Currently showing reports relevant to the Finance and Public Administration Senate estimates committee. [Remove filter]

Type: Performance audit
Report number: 5 of 2024-25
Portfolios: Home Affairs; Prime Minister and Cabinet
Entities: Department of the Prime Minister and Cabinet; National Emergency Management Agency
Date tabled:
Audit Summary : show

Summary and recommendations

Background

1. The Australian Government Crisis Management Framework (AGCMF) outlines the Australian Government’s approach to preparing for, responding to, and recovering from crisis.1 The AGCMF describes an ‘all-hazards’ approach that includes mitigation, planning, and assisting states and territories to manage emergencies resulting from natural events.2

2. The AGCMF has been used to respond to a variety of crises between 2020 and 2023 including:

  • the COVID-19 pandemic;
  • natural disasters such as prolonged flood events across Australia and tropical cyclone events;
  • cyber security incidents including data breaches involving Medibank and Latitude Financial, and the security breach affecting the email gateway system supporting some ACT Government systems; and
  • the Turkiye and Syria earthquake for which the Australian Government committed humanitarian assistance.

3. In March 2023, government agreed to conduct a review of the AGCMF. The Department of the Prime Minister & Cabinet (PM&C) conducted this review. Following the 2023 AGCMF Review, a revised AGCMF was released at the 2024–25 Higher Risk Weather Season National Preparedness Summit in Canberra on 18–19 September 2024.3

Rationale for undertaking the audit

4. The AGCMF is the basis for the Australian Government’s response to crises including pandemics, natural disasters, terrorism, and cyber incidents. This audit provides assurance to the Parliament on whether Australian Government entities have identified and applied lessons from crises between 2020 and 2023, including the COVID-19 pandemic, to the AGCMF in preparation for future severe to catastrophic crises.

5. In its report on the Department of Foreign Affairs and Trade’s crisis management approaches, the Joint Committee of Public Accounts and Audit (JCPAA) recommended that the Auditor-General consider undertaking a performance audit of the AGCMF, and include within the audit scope whether the updated framework adequately reflects lessons learned from the COVID-19 pandemic.4 The JCPAA also identified an audit of the AGCMF as an audit priority of the Parliament in 2022–23.

Audit objective and criteria

6. The audit objective was to assess whether the Australian Government has established an appropriate framework for responding to crises.

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

  • Has the readiness of systems and processes to respond to crises been assessed?
  • Is the AGCMF fit for purpose to respond to a changing threat environment?

8. The audit examined whole-of-government crisis coordination arrangements established through seven versions of the AGCMF between 2020 and 2023, and the 2023 review of the AGCMF undertaken by PM&C. The audit focussed on whole-of-government crisis coordination arrangements between 2020 and 2023 including the supporting mechanisms to convene key committees under the AGCMF.

9. The audit did not examine:

  • the application of the framework to the response to the COVID-19 pandemic or other crises;
  • the adherence to individual national plans required under the AGCMF;
  • agency specific crisis coordination arrangements; or
  • operational responses to crises.

Conclusion

10. In establishing the revised AGCMF, PM&C has developed a largely appropriate framework for responding to crises. The revised AGCMF incorporates lessons from prior crises and provides increased guidance for all-hazards responses, including complex and concurrent crises. The increased oversight and additional continuous improvement activities established in the revised AGCMF will be important to ensure the framework remains appropriate for responding to crises over time as threats and the environment continue to evolve. The revised AGCMF represents a shift in approach from previous versions of the AGCMF and will require sustained effort to build and maintain appropriate capability.

11. A structured assessment of the readiness of systems and processes contained in the AGCMF was not undertaken prior to the 2023 Review. Updates to the AGCMF during 2020 to 2023 were administrative in nature and reflected changes that had already been operationalised. The roles and responsibilities set out under previous versions of the AGCMF were not clearly defined. The 2023 AGCMF Review was guided by a project plan which captured evidence from a range of inputs including comprehensive stakeholder engagement and testing of recommendations and proposed actions. Clarifying arrangements for annual updates and future comprehensive reviews is important to ensure these activities adequately capture and address required changes in a timely manner. The lessons management capability and associated processes are evolving. Formal lessons activities are not conducted for all crises. Thresholds for conducting a lessons process had not been defined or documented prior to 2024.

12. The revised AGCMF released in September 2024 incorporates an increased emphasis on continuous improvement and improved oversight. These amendments, if effectively implemented, should position the framework to respond to a changing threat environment. Activities that informed the 2023 AGCMF Review, such as ‘futures workshops’, would provide value to the framework into the future as they provide an opportunity to examine whether the framework is strategically positioned to adapt to the future. The revised AGCMF introduces several new roles. The responsibilities of these roles are largely clear. Until 2024, there has been a lack of oversight over national level plans to ensure they are reviewed and updated. The annual national exercise program conducted by the National Emergency Management Agency (NEMA) has primarily focussed on natural disaster scenarios. Compounding non-natural disaster specific impacts are now being integrated into natural disaster scenario-based exercises within the program. There is scope to improve the transparency and currency of national plans and risk planning in relation to shared risks and key management personnel risks.

Supporting findings

Readiness of systems and processes

13. Within the AGCMF, specific hazards are identified with lead ministers and entities assigned to these hazards. The emergence of newly identified hazards has led to updates in the AGCMF. Space weather events were added as a specific hazard as they were identified as posing a risk to critical infrastructure. Cyber incidents were added as a specified hazard following a review of crises that indicated roles and responsibilities were not clearly defined. Under previous versions of the AGCMF, triggers and thresholds for activation of whole-of-government crisis coordination were broad and did not provide clear guidance to entities. There are multiple mechanisms that support crisis coordination and response. Some of these mechanisms were not defined in the AGCMF. The role and interactions between various crisis mechanisms could have been more clearly defined. The National Coordination Mechanism (NCM) was introduced as a means to provide broader engagement than previously existing arrangements. The NCM was embedded in the AGCMF after it became a regularly used mechanism during the COVID-19 pandemic response. (See paragraphs 2.3 to 2.33)

14. Updates undertaken annually between 2020 and 2023 were largely limited to documenting machinery of government changes. These updates varied in the approach and stakeholder engagement. There was no engagement with states and territories as part of the administrative updates in 2020, the second update in 2021 or 2022. More significant comments relating to the framework were held over in anticipation of a future review, which was conducted in 2023. The 2023 AGCMF Review had not been approved at the time. The approach to the 2023 AGCMF Review was guided by a project plan which captured evidence from a range of inputs including comprehensive stakeholder engagement and testing of recommendations and proposed actions. There are minor gaps in documentation relating to the analysis of some of this evidence base. Lessons management, including a lessons management capability, to inform continuous improvement activities is evolving. (See paragraphs 2.34 to 2.79)

15. There are gaps in lesson management at the whole-of-government level. As the lessons management capability matures, implementation of actions to address identified lessons is improving. During crises between 2019 and 2023, an APS Surge Reserve was established from lessons relating to capability across the APS. While intended to provide additional personnel capacity in the event of a crisis, the APS Surge Reserve provides staff with generalist skills. The 2023 AGCMF Review identified a gap in suitably qualified staff for crisis management roles. NEMA has sought opportunities to utilise the Centres for National Resilience for certain crises, however, an agreement to utilise Department of Finance managed centres has not yet been established. NEMA has established the National Emergency Management Stockpile to enable the rapid deployment of resources. (See paragraphs 2.80 to 2.97)

Responding to a changing threat environment

16. Risk assessments do not include potential key management personnel risks. The 2023 ACGMF Review incorporated strategic risk consideration including future scenario planning which had not previously been conducted. The Crisis Appreciation and Strategic Planning (CASP) methodology has been embedded in NEMA’s approach to operational response activities, however, the methodology has not yet been established as a consistent planning tool across the range of entities involved in crisis management, or in horizon scanning activities to detect emerging threats. When fully embedded, the CASP methodology has the potential to provide a robust approach to planning and preparedness as well as recovery. (See paragraphs 3.3 to 3.37)

17. The revised AGCMF provides increased clarity on roles and responsibilities. This includes introduction of a tiered crisis coordination model intended to provide greater flexibility as crises evolve. The revised AGCMF groups key information relating to roles and responsibilities together for an easier read. The Handbook provides additional guidance to senior officials. The revised AGCMF has largely addressed feedback obtained during the 2023 AGCMF Review to improve the clarity of the arrangements for the available crisis mechanisms. PM&C have identified ongoing activities are required to support the implementation of the revised AGCMF including by improving capability. (See paragraphs 3.38 to 3.67)

18. Previous versions of the AGCMF did not establish oversight arrangements for the full suite of national level plans to ensure they are reviewed and updated to respond to future events. The September 2024 version of the AGCMF establishes oversight arrangements. As at July 2024, thirty-two per cent of the publicly available plans have not been updated in the last three years. (See paragraphs 3.68 to 3.80)

19. NEMA delivers two annual national-level exercises primarily focussed on multi-jurisdictional natural disasters. Since 2022 compounding non-natural disaster specific impacts such as mass power outages and supply chain issues have been included in NEMA led exercises. Prior to 2024, there were gaps in the arrangements to identify and prioritise whole-of-government exercises. There are limitations with arrangements to capture information relating to exercises led by other entities, reducing the ability to advise government on the preparedness of Australian Government entities to response to crises. The expanded role of the Crisis Arrangements Committee under the revised AGCMF provides coverage of these gaps. Higher Risk Weather Season (HRWS) preparedness has evolved with the addition of ministerial exercises and the HRWS National Preparedness Summit. (See paragraphs 3.81 to 3.111)

Recommendations

Recommendation no. 1

Paragraph 2.44

The Department of the Prime Minister and Cabinet:

  • document a process for annual administrative updates that provides a consistent approach including ensuring appropriate records of engagement and input are maintained; and
  • ensure significant issues are documented to be considered in comprehensive reviews of the AGCMF.

Department of the Prime Minister and Cabinet response: Agreed.

Recommendation no. 2

Paragraph 2.75

The Department of the Prime Minister and Cabinet:

  • provide stronger guidance to entities in their development and updating of entity level and relevant national level crisis management policies and plans; and
  • provide a formal response to the Joint Committee of Public Accounts and Audit that outlines actions taken to address recommendation three from Report 494: Inquiry into the Department of Foreign Affairs and Trade’s crisis management arrangements.

Department of the Prime Minister and Cabinet response: Agreed.

Recommendation no. 3

Paragraph 3.23

The Department of the Prime Minister and Cabinet embed arrangements for future scenario planning into ongoing review and update arrangements for the AGCMF. These should be appropriately documented to ensure lessons are captured and can be learned.

Department of the Prime Minister and Cabinet response: Agreed.

Recommendation no. 4

Paragraph 3.79

The Department of the Prime Minister and Cabinet include in the Australian Government Crisis Management Handbook criteria for the publication of plans to appropriately inform stakeholders of crisis arrangements.

Department of the Prime Minister and Cabinet response: Agreed.

Recommendation no. 5

Paragraph 3.97

The National Emergency Management Agency document its consideration of Crisis Arrangements Committee advice on gaps and priorities for whole-of-government exercising, as well as the annual analysis undertaken to review and update the list of identified hazards under AGCMF, to inform the development of the annual national exercise program. This should include ensuring that exercises consider both natural and all-hazard scenarios.

National Emergency Management Agency response: Agreed.

Summary of entity responses

20. The proposed audit report was provided to the Department of the Prime Minister and Cabinet and the National Emergency Management Agency. Letters of response provided by each entity are included at Appendix 1. The summary responses provided are included below. The improvements observed by the ANAO during the course of this audit are at Appendix 2.

Department of the Prime Minister and Cabinet

The Department of the Prime Minister and Cabinet (PM&C) welcomes the proposed report on the Australian Government Crisis Management Framework (AGCMF). PM&C accepts the key findings and recommendations, and has commenced steps to address these matters.

PM&C is committed to strengthening the Australian Government’s crisis management arrangements and preparedness in partnership with other Australian Government agencies. It has undertaken a comprehensive review of the AGCMF, resulting in the development of a new and enhanced Framework, supporting Handbook and more robust continuous improvement processes. It will continue to enhance guidance under these products to guide the publication of plans, assessment of staffing capacities and the development of surge arrangements.

PM&C will also continue to work other relevant agencies, including the National Emergency Management Agency (NEMA), to enhance guidance on national planning and preparedness activities, including human rights considerations and consider options to clarify crisis responsibilities following machinery of government changes. It will establish improved guidance and repeatable processes for the annual review of the AGCMF, as well as for future comprehensive reviews, to ensure lessons from future scenario planning and exercises are captured. PM&C will also assess its senior staffing capacities in the context of crisis response.

National Emergency Management Agency

The National Emergency Management Agency (NEMA) welcomes the findings of the ANAO Performance Audit of the Australian Government Crisis Management Framework (AGCMF) and is committed to preparing Australia for all hazard crisis events, now and into the future. The Performance Audit complements the recent review of the AGCMF. NEMA will continue to work with the Department of the Prime Minister and Cabinet (PM&C), the Australian Government, jurisdictions, industry and non-government organisations for continuous improvement in crisis management preparedness.

NEMA will work with PM&C to ensure whole-of-government crisis exercising aligns to the priorities identified by the Crisis Arrangements Committee, including consideration of natural and all-hazard impacts and consequences.

Acknowledging the current and future risk of consecutive, compounding and concurrent crises, NEMA will continue building crisis capability within the agency and across the Australian Government. NEMA will work alongside PM&C to assess crisis workforce planning needs and increase crisis workforce capability.

NEMA is committed to building the Australian Government’s strategic crisis planning capability through the Crisis Appreciation and Strategic Planning (CASP) methodology. We will continue to support a nationally-consistent approach to planning and preparedness activities through CASP, ensuring Australians and their communities are supported before, during and after crisis events.

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
  • Crises require rapid responses. Preparedness for crisis response should occur in a non-crisis setting and requires robust planning informed by risk assessments. Testing and exercising helps to ensure that roles and responsibilities are clearly defined and understood. These mechanisms also help to ensure that entities can implement relevant plans quickly and, where multiple stakeholders are involved, in a coordinated manner. Regular evaluation of preparedness, including risk reviews to identify new and emerging risks and threats and allow for minor course corrections over time, rather than requiring a significant shift without sufficient testing.
  • As crises become more complex, concurrent, and cut across multiple sectors, the breadth of consequences increases, and more stakeholders are involved. This necessitates a governance structure where roles and responsibilities are clearly articulated.
Group title

Records management

Key learning reference
  • In a sector where senior officers and key personnel change, well established lessons processes that include sound records are important to communicate reasons behind changes. This is to ensure that their importance is clear to future decision-makers and prior mistakes are not repeated.
Type: Performance audit
Report number: 43 of 2023-24
Portfolios: Prime Minister and Cabinet
Entities: Australian Public Service Commission
Date tabled:
Audit Summary : show

Summary and recommendations

Background

1. The Australian Public Service (APS) is established by the Public Service Act 1999 (PS Act). It is one part of the wider Commonwealth public sector and consists of agency heads and APS employees engaged under the PS Act.1 The APS operates largely under principles-based frameworks, including that established by the PS Act, which impose high expectations regarding integrity.

2. Members of the APS are subject to integrity obligations specified in the PS Act, including the APS Values2 and APS Code of Conduct.3 At 5 April 2024 the PS Act specified five APS Values — committed to service, ethical, respectful, accountable and impartial.4 The APS Code of Conduct has 13 requirements relating to: behaving honestly and with integrity in connection with APS employment; acting with care and diligence; treating people with respect and courtesy; complying with all applicable Australian laws; complying with any lawful and reasonable direction; maintaining confidentiality; avoiding conflicts of interest and disclosing material personal interests; proper use of resources; not providing false or misleading information; not misusing power or authority; upholding the APS values; upholding the integrity and good reputation of the agency and the APS; and upholding the good reputation of Australia when overseas.

3. Under the PS Act, further integrity obligations apply to agency heads5 and members of the Senior Executive Service (SES)6, which comprise the senior cadre of the APS.

4. The Public Governance, Performance and Accountability Act 2013 (PGPA Act) establishes the overarching governance, performance and accountability framework for resource use and management within the Commonwealth public sector as a whole, including all members of the APS. It is a principles-based framework that imposes high expectations on the sector, including ‘high standards of governance, performance and accountability’.7

5. The PGPA Act contains ‘general duties of officials’ applying to both the accountable authority of the PGPA entity8 and entity officials. The general duties relate to: acting with care and diligence; acting honestly, in good faith and for a proper purpose; not misusing one’s position; the proper use of information; and disclosing interests.9 Taken together, the general duties establish an overarching framework for integrity, probity and ethical behaviour applying to the accountable authorities and officials of all PGPA Act entities, including all members of the APS.

6. There are also ‘general duties of accountable authorities’ applying to the accountable authority of a PGPA entity. These include the duty to govern the entity in a way that promotes the proper use and management of public resources for which the accountable authority is responsible.10

7. The office of Australian Public Service Commissioner (Commissioner) is established under the PS Act.11 The Commissioner’s functions are set out in section 41 of the PS Act and include the following functions considered in this audit.

  • To uphold high standards of integrity and conduct in the APS.12
  • To promote the APS Values, the APS Employment Principles and the Code of Conduct.13
  • To evaluate the extent to which Agencies incorporate and uphold the APS Values and the APS Employment Principles.14
  • To partner with Secretaries in the stewardship of the APS.15
  • To provide advice and assistance to Agencies on public service matters.16
  • To evaluate the adequacy of systems and procedures in Agencies for ensuring compliance with the Code of Conduct.17

8. The Commissioner and APS employees assisting the Commissioner together constitute a statutory agency under the PS Act, known as the Australian Public Service Commission (APSC).18 In 2022–23 the departmental expenses of the APSC were $80.8 million.19 At 30 June 2023, the APSC had 373 employees.20

9. Within the Commonwealth public sector, which includes the APS, there is both collective and individual responsibility for maintaining integrity, probity and ethical conduct — shared by framework policy owners, the heads of public sector organisations, and their personnel.

10. Framework policy owners establish the rules of operation in key areas and then largely rely on the accountable authorities of PGPA Act entities and the agency heads of APS agencies to be responsible for culture and compliance within public sector organisations. In that respect the frameworks are devolved and largely self-regulating. Under the principles-based approach, mandatory rules are largely set to control actions where risks are deemed highest. Key policy owners include the Department of Finance for the PGPA Act framework and the APSC for the PS Act integrity framework.21

11. The role of policy owners in maintaining a culture of integrity in the sector, including respect for the rule of law, has been a focus of recent reviews, initiatives and investigations relating to the APS and its performance. These have included the following.22

  • The 2019 Independent review of the APS (Thodey review) and 2022 government APS reform agenda intended to build on the Thodey review.
  • The 2023 Royal Commission into the Robodebt Scheme (Royal Commission), government response to the Royal Commission recommendations, and 16 Code of Conduct processes resulting from the Royal Commission.
  • The 2023 APS Integrity Action Plan intended to address the 2022 government APS reform agenda and 2023 Royal Commission findings.
  • The 2023 Code of Conduct inquiry and termination of a departmental secretary.

Rationale for undertaking the audit

12. The Australian Parliament has provided, in the PS Act, that all members of the APS are subject to the integrity, probity and ethical obligations specified in the Act. The Parliament has also provided that one of the three broad functions of the Commissioner under the Act is ‘to uphold high standards of integrity and conduct in the APS’.23 The function of upholding APS integrity standards occurs in a changing and often dynamic operating environment, which in recent years has featured the following.

  • Reviews, initiatives and investigations, which have often focused on perceived shortcomings in upholding APS integrity, probity and ethics, including at the highest levels of APS leadership and the Secretaries Board.
  • Australian Government statements that the Royal Commission Robodebt Scheme identified ‘serious failings within the Australian Public Service’.24 The APSC has stated that ‘Rebuilding trust in the APS is a priority’25 and that this process includes ‘reinforcing a culture with integrity at its core’.26
  • Leadership change at the top of the APS, with 69 per cent turnover of departmental secretaries between July 2022 and December 2023.27
  • Growth in APS employment. The APSC reported in March 2024 that at 31 December 2023 the APS headcount was 177,442, a 9.9 per cent increase since December 2022.28
  • Establishment of the National Anti-Corruption Commission to: detect, investigate and report on serious or systemic corruption in the Commonwealth public sector; and educate the sector and the public about corruption risks and prevention.29

13. There is ongoing parliamentary interest in APS integrity, probity and ethics, including by the Joint Committee of Public Accounts and Audit (JCPAA), which in June 2023 adopted an inquiry into probity and ethics in the Australian public sector. This audit provides independent assurance and reporting to the Parliament on the APSC’s administration of statutory functions relating to upholding high standards of integrity and ethical conduct in the APS.

Audit objective, criteria and scope

14. The audit objective was to assess the effectiveness of the APSC’s administration of statutory functions relating to upholding high standards of integrity and ethical conduct in the APS.

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

  • Has the APSC effectively promoted the APS Values and Code of Conduct?
  • Has the APSC effectively monitored and evaluated agencies’ implementation of the APS Values and Code of Conduct?
  • Has the APSC effectively contributed to stewardship of the APS?

16. The ANAO reviewed the APSC’s administration for the period July 2022 to December 2023.

Conclusion

17. The APSC was partly effective in its administration of statutory functions relating to upholding high standards of integrity and ethical conduct in the APS during the audit review period (July 2022 to December 2023). The APSC’s approach was largely activity-driven and it did not have relevant strategies, linked to measurable outcomes, to guide its efforts. As a consequence, the APSC could not demonstrate or provide assurance on whether its activities relating to integrity functions were well directed or fully effective. In the context of an operating environment focused on perceived shortcomings in APS integrity, the APSC was in the process of developing a more strategic approach.

18. The APSC was partly effective in promoting the APS Values and Code of Conduct and in providing advice and assistance to APS agencies on public service matters. The APSC did not have a strategy, linked to outcomes which can be measured, for promoting the APS Values and Code of Conduct and its approach to this function was largely activity-driven. While the APSC communicated integrity and ethical requirements and expectations through a variety of activities, including training and guidance, they were not guided by a risk-based strategy. APSC guidance was revised or new guidance issued, to manage identified risks and issues, without reference to a forward engagement strategy. The APSC had limited arrangements in place to provide assurance to the Commissioner and Parliament that it had effectively promoted the APS Values and Code of Conduct.

19. The APSC did not have a sound basis for monitoring and evaluating the extent to which agencies incorporate and uphold the APS Values, or the adequacy of systems and procedures in agencies to ensure compliance with the Code of Conduct. There was no mechanism to provide assurance or insight to the Commissioner or the Parliament on agencies’ implementation of the APS Values and Code of Conduct.

20. The APSC did not have a documented strategy or plan to support the Commissioner’s functions relating to stewardship and partnering with secretaries or agency heads. The APSC did not clearly articulate the stewardship concept appearing since 2013 in the PS Act and did not measure its effectiveness in administering the stewardship function. The APSC’s approach to the stewardship function was largely activity-driven, and it contributed to or led a range of APS improvement initiatives, including with the Secretaries Board.

Supporting findings

Promote, advise and assist

21. The APSC did not have a strategy, linked to outcomes which, can be measured, for promoting the APS Values and Code of Conduct during the audit review period and its approach to this function was largely activity-driven. The APSC had two strategies with components relating to the promotion of integrity, ethics and the APS Values and Code of Conduct — an APS Workforce Strategy and APS Academy Engagement and Communication strategy. These two strategies, when read together, do not equate to a strategy for promoting the APS Values and Code of Conduct.

22. The APSC provided or administered guidance, support and training/event offerings intended to promote the APS Values and Code of Conduct. While the APSC communicated integrity and ethical requirements and expectations through these activities, they were not guided by a risk-based strategy.

23. The APSC had limited arrangements in place to provide assurance to the Commissioner and Parliament that it had effectively promoted the APS Values and Code of Conduct. Data collection and feedback received on APSC training and guidance did not link to a structured approach to assessing whether the APSC’s activities to ‘promote’ were achieving their intended purpose. There was no record of the APSC’s most senior internal committees — the Executive Board and Executive Committee — discussing issues relating to the APS Values during the audit review period. Issues relating to the APS Code of Conduct were discussed at 13 per cent of Executive Board meetings and five per cent of Executive Committee meetings. More generally, there were deficiencies in the APSC’s record keeping arrangements for its governance committees.

24. The enterprise-level risks documented in the APSC’s enterprise risk register did not directly relate to the APSC’s delivery of its statutory functions relating to the APS Values, Code of Conduct or integrity. This was in the context of an operating environment which featured ongoing scrutiny of perceived shortcomings in upholding APS integrity, including at the highest levels of APS leadership. (See paragraphs 2.4 to 2.96)

25. The ANAO reviewed six APSC mechanisms in operation during the audit review period to provide advice and assistance to APS agencies on public service matters: the Integrity Agencies Group (IAG); the Ethics Advisory Service (EAS); Ethics Contact Officer network (ECOnet); Cross-agency Code of Conduct Practitioners’ Forum (conduct forum); APS Agency Survey (agency survey); and consultation and advice on suspected breaches of the APS Code of Conduct.

26. The IAG offers opportunities for information-sharing amongst participants. The EAS received 684 enquiries during the audit review period. The APSC is not able to demonstrate what advice or assistance it provided on public service matters to the agencies represented at meetings of ECOnet or the conduct forum.

27. The APSC used the 2021 agency survey results to develop its Integrity Metrics Resource, which was released in 2022. If used by agencies, it provides a basis to focus their efforts to lift integrity measurement, monitoring and reporting.

28. During the audit review period, APSC guidance was revised or new guidance issued, to manage identified risks and issues, without reference to a forward engagement strategy. The APSC issued timely guidance and advice for APS agency heads in 2023, relating to the management of Code of Conduct reviews following the report of the Royal Commission Robodebt Scheme. (See paragraphs 2.97 to 2.147)

Evaluate

29. The APSC did not have fit-for-purpose arrangements to evaluate the extent to which agencies incorporate and uphold the APS Values, or a documented strategy linked to outcomes which could be measured.

30. The APSC collected information from several mechanisms and activities to inform its understanding of issues and developments in the APS and which may influence its thinking, actions and priorities. It has not leveraged the data and insights gained from its various activities to evaluate the extent to which agencies incorporate and uphold the APS Values. This does not provide the Commissioner or Parliament with broader insight or assurance on the extent to which agencies uphold the APS Values.

31. A capability review conducted in 2023 assessed the APSC as having a maturity rating of ‘developing’ in respect to ‘Review and evaluation’. The APSC advised the ANAO in November 2023 that it has begun work to systematise its use of data to observe patterns or areas of concern for agencies. (See paragraphs 3.43 to 3.44)

32. The APSC did not have fit-for-purpose arrangements to evaluate the adequacy of systems and procedures in agencies for ensuring compliance with the Code of Conduct, or a documented strategy linked to outcomes which could be measured.

33. There was no mechanism to provide assurance or insight to the Commissioner or Parliament on the adequacy of systems and procedures in agencies for ensuring compliance with the Code of Conduct. (See paragraphs 3.45 to 3.48)

Stewardship

34. The APSC did not have a documented strategy or plan to support the Commissioner’s functions relating to stewardship and partnering with secretaries or agency heads — including where the Commissioner is independently performing functions under the PS Act — or to measure its effectiveness in administering the Commissioner’s stewardship function.

35. The APSC’s approach to the stewardship function was largely activity-driven, and included: participation in sector-wide boards and committees with integrity-related roles or functions, such as the Secretaries Board; briefing and induction activity for new secretaries and other agency heads; engaging with APS agency heads on SES Code of Conduct matters; providing advice and guidance on integrity issues; and involvement in SES recruitment and talent management activities.

36. The APSC has undertaken planning relating to the addition of ‘stewardship’ as a sixth APS Value in the PS Act. The Public Service Amendment Bill 2023 received royal assent on 11 June 2024 and is now known as the Public Service Amendment Act 2024. (See paragraphs 4.3 to 4.34)

Recommendations

37. This report makes four recommendations to the Australian Public Service Commission.

Recommendation no. 1

Paragraph 2.30

The Australian Public Service Commission develop a strategy to document and guide its objectives, key activities, relationships with key stakeholders, and desired outcomes relating to the statutory function to ‘promote’ the APS Values and Code of Conduct set out in paragraph 41(2)(e) of the Public Service Act 1999.

Australian Public Service Commission response: Agreed.

Recommendation no. 2

Paragraph 2.80

The Australian Public Service Commission develop and implement an evaluation strategy for its integrity training to determine if its suite of integrity training is achieving the intended outcomes.

Australian Public Service Commission response: Agreed.

Recommendation no. 3

Paragraph 2.86

The Australian Public Service Commission should review record keeping arrangements for its governance committees.

Australian Public Service Commission response: Agreed.

Recommendation no. 4

Paragraph 3.40

The Australian Public Service Commission develop an evaluation strategy and review its current evaluation methodology to improve the level of assurance provided to the Commissioner and Parliament on whether agencies incorporate and uphold the APS Values, and the adequacy of agencies’ systems and procedures for ensuring compliance with the APS Code of Conduct.

Australian Public Service Commission response: Agreed.

Summary of entity response

38. The proposed final performance audit report was provided to the APSC. The summary response from the APSC is provided below and the full response is at Appendix 1. Improvements observed by the ANAO during the audit are at Appendix 2.

Australian Public Service Commission

The Commission welcomes the observations of the ANAO in this report, and agrees with the four recommendations and intent of the opportunities for improvement. These recommendations are timely given our ongoing program of work to strengthen the articulation of our purpose, key activities, priorities and performance measures. In addition, actions to address these recommendations will dovetail with work arising from our Capability Review to enhance strategies and tools for data and stakeholder engagement, as well as corporate systems for governance, risk, information management and assurance.

In our stewardship role, we will partner with the Attorney General’s Department to develop an enduring APS Integrity Strategy to articulate a clear narrative for integrity activities and reforms, and to clearly identify the role and actions all agencies and public servants are required to embrace to demonstrate excellence in integrity. In parallel, the Commission will bring together its broad suite of integrity initiatives into an overarching integrity strategy, supporting impact and outcome-focussed evaluation to strengthen assurance over the performance of our legislated functions.

Key messages from this audit for all Australian Government entities

39. 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
  • To achieve intended outcomes, it is important that agencies develop strategies that identify objectives and the planned actions to achieve them. A strategy assists in resource allocation, achieving focus and efficiency in work effort, and provides a framework to monitor and assess progress against objectives.
  • A strategy assists with assessing effectiveness in achieving objectives by establishing clear and measurable performance expectations, identifying the information to be collected for assessment and evaluation purposes, and establishing a framework for progress reporting and evaluation against the documented expectations.
  • Enterprise risk registers are a key tool of effective corporate governance and require active review and adjustment as necessary, having regard to changes in the operating environment.
Group title

Records management

Key learning reference
  • Good record keeping is required by law and supports effective corporate governance, accountability and performance.
Type: Financial statement audit
Report number: 42 of 2023-24
Portfolios: Across Entities
Entities: Across Entities
Date tabled:
Audit Summary : show