, which inform the regulation, professional development and career pathways of the teaching profession.6
5. This audit provides assurance to the Parliament over the effectiveness of AITSL’s administration of national standards and frameworks.
Audit objective and criteria
6. The audit objective was to assess the effectiveness of AITSL’s administration of national standards and frameworks.
7. To form a conclusion against the objective, the following high-level audit criteria were adopted:
- Has AITSL established fit-for-purpose governance arrangements to support the administration of national standards and frameworks?
- Has AITSL adopted an appropriate approach to developing, revising and supporting the implementation of national standards and frameworks?
- Does AITSL effectively measure, monitor, evaluate and report on national standards and frameworks?
Conclusion
8. AITSL’s administration of national standards and frameworks is largely effective. By improving its strategic planning and assurance, AITSL would be better positioned to determine whether national standards and frameworks are having the intended impact on the quality of teaching and school leadership in Australia.
9. AITSL has established governance arrangements that are largely fit‐for‐purpose to support the administration of national standards and frameworks. Strategic planning arrangements largely support the company’s work on national standards and frameworks. Alignment between the corporate plan and annual work plan could be improved. Risk management and internal reporting arrangements incorporate national standards and frameworks, and action is taken in response to risks. The company’s arrangements to gather, document, and use expert advice support its purpose. Feedback to expert advisory groups on how AITSL uses their advice could be improved. The Department of Education’s support for assessing the collective expertise of the Board to support appointments could be improved.
10. AITSL has adopted a largely appropriate approach to developing, revising and supporting the implementation of national standards and frameworks. While stakeholder engagement approaches are in place, there is no overarching strategy for stakeholder engagement activities. Training, guidance and information resources to support the implementation of national standards and frameworks are appropriate. There is no overarching strategy to consider how materials contribute to and are relevant to the implementation of the national standards and frameworks. The company’s information management, framework to guide decision-making about the contents of its collection of training, guidance and information resources, guidance for stakeholders other than teachers and school leaders, and clarity of its role in respect to early childhood teachers, could be improved.
11. AITSL’s measurement, monitoring, evaluation and reporting on national standards and frameworks is largely effective. An effective assurance approach for all agreed national standards and frameworks has not been established. AITSL executes the assurance role it has been afforded in initial teacher education (ITE) effectively. AITSL’s measurement, monitoring, evaluation and reporting does not occur across all national standards and frameworks. As a consequence, AITSL is not able to determine whether national standards and frameworks are having the intended impact on the quality of teaching and school leadership in Australia. AITSL’s reporting obligations to the Department of Education could be improved.
Supporting findings
Governance
12. AITSL does not have a strategic planning framework which documents the interactions between the AITSL Constitution, corporate plan, annual work plan, priorities given by education ministers, and its approach to providing strategic advice to ministers. The company uses its internal annual work plan to manage its business. This plan incorporates streams of work from different funding sources, is updated in response to significant changes in work allocation, and is approved by the Minister for Education as the representative of the sole member of the company. Detailed planning about how work is to be undertaken is on a project-by-project basis, in accordance with AITSL’s Project Management Framework. In the absence of a framework that articulates the relationship between its planning documents, the AITSL Board lacks a basis to consider how new work will relate to the company’s existing priorities. (See paragraphs 2.4 to 2.15)
13. AITSL’s governance framework supports its work on national standards and frameworks through internal reporting arrangements. Project oversight is provided by an Operations Board, supported by a Project Steering Committee, with high-risk projects escalated to the Senior Executive Team. Project information and reporting was provided and considered at an appropriate level, in line with the provisions of the Project Management Framework. (See paragraphs 2.16 to 2.18)
14. AITSL‘s identification and management of risk is fit-for-purpose. The company has established an enterprise risk management policy, framework, and guide, as well as project risk identification and escalation procedures. These arrangements are being used to support AITSL’s work on national standards and frameworks. (See paragraphs 2.19 to 2.28)
15. AITSL’s arrangements for incorporating expert advice into decision-making about national standards and frameworks are generally sound and could be improved by providing information to expert standing committees about how their advice has been used. Of the expert standing committee agenda items relevant to national standards and frameworks, eight (19 per cent) School Leadership and Teaching Expert Standing Committee items and 14 (31 per cent) Teacher Education Expert Standing Committee items resulted in agreed actions. Other mechanisms for AITSL to access expertise, such as advisory bodies and procurement, are well-utilised. The Department of Education’s support for assessing the collective expertise of the Board to support appointments could be improved. (See paragraphs 2.29 to 2.45)
Developing, revising and supporting the implementation of national standards and frameworks
16. AITSL does not have an enterprise-wide consultation strategy or framework. The company’s approach to stakeholder engagement includes five standing stakeholder forums (four of which it convenes), project-specific engagement under its Project Management Framework, a stakeholder engagement survey, and other activities such as senior executive meetings and presentations. The company provides little written guidance for project managers about how engagement should be conducted. Project-specific consultations were largely consistent with better practice guidance in the APS Framework for Engagement and Participation standards. (See paragraphs 3.3 to 3.20)
17. As of December 2023, AITSL provides training, guidance and information to support the implementation of national standards and frameworks via six training courses and 774 digital tools and resources. These materials are appropriate in that they are well aligned to the national standards and frameworks and provide detailed and practical guidance on implementation. AITSL does not have an overarching strategy to consider how materials contribute to and are relevant to the implementation of the national standards and frameworks. (See paragraphs 3.21 to 3.32)
Measurement, monitoring, evaluation, and reporting
18. Education ministers have endorsed national quality assurance arrangements, which afford AITSL a role, in respect to initial teacher education (ITE) program accreditation. AITSL’s quality assurance arrangements for ITE are effective, but efforts to build on these have been limited. An effective approach to gain assurance about the ongoing currency and effectiveness of all agreed national standards and frameworks has not been established. There could be benefit to AITSL and education ministers having more information about the implementation of all national standards and frameworks to inform the need for and priority of revisions, especially the Australian Professional Standards for Teachers and Framework for Teacher Registration in Australia. (See paragraphs 4.2 to 4.12)
19. AITSL has established arrangements to measure, evaluate and report on its work on national standards and frameworks. Its performance measures are aligned with its purpose but performance information is not presented to allow readers to understand its limitations, or performance over time. The company can demonstrate the value of its work in most areas via evaluation, although reports and responses are of variable quality. The company has adhered to its reporting obligations since 2020–21 in all but one instance. (See paragraphs 4.13 to 4.36)
Recommendations
Recommendation no. 1
Paragraph 2.34
The Department of Education ensure briefing to its minister supports the minister’s consideration of the collective expertise of prospective Australian Institute for Teaching and School Leadership Board of Directors appointments.
Department of Education response: Agreed.
Recommendation no. 2
Paragraph 3.19
The Australian Institute for Teaching and School Leadership clearly document its approach to stakeholder engagement, including:
- its stakeholder engagement strategy; and
- guidance for project managers on planning, record keeping, documenting changes to plans during implementation, and providing feedback to stakeholders about how their input has been used.
Australian Institute for Teaching and School Leadership response: Agreed.
Recommendation no. 3
Paragraph 4.11
The Australian Institute for Teaching and School Leadership lead work to advise education ministers of the need for governments to develop an agreed approach and implementation plan to:
- regularly review national standards and frameworks;
- assure the currency and effectiveness of all currently agreed national standards and frameworks;
- provide reports resulting from this work to education ministers for consideration; and
- publish reports resulting from this work.
Australian Institute for Teaching and School Leadership response: Agreed.
Recommendation no. 4
Paragraph 4.23
The Australian Institute for Teaching and School Leadership review the company’s performance measures with particular attention to diversifying sources of performance information, and ensuring the outcomes of the company’s work are captured.
Australian Institute for Teaching and School Leadership response: Agreed.
Summary of entity response
20. The proposed audit report was provided to AITSL and an extract was provided to the Department of Education. The entities’ summary responses are reproduced below. Their full responses are included at Appendix 1. Improvements observed by the ANAO during the course of this audit are listed at Appendix 2.
Australian Institute for Teaching and School Leadership
AITSL welcomes the report of the ANAO performance audit, including its finding that the company’s administration of national standards and frameworks is largely effective, as well as its largely positive assessments against the high-level audit criteria. AITSL accepts all three recommendations to the company outlined in the report, and AITSL Management will commence work to implement these within the company’s relevant authorising and implementation environments.
AITSL will develop a stakeholder engagement strategy and improve written guidance for project managers, mainly by codifying existing effective practices and applying these consistently across all projects. AITSL will bring forward advice to education ministers on the development of an agreed approach and implementation plan to regularly review and assure the currency of national frameworks, subject to ministers’ agreement to an appropriate authorising environment and resourcing for this work. AITSL is currently reviewing its performance measures to better address the company’s intended impact and the outcomes of its work, as well as diversifying its sources of performance information.
AITSL also notes the opportunities for improvement as outlined in the report. AITSL Management will consider how they might be addressed within the company’s context. AITSL thanks the audit team for their engagement throughout the performance audit.
Department of Education
The Department of Education welcomes this report’s focus on AITSL’s role in administering National Standards and Frameworks.
As highlighted, the department plays a role in supporting AITSL in these responsibilities, primarily through advice provided to the Minister for Education that ensures the AITSL board possesses appropriate skills and expertise.
The department meets its formal obligations in this regard and agrees with the audit’s findings that it would be appropriate for the Minister to be provided with advice on the collective expertise of the board members when asked to consider new appointments. The department undertakes to ensure that future ministerial briefings on potential appointments include a skills matrix of all board members.
The department will also take action in relation to the audit’s suggested ‘opportunity for improvement’ by ensuring that future grant agreements require AITSL to provide a more detailed breakdown showing where expenditure will be allocated, and tracking this as the project progresses.
The department commits to requiring AITSL deliver more consistent and transparent reports and will provide guidance regarding its expectations.
Key messages from this audit for all Australian Government entities
21. Below is a summary of key messages, including instances of good practice, which have been identified in this audit and may be relevant for the operations of other Australian Government entities.
Group title
Governance and risk management
Key learning reference
Group title
Policy/program design
Key learning reference