Independent Report on the Education Tax Refund Campaign (Phase Three)

To the Treasurer

Introduction

The Government’s Guidelines on Campaign Advertising by Australian Government Departments and Agencies (the Guidelines) state that Government information and advertising campaigns can only be approved for launching by the responsible Minister where:

• the Chief Executive of the agency undertaking the campaign certifies that the campaign complies with the Guidelines and relevant Government policies; and
• for those campaigns with expenditure in excess of $250 000, the Auditor-General provides a report to the Minister responsible for the agency undertaking the campaign as to the proposed campaign’s compliance with the Guidelines.

You were provided with the Auditor-General’s review reports on other elements of the Education Tax Refund Campaign on 20 January 2009, 23 January 2009 and 19 February 2009.

Scope

I have undertaken a review of the Education Tax Refund Campaign (Phase Three), administered by the Australian Taxation Office, to enable me to report on the proposed campaign’s compliance with the Guidelines.

The Guidelines state that campaigns should be instigated only where a need is demonstrated, target recipients are clearly identified and the campaign is based on appropriate research, and require that:

• material should be relevant to government responsibilities;
• material should be presented in an objective, fair and accessible manner;
• material should not be directed at promoting party political interests;
• material should be produced and distributed in an efficient, effective and relevant manner, with due regard to accountability; and
• advertising must comply with legal requirements.

The criteria I have used to make my assessment of the compliance of Education Tax Refund Campaign (Phase Three) with the Guidelines are the matters specified at paragraphs 11 to 24 of the Guidelines published by the Department of Finance and Deregulation in June 2008.

Responsibilities of the Agency

Agencies subject to the Financial Management and Accountability Act 1997 must comply with the Guidelines as a matter of Government policy. The Commissioner of Taxation has certified that the Campaign complies with the Guidelines.

The Auditor’s Responsibility

My responsibility is to express, in this assurance report, an independent conclusion based on my review.

My review is conducted in accordance with the Australian Standard on Assurance Engagements ASAE 3000 Assurance Engagements Other than Audits or Reviews of Historical Financial Information issued by the Australian Auditing and Assurance Standards Board. My review is designed to enable me to obtain sufficient appropriate evidence to form a conclusion whether anything has come to my attention to indicate that the Campaign does not comply, in all material respects, with the Guidelines.

Review methodology

I have conducted the review of the campaign by making such enquiries and performing such procedures as I considered reasonable in the circumstances including:

• an examination of campaign materials including direct mail materials to the recipients of Family Tax Benefit Part A and independent students; a printed advertisement for selected newspapers and national magazines; posters to be made available at local shopping centres; radio scripts; and digital banner shown at several popular web-sites;
• a review of the printed advertisements and radio scripts in languages other than English;
• a review of supporting documents and records relevant to the campaign, including related research, cost benefit analysis and campaign funding approvals;
• interviews with staff of the Australian Taxation Office involved with the preparation of the campaign;
• an assessment of the reasonableness of the judgements made by the Australian Taxation Office against each of the Guidelines; and
• an examination of the certification by the Commissioner of Taxation dated 11 May 2009.

The ANAO review did not extend to an assessment of the general system controls and supporting procedures in place in the Australian Taxation Office to manage its advertising activities, but focussed on matters relating specifically to the Education Tax Refund Campaign (Phase Three). A review of this nature provides less assurance than an audit.

Conclusion

Based on my review described in this report, nothing has come to my attention that causes me to believe that the Education Tax Refund Campaign (Phase Three) does not comply, in all material respects, with the requirements of the Government’s Guidelines on Campaign Advertising by Australian Government Departments and Agencies.

Steve Chapman
Deputy Auditor-General
Canberra, 15 May 2009