Introduction

1. Advertising is an important and legitimate element of government communication and information strategies. Governments use advertising to inform the public about taxpayer funded programs, to explain government policies and to support the establishment and delivery of programs. It provides a mechanism for governments to connect directly with citizens, informing them about new and existing government policies, programs or services, providing advice about their obligations, rights and entitlements, and conveying other important information.

2. While government advertising is a legitimate and accepted element of government communication and information strategies, there have long been concerns that governments may use, or may be perceived to use, taxpayer funds to gain political advantage through the partisan promotion of their views or themselves, rather than to meet the genuine information needs of citizens.¹

3. Earlier ANAO reports² have referred to significant issues with the administration of government advertising in the period prior to the release of updated guidelines on government advertising in 2008³, which established enhanced administrative and certification arrangements informed by recommendations of the Joint Committee of Public Accounts and Audit (JCPAA)⁴ and a Senate inquiry.⁵

4. The enhanced arrangements introduced in 2008 made it clear that campaign development was to be wholly undertaken by the commissioning department or agency, addressing one of the most challenging areas in relation to earlier campaigns, that of achieving clarity in the roles of ministers and their offices on the one hand and agencies on the other.⁶ The 2008 Guidelines provided that campaigns could be approved for launch only when the responsible agency chief executive had certified that the campaign complied with the Guidelines and relevant government policies. For campaigns with expenditure over $250 000 the Auditor-General provided a report to the responsible minister on the proposed campaign’s compliance with the Guidelines, based on a limited assurance approach.⁷ The Government decided in early 2010 to revise the 2008 arrangements by not continuing the Auditor-General’s review role and establishing an Independent Communications Committee (ICC) to provide advice—rather than limited assurance—on compliance to agency chief executives, who would in turn provide a certification to the relevant Minister.⁹ The Auditor-General was requested to undertake performance audits of the administration of government advertising and the ANAO has continued to schedule periodic performance audits in the performance audit program.

5. The potential benefits of, and risks relating to, the administration of government advertising have been acknowledged by the Australian Government—including by the then Cabinet Secretary and Special Minister of State (SMOS), Senator the Hon Joe Ludwig, in the context of releasing in March 2010 the current Guidelines on Information and Advertising Campaigns by Australian Government Departments and Agencies (2010 Guidelines)¹⁰:

Government advertising is a key mechanism through which governments can communicate information directly to the public to explain the impact of changes to existing policies or to inform people of important public initiatives…At the same time, governments have an obligation to establish a framework for delivering this information in a transparent, accountable and fiscally responsible way.¹¹

6. The 2010 Guidelines, combined with certain advertising-specific procurement arrangements¹² and the Australian Government’s financial management requirements,¹³ make up the revised campaign advertising framework applying since March 2010 to all departments and agencies subject to the Financial Management and Accountability Act 1997 (FMA Act).¹⁴

7. The 2010 Guidelines provide that three underlying principles govern the use of public funds for all government information and advertising campaigns:

• members of the public have equal rights to access comprehensive information about government policies, programs and services which affect their entitlements, rights and obligations;
• governments may legitimately use public funds to explain government policies, programs or services, to inform members of the public of their obligations, rights and entitlements, to encourage informed consideration of issues or to change behaviour; and
• government campaigns must not be conducted for party political purposes.

8. The 2010 Guidelines also include five detailed ‘Information and Advertising Campaign Principles’ (the Principles)¹⁶ as a basis for regulating the probity and cost-effectiveness of government campaign advertising; and establish a revised certification process to promote, advise on and document agency compliance with the regulatory framework.

9. As mentioned above, the ICC¹⁷ provides advice to agency chief executives on all advertising campaigns valued at more than $250 000, or where requested to do so by the chief executive.¹⁸ The committee provides advice on compliance with Principles 1 to 4 of the 2010 Guidelines but not on Principle 5, which is considered to relate to a chief executive’s normal responsibilities. Following the receipt of ICC advice, chief executives certify compliance against Principles 1 to 5 and provide the certification to the relevant minister, who may decide to launch the campaign or approve its launch. Publication and reporting requirements are also set out in the 2010 Guidelines, to promote transparency and accountability.¹⁹

10. The 2010 Guidelines make provision for the SMOS to exempt campaigns from their operation on the basis of a national emergency, extreme urgency or other compelling reason²⁰; with one exemption granted since the 2010 Guidelines took effect.²¹ An earlier exemption granted to the Australian Electoral Commission (AEC) under the 2008 Guidelines remained in place following the release of the 2010 Guidelines.²²

11. The Department of Finance and Deregulation (Finance) provides secretariat support to the ICC and advice to agencies on the framework, while the SMOS²³ is responsible for the administration of the campaign advertising framework.

12. While these elements of the revised campaign advertising framework remain in place, it has continued to evolve. In August 2011 Finance advised agencies of a new Peer Review Group modelled on Victorian Government arrangements²⁴ and a revised role for Finance.²⁵ The audit focuses on the campaign advertising framework as it applied from the release of the 2010 Guidelines to the announcement of the Peer Review Group on 3 August 2011.

Audit objectives and scope

Audit objectives

13. The audit objectives were:

• to assess the effectiveness of the revised certification process in promoting compliance of government advertising campaigns (campaigns) with the March 2010 Guidelines on Information and Advertising Campaigns by Australian Government Departments and Agencies (2010 Guidelines);
• to assess the effectiveness of agency administration in developing campaigns and implementing key processes against the requirements of the campaign advertising framework;
• to assess the effectiveness of Finance’s administration of the campaign advertising framework; and
• to assess the effect on campaigns of an exemption from the 2010 Guidelines.

Audit criteria and scope

14. To form a conclusion against the audit objectives, the audit considered:

• the interpretation of the requirements of the 2010 Guidelines, and the provisions for exemptions under the 2010 Guidelines;
• the campaign certification process established under the 2010 Guidelines;
• Finance’s administrative arrangements in support of FMA Act agencies, governance arrangements for the exemption process, and procurement elements associated with advertising campaigns, including the Master Media Agency (MMA) contract;
• for three campaigns, compliance with the requirements of the campaign advertising framework; and
• for two exempt campaigns, whether the campaigns were developed in accordance with the non-exempt elements of the 2010 Guidelines and the applicable elements of the campaign advertising framework.

Selected agencies

15. Four agencies and advertising campaigns were initially selected for review: the Department of Families, Housing, Community Services and Indigenous Affairs (FaHCSIA, Paid Parental Leave Campaign); the Department of Health and Ageing (DoHA, Health Reform Campaign); the Department of the Treasury (Treasury, Tax Reform Campaign); and the Australian Electoral Commission (AEC, 2010 Federal Election Campaign).

16. These agencies were selected as they administered two campaigns subject to the normal provisions of the 2010 Guidelines (the Paid Parental Leave and Health Reform Campaigns) and two campaigns exempted from the certification processes of the Guidelines (the Tax Reform and 2010 Federal Election Campaigns).

17. The audit was extended on 11 August 2011, following a request from the Leader of the Opposition on 29 July 2011, to include the Clean Energy Future Campaign administered by the Department of Climate Change and Energy Efficiency (DCCEE).

Overall conclusion

18. A revised campaign advertising framework (framework) for FMA Act agencies was introduced in 2010 comprising amended guidelines, advertising specific procurement arrangements and the Australian Government’s financial management requirements.

19. As part of the framework, a revised campaign certification process for FMA Act agencies was introduced to promote, advise on, and document agency compliance with the amended guidelines (2010 Guidelines) promulgated on 31 March 2010. The 2010 Guidelines contain five Principles as a basis for regulating the probity and cost-effectiveness of government campaign advertising, and set out reporting requirements to promote transparency and accountability. Through the certification process, agency chief executives receive advice from the Independent Communications Committee (ICC) on the compliance of campaigns over $250 000 with Principles 1 to 4 of the Guidelines, as an input to their own certification against Principles 1 to 5 of the Guidelines. Chief executive certifications are provided to the relevant Minister before campaigns are approved for launch.

20. The audit assessed the effectiveness of the revised certification process in promoting campaign compliance with the 2010 Guidelines; the effectiveness of agency administration in developing campaigns and implementing key processes against the requirements of the framework; and Finance’s administration of the framework.

21. Where it applied²⁶, the revised certification process for FMA Act agencies has been generally effective in promoting compliance with the 2010 Guidelines. The compliance assessments prepared for the ICC by FaHCSIA and DoHA, and the certifications signed-off by those agencies’ chief executives following the receipt of ICC advice, contained reasonable representations of campaign compliance with the Principles in the 2010 Guidelines. Further, the operations of the ICC established a vehicle for discussion and debate between the committee, Finance, FaHCSIA, DoHA and DCCEE on the development, timing and content of agency campaigns and creative materials; a process which informed the ICC’s advice to chief executives on compliance with Principles 1 to 4 of the 2010 Guidelines.²⁷ The practice of agency chief executives certifying campaign compliance has also continued to provide an important discipline on agencies to document compliance with the Principles.

22. In contrast, where a campaign exemption has been granted under the Campaign Guidelines yet the responsible agency was still expected to comply with the ‘intent’ of the Guidelines, as in the case of Treasury and the AEC,²⁸ there was not the same level of discipline evident in the processes of the responsible agencies to demonstrate compliance with those elements of the 2010 Guidelines which had not been exempted.²⁹

23. While the certification process provided a generally effective framework for promoting compliance with the 2010 Guidelines, where it applied, there were aspects of DCCEE’s administration of the Clean Energy Future Campaign that suggested greater discipline could be applied in the implementation of key processes. The audit highlighted scope for improvement in processes for: documenting the source(s) of campaign statements; the giving and recording of financial approvals; signing-off ministerial briefs and record keeping; and procurement practices affecting the capacity of a tender to achieve value for money. Going forward, there is also room for greater emphasis to be given by agencies to the explicit assessment of the overall cost effectiveness of the media buy for campaigns.

24. As the central government department responsible for the administration of the campaign advertising framework, Finance has released key documents in a timely manner³⁰ and has been a source of helpful advice to agencies and the SMOS. Finance has also managed a large volume of often complex inquiries well, and has provided support to agencies through a number of useful resources such as an indicative campaign development timeline and a pro forma document for chief executive certifications. Nevertheless, there would be benefit in Finance reviewing some aspects of its strategy for supporting agencies, and enhancing its reports to Parliament on the campaign advertising framework.

25. There would also be benefit in Finance providing written guidance to agencies on the interpretation of key terms in the 2010 Guidelines, which are drafted in a manner suggesting that a hierarchy of requirements applies, but do not otherwise define or make explicit the meaning of key terms for the benefit of agencies.³¹ Clarity of meaning is particularly important in the context of a regulatory framework relying on formal written certifications.

26. The ANAO has made five recommendations aimed at strengthening the integrity and transparency of the campaign advertising framework within existing policy settings by refining agencies’ systems and processes, the support provided by Finance to agencies, and Finance’s reporting on the framework.

Key findings

27. The ANAO’s assessment of agency administration against the requirements of the campaign advertising framework identified scope for improvement in processes for: documenting the source(s) of campaign statements; assessing the overall cost effectiveness of the media buy for campaigns; giving and recording financial approvals; signing-off ministerial briefs and record keeping; procuring services; and evaluating campaigns. There is also scope for refining aspects of Finance’s administration of the campaign advertising framework and its reporting on the framework.

Campaign statements

28. Principle 2 of the 2010 Guidelines provides that campaign materials should enable the recipients of the information to distinguish between facts, comment, opinion and analysis (paragraph 20) and that where information is presented as a fact, it should be accurate and verifiable (paragraph 21).

29. The certification process for the FaHCSIA, DoHA and DCCEE campaigns was informed by an active process of discussion and debate between the ICC, supported by Finance, and the responsible agencies on campaign compliance with Principle 2. The certification documents mandated in paragraph 14 of the 2010 Guidelines—comprising ICC advice to chief executives on compliance with Principles 1 to 4 of the Guidelines, and chief executive certifications of compliance with Principles 1 to 5 of the Guidelines—were also prepared and signed-off.³²

30. The Government’s Clean Energy Plan was a complex package and DCCEE relied heavily on the work of other agencies, particularly the Treasury, for technical input when developing the Clean Energy Future Campaign. DCCEE established an e-mail process to consult with Treasury on proposed campaign statements relating to its responsibilities, and also prepared a ‘matrix of factual statements and supporting sources’ to document the source of 142 statements appearing in campaign materials.³³ While DCCEE adopted a sound approach in preparing the matrix, the initiative was not well implemented as the department was not able to establish a clear line of sight between 52 statements presented as fact in the campaign and the sources cited in the matrix to support those statements. There were also instances where the sources cited in the matrix did not, on their face, support or lend support to statements presented as fact in campaign materials, and further research and analysis was required in the course of the audit to document a source for those statements.

31. A 20–page colour booklet³⁴ mailed to 9.8 million households during August 2011, at a cost of approximately $4.2 million, was an important element of the Clean Energy Future Campaign. DCCEE’s matrix referenced 99 discrete statements appearing in the household mail–out, including four ‘headline’ statements appearing prominently at the beginning of the document.³⁵ It was necessary to access material not cited by DCCEE in the matrix to establish an authoritative source—Treasury modelling and distributional analysis—for the headline statements. Further, the matrix did not reference three key statements appearing in the Introduction to the household mail–out³⁶, and the ANAO was required to assess comparable statements appearing elsewhere in the mail–out which had been included in the matrix.³⁷ For two of the key statements³⁸, it was necessary to access material not cited by DCCEE to establish an authoritative source—Treasury information and DCCEE calculations.³⁹

32. In light of its experience in developing the Clean Energy Future Campaign, there would be merit in DCCEE reviewing its campaign certification processes to establish a clearer line of sight between information presented as fact in a campaign and the sources cited in support of that information. In this context, it is a matter of judgment as to when there is sufficient support, on the basis of analysis, to turn a forecast into an unqualified statement. These are judgments to be weighed by chief executives, and ministers, in situations where advertising campaigns strip away the supporting analysis to deliver clear and unequivocal statements such as some of the statements made in the Clean Energy Future campaign. While prudence would suggest that significant statements that are based on analysis should indicate this position in some way, particularly when government is responsible for a campaign, there may be situations when the weight of evidence makes qualification of such statements unnecessary.A review of the certification process could usefully inform the development of future advertising campaigns by the department.

33. The Treasury also adopted a process to obtain technical clearance from its internal policy areas of materials prepared for the Tax Reform Campaign⁴⁰, but did not document that its policy areas had cleared those materials for factual accuracy. Treasury advised that it reviewed its processes for technical clearance of campaign material after the campaign ended and introduced an improved sign-off process. While the department was able to demonstrate improvement in its internal processes for clearing material provided to DCCEE for the Clean Energy Future Campaign—informed by its experience in developing the Tax Reform Campaign—there was some inconsistency in implementing the revised arrangements, with internal clearance forms not fully completed in all cases.

34. Where legislation has not been passed before the launch of an advertising campaign, information in creative material which is presented as fact carries the risk of changing if the legislation is amended or not passed. FaHCSIA included a clear disclaimer in its Paid Parental Leave Campaign brochure stating that until the scheme became law, it was possible that some details outlined in the brochure could change. There was some inconsistency in the approach adopted by DCCEE for the Clean Energy Future Campaign, with disclaimers included in the household mail-out booklet and print advertisement, but not the radio and television advertisements. DoHA’s Health Reform Campaign and Treasury’s Tax Reform Campaign did not identify that some information presented as fact may change subject to the passage of legislation⁴¹. The risk of providing the community with information that may change is likely to be higher where the underlying policy position is still subject to active debate in the Parliament, and there would have been merit in considering the use of disclaimers in those circumstances.⁴²

Cost effectiveness

35. Earlier ANAO reports on government advertising⁴³ have highlighted the financial framework requirement that the spending of public money not be approved unless reasonable inquiries have been undertaken that demonstrate that the proposed expenditure will make efficient and effective use of public money.

36. The 2008 Guidelines provided that material should be produced and distributed in an efficient, effective and relevant manner, and that campaigns should be justified by a cost benefit analysis. The requirement for a cost benefit analysis was subsequently removed from the 2010 Guidelines on the advice of the Hawke Review, which favoured an approach focusing on cost effectiveness. The Government accepted the Review’s recommendation that the provision of information regarding the cost effectiveness of proposed campaigns be mandatory at the initial Cabinet approval stage, with the Cabinet Handbook to be revised accordingly.⁴⁴ Further, Principle 4 of the 2010 Guidelines provides that campaigns should be justified and undertaken in an efficient, effective and relevant manner.⁴⁵

37. The audited agencies could generally show that they had liaised regularly with the Master Media Agency (MMA) on the media buy for their respective campaigns, but did not document that they had made an explicit assessment of the overall cost effectiveness of the proposed media placement approach recommended by the MMA. While this does not necessarily mean that value for money was not achieved, the agencies should have satisfied themselves that the proposed media mix was a cost effective way to achieve the objectives of the campaign before authorising the proposed media spend with the MMA.

38. While agencies are required to place their advertising through the MMA, which brings specialist expertise and market knowledge to the table, the cost effectiveness of the media buy undertaken by MMA on an agency’s behalf—including issues of quantity and quality—remains an agency responsibility. Agency approvers of spending proposals must satisfy themselves on the question of cost effectiveness and should not assume that the MMA’s involvement will, of itself, secure value for money.⁴⁶

39. The financial framework requirements also operate at an agency level, and are in addition to the arrangements put in place by Finance through the deed of contract with the MMA to secure discounts on media rates for the Australian Government. Agencies are not able to rely on the operation of the deed alone to satisfy the financial framework requirements for efficient and effective use of Commonwealth resources, which apply to agencies’ individual spending proposals.

40. Further, while the campaign budget agreed by government provides policy authority and a financial ceiling for agencies’ delivery of campaigns, it does not require agencies to spend to the limit of that authority—not least because the Parliament has recently amended the financial management framework to highlight the need for ‘economical’ use of Commonwealth resources, requiring agencies to have explicit regard to minimising cost when considering spending proposals. ^{47 48}

41. While the recent amendments to the financial management framework did not apply to the campaigns examined in the audit⁴⁹, all campaigns developed since the amendments came into effect will be required to comply with the now explicit requirement for economical use of Commonwealth resources. There would be merit in Finance providing further specific advice to agencies on the implications of the amendments to campaign advertising, as a means of supporting agencies in making assessments on the efficient, effective and economical use of Commonwealth resources in the campaign advertising context.

Approvals and record keeping

42. Principle 5 of the 2010 Guidelines provides that procurement policies and procedures for the tendering and commissioning of services and the employment of consultants should be followed, and there should be a clear audit trail regarding decision–making. These requirements also exist independently of the Guidelines, as they have their basis in the FMA Act and Regulations, the CPGs and internal agency requirements governing financial approvals and procurement.

43. FaHCSIA, DoHA, AEC and Treasury procurement processes provided an audit trail, supported by documentation of the relevant financial approvals and the basis for decisions. Authorisations were completed by people with appropriate delegation and the invoices received matched the approved budget for the stated procurement.

44. DCCEE’s management and recording of approvals for the Clean Energy Future Campaign fell short of sound practice. Shortcomings were identified in the approval of ministerial briefs and record keeping practices for those briefs, and the giving and recording of financial approvals for spending proposals.

45. DCCEE was often unable to provide the ANAO with complete or signed versions of ministerial briefs , and the department advised that it would amend its processes to improve the management of ministerial briefs⁵⁰ and ensure that responsible officials sign all future advice to ministers and parliamentary secretaries.

46. A verbal financial approval⁵¹ was given by a DCCEE delegate for a spending proposal, valued at $1.7 million, for the household mail–out distribution contract. However, a different person was recorded in DCCEE’s systems as having given the approval, resulting in a breach of the financial management regulations.⁵² Six other DCCEE spending proposals only received the necessary financial approvals⁵³ after the relevant funding agreement was entered into, resulting in further breaches of the financial management regulations⁵⁴ to be recorded in the department’s annual Certificate of Compliance to the minister.⁵⁵ Finance guidance emphasises the need to clearly determine the financial approver for spending proposals, to preserve accountability.⁵⁶ Further, well documented written approvals, rather than verbal approvals, remain the most appropriate means for considering the majority of spending proposals and in particular high–value spending proposals such as the household mail–out contract. DCCEE advised that all financial delegates in the relevant Division would attend training to refresh their knowledge of financial framework requirements and the department’s financial management system.

Campaign development timelines

47. Finance has consistently advised agencies on the importance of allowing sufficient time for campaign development and the risks of compressed development timelines.⁵⁷ Finance developed a useful guide on indicative timelines for the development and placement of a campaign involving television⁵⁸, and an overview of campaign activity and review processes, which were circulated to agencies shortly after the 2010 Guidelines took effect.

48. DCCEE’s select tender for procuring print services for the household mail–out booklet, valued at $2.7 million for the publication of 10 million copies, was conducted within a severely compressed timeframe of approximately 1.5 days, which had the effect of limiting the number of suppliers and reducing the potential of the process to maximise value for money. A last–minute variation to the scope of the tender—which gave firms approximately 90 minutes to quote on the cost of printing the booklet in A4 size as well as A5 size—had the effect of further limiting the number of suppliers likely to submit satisfactory quotes, and further eroded the capacity of the tender process to maximise value for money.

49. Further, the short lead times—sometimes less than a week—available for media buying by the MMA for the Clean Energy Future Campaign, prompted the ICC to observe that this would have had a significant impact on the MMA’s ability to buy advertising space on the most appropriate programs and secure the best placement positions.⁵⁹

50. DoHA was required to deliver the Health Reform Campaign in the ‘fastest possible timeframe’⁶⁰, and much of the development work for the overarching phase of the campaign was done very quickly.⁶¹ As a consequence, the specific campaign components under development for Indigenous audiences and people of Non English Speaking Background could not be developed in time for the launch of the campaign’s overarching phase. The JCPAA has taken a close interest in the accessibility of campaigns⁶² to all Australians, and Finance has recently reminded agencies of the Government’s ‘continuing obligation’ to address and be responsive to the information needs of culturally and linguistically diverse communities.⁶³

51. The Treasury was also required to fast–track the development of the Tax Reform Campaign, and an exemption from the 2010 Guidelines was sought and granted ‘in order that advertising is able to go to air more quickly’.⁶⁴ Treasury took some steps, in the limited time available⁶⁵, to ensure that elements of the campaign were tested and performing well against the campaign objectives before its launch.⁶⁶ The speed with which the campaign was launched and its exemption from the Guidelines attracted comment in Parliament and the media.

52. It is prudent for agencies to alert ministers, where necessary, to the potential risks of significantly truncated campaign development timeframes and provide options. There would also be benefit in Finance incorporating such advice in its guidance materials.⁶⁷

Evaluation

53. Paragraph 33 of the 2010 Guidelines provides that it is sound practice to evaluate campaigns to determine their effectiveness. DCCEE, FaHCSIA, the AEC and DoHA undertook some form of campaign evaluation, while the early cancellation of the Tax Reform Campaign prompted Treasury not to conduct a post campaign evaluation.

54. The AEC’s evaluation of the 2010 Federal Election Campaign focused on public recall, awareness of the campaign, and levels of understanding of the information relayed in the campaign. However, the AEC did not document whether it had evaluated the effectiveness of the campaign against its stated purpose: to maximise effective participation in the federal election. An evaluation would have allowed the AEC to assess whether such a method of promoting public awareness was the most effective way of achieving the stated purpose.

55. DoHA received a final research report on levels of public awareness about health reform, established through a tracking survey. While the survey reported on the ‘aim of increasing awareness of the proposed health reforms amongst the general public’, the campaign objective agreed by the Government had been to inform Australians of the changes to the health system under the proposed Health Reform Plan; on its face a more ambitious objective which was not evaluated.

56. Treasury did not conduct a post–campaign evaluation to obtain lessons learned, as the Tax Reform Campaign was not completed. In light of the actual costs incurred before cancellation, including a media buy of approximately $10.5 million, there would have been merit in conducting appropriate evaluation activity.

57. The draft evaluation received by DCCEE in November 2011 on the Clean Energy Future Campaign, prompted the ICC to observe⁶⁸ that the draft highlighted a number of matters that were particularly relevant to the development of any future advertising on a Clean Energy Future, such as the limited acceptance of the key campaign messages related to carbon pricing and household assistance, and the findings that the advertisements did not translate into high levels of action.⁶⁹ When completed, the evaluation has the potential to provide valuable lessons from the campaign, which DCCEE would benefit from in developing any future advertising campaigns.

Finance’s support to agencies and reporting on the framework

58. The ANAO identified a number of opportunities for Finance to improve the administration of the campaign advertising framework and enhance the transparency of reporting on the framework.

59. Significant variability was evident in the time taken to issue ICC minutes to agencies⁷⁰, and there would be benefit in Finance reviewing its secretariat processes to address this variability and improve its support to agencies and the ICC. Further, while the proforma campaign certification template provided to chief executives is a useful starting point for their certifications, it goes further than reproducing the requirements of the 2010 Guidelines and in some cases alters their meaning. As the template forms the basis of a chief executive’s written certification against the Guidelines, there would be benefit in Finance reviewing the template for alignment with the Guidelines.

60. As part of the revised campaign advertising framework, the Government undertook to report twice yearly to the Parliament on advertising expenditure for government departments and agencies. A half year report was first released in March 2009⁷¹ and the first full year report was released in September 2009.⁷² Further full and half year reports have been released by Finance in a timely manner.

61. While the reports are an aid to transparency, the full year report contains information on media placement expenditure which is exclusive of GST, and does not aggregate the significant expenditure incurred on ‘consultants, services and other costs’, which totalled $39.8 million in 2009–10 and $46.9 million in 2010–11.⁷³ The inclusion of a consolidated table on total expenditure incurred on ‘consultants, services and other costs’, and expenditure on media placement inclusive of GST⁷⁴, would further enhance transparency and the value of the report.

62. In the context of a framework which continues to evolve, there would also be benefit in Finance publishing updated information on its revised roles and responsibilities. Clarity and transparency would be further improved if the roles and responsibilities of other key participants in the framework were documented, such as the new Peer Review Group (PRG) and the role of the Department of the Prime Minister and Cabinet (PM&C) in chairing the PRG.⁷⁵ Finance’s full year report on campaign advertising would be an appropriate vehicle.

Summary of agencies’ responses

63. The agencies’ responses to the report recommendations are included in the body of the report, directly following the recommendation. Agencies’ general comments on the audit report are provided below.

The Department of Finance and Deregulation

64. Finance welcomes the Report on the Administration of Government Advertising Arrangements: March 2010 to August 2011. Finance appreciates the Report’s acknowledgement of the work it has undertaken to improve the administration of the Government’s campaign advertising framework, following the findings of ANAO Report No.24 of 2008–09 — The Administration of Contracting Arrangements in relation to Government Advertising to November 2007.

65. Overall, Finance notes that none of the audit recommendations indicate significant concern about the overall administration and effectiveness of the Government’s campaign advertising framework. Rather, the five recommendations are primarily directed at refining or improving current practices. Finance agrees to Recommendations 1, 2 and 3.

The Department of Families, Housing, Community Services and Indigenous Affairs.

66. I am pleased to note that the Department is not required to respond to any of the recommendations made in the report, however I note the report includes discussion about the assessment of cost-effectiveness of media placement and I look forward to the ANAO final recommendations on this issue.

The Department of Health and Ageing

67. I note that there are no recommendations relating specifically to the Department and accordingly the Department has no further comments to make. I would like to thank you and your officers for the professionalism with which this audit was undertaken.

The Treasury

68. The Treasury agrees with the findings outlined in the draft report. This includes the recommendation that ‘in future, agencies granted an exemption from the 2010 Guidelines on Information and Advertising Campaigns by Australian Government Departments and Agencies should adopt a process of internal ‘certification’ to provide assurance to the agency Chief Executive of compliance with the Guidelines to the extent that they continue to apply.’

69. As you are aware, we are satisfied that the previous Secretary was kept appropriately informed during the development of the Tax Reform advertising campaign. However, we regard the ANAO recommendation as helping ensure that adequate focus remains on these issues during what can be fairly intense periods of effort.

The Australian Electoral Commission

70. AEC campaigns are conducted in a unique context where timeframes are not known in advance and information critical to effective voter participation in an election must be communicated to over 14 million people by tight, immutable deadlines. The AEC agrees with the only ANAO recommendation relating directly to it and will adopt a process of internal certification to provide to the Electoral Commissioner assurance of compliance with the intent of the Guidelines. The AEC believes that exemption from the Guidelines is critical to its capacity to be, and be perceived to be, independent and neutral.

The Department of Climate Change and Energy Efficiency

71. DCCEE notes that the ANAO did not identify any inaccuracies or statements used in the advertisements that could not be supported by evidence. We further note the ANAO's acknowledgement at [paragraph 8.20 of the report] that the campaign was undertaken in difficult circumstances and related to a complex policy package that relied heavily on the work of other agencies.

72. DCCEE recognises that there were procedural shortcomings in the administration of the campaign. As part of our commitment to continuous improvement of processes and systems, DCCEE accepts the ANAO's findings on the procedural issues raised in the report. The Department has started taking action in direct response to several of the ANAO's findings and will continue to improve its processes and systems in the pursuit of best practice.

73. In this context, and with regard to Recommendation 5, the Department will now review its campaign certification processes in the application of Paragraph 21 of the 2010 Guidelines on Information and Advertising Campaigns by Australian Government Departments and Agencies, specifically that element of Principle 2 which requires that information presented as fact in advertising campaigns is accurate and verifiable, to strengthen transparency.

74. The ANAO's observations on the Department's performance with regard to procurement and recordkeeping are also noted. In response, the Department intends to allocate additional resources to the development of internal education programs designed to communicate to employees the requirements of departmental procurement and recordkeeping policies. Since the ANAO completed its fieldwork, the Department has delivered purpose-designed financial management training to relevant officers of the Division with accountability for the Clean Energy Future advertising campaign.

75. The Department has also reviewed its processes for the approval of ministerial briefs and recordkeeping practices associated with those briefs. As a result, new procedures have been introduced to ensure that complete, signed versions of ministerial briefs are maintained in accordance with the Department's Information Management Policy.

76. The Department welcomes the proposal that the Department of Finance and Deregulation provide additional guidance on how agencies might best meet the 'proper use' requirements of the Financial Management and Accountability Act 1997 and Regulation 9 of the Financial Management and Accountability Regulations 1997. Guidance of this nature will facilitate improved governance and better quality outcomes in future campaigns.

The Department of the Prime Minister and Cabinet

77. In relation to paragraph 62 of the summary, PM&C does not agree that there is a lack of clarity or transparency in the roles and responsibilities of key participants in the evolving framework. There has been thorough communication with departments in relation to the framework. We believe there is a good understanding of the objectives behind the recent changes and strong support for initiatives such as the Peer Review Group, which aims to foster increased collaboration and professional skills among communications executives.

78. In relation to paragraphs [2.32 to 2.34 of the report], the ANAO implies that PM&C failed to heed a recommendation of the Hawke Review calling for the Cabinet Handbook to be updated to mandate that submissions must provide adequate information to enable Cabinet to consider the cost-effectiveness of proposed advertising campaigns. An updated draft of the Cabinet Handbook, reflecting this recommendation is currently before the Government for consideration.

Footnotes

[1]   Senate Finance and Public Administration References Committee, Government advertising and accountability, p. xiii [Internet]. Finance and Public Administration References Committee, Canberra, 2005, available from <http://www.aph.gov.au/senate/committee/fapa_ctte/completed_inquiries/2004-07/govtadvertising/index.htm> [accessed 22 July 2011]. In the Committee’s view, two major mechanisms were required to deal with these concerns: ‘The first is an adequate system for disclosing the quantum of advertising expenditure and, equally importantly, for disclosing the public policy justification of major advertising campaigns. The second is the scrutiny of that justification and of the government’s proposed campaign material against agreed guidelines,’ p. xvii.

[2]   ANAO Performance Audit Report No.24 2008–09, The Administration of Contracting Arrangements in relation to Government Advertising to November 2007, available from <http://www.anao.gov.au/~/media/Uploads/Documents/2008%2009_audit_report_24.pdf.> [accessed 7 December 2011]. The audit observed that it is important that the administrative arrangements in respect of government advertising provide assurance that both statutory and government policy requirements are satisfied.

[3]   Department of Finance and Deregulation, Guidelines on Campaign Advertising by Australian Government Departments and Agencies, June 2008.

[4]   In its September 2000 report (No.377) Guidelines for Government Advertising, the JCPAA recommended the adoption of guidelines for advertising, similar to those proposed in ANAO Audit Report No.30 1994–95 Commonwealth Government Information and Advertising, which had suggested the adoption of principles and guidelines for the development, content and presentation of government advertising. The JCPAA’s recommendations were not taken up by the government of the day.

[5]   In 2004 and 2005, the Senate Finance and Public Administration References Committee also undertook an inquiry into government advertising, and the non-government majority report of December 2005, Government advertising and accountability, recommended the adoption of guidelines and reporting on compliance against the guidelines for all campaigns valued at more than $250 000.

[6]   ANAO Report No.2 2009–10, Campaign Advertising Review 2008–09, p.9.

[7]   The review of a proposed advertising campaign’s compliance, undertaken by the ANAO as the basis for the Auditor-General’s report, was designed to provide limited assurance in accordance with the relevant Australian Standard on Assurance Engagements. The limited assurance approach was designed to ensure sufficient appropriate evidence was obtained to enable an assurance conclusion to be formed in relation to an advertising campaign’s compliance with the Guidelines.

[8]   ANAO Report No.38 2009–10, Campaign Advertising Review July 2009–March 2010, provides further background on the changes.

[9]   ibid., p.7.

[10]   The 2010 Guidelines were informed by the Independent Review of Government Advertising Arrangements conducted by Dr Allan Hawke AC in early 2010.

[11]   Ludwig, J (Cabinet Secretary, Special Minister of State), Changes to the Framework for Government Advertising, media statement, Parliament House, Canberra, 31 March 2010. The statement is referred to in New Arrangements for Government Advertising, media release, Parliament House, Canberra, 31 March 2010.

[12]   A Communications Multi-Use List of all communications consultants interested in working on government information and advertising campaigns must be used by agencies to select communications consultants for campaigns over $250 000, and replaces all other agency procurement mechanisms. A Central Advertising System consolidates government advertising expenditure with the goal of securing media discounts for government. Two ‘master media’ agencies are contracted by Finance to manage media planning, placement and rates negotiations with media outlets.

[13]   Financial framework requirements, established by the Financial Management and Accountability Act 1997 and Financial Management and Accountability Regulations 1997, operate independently of the 2010 Guidelines. The framework promotes the proper use of Commonwealth resources.

[14]   At 20 December 2011, 109 agencies were subject to the FMA Act, including the 20 departments of state. They are referred to collectively as ‘agencies’ in this audit.

[15]   Guidelines on Information and Advertising Campaigns by Australian Government Departments and Agencies (March 2010), paragraph 8, available from <http://www.finance.gov.au/advertising/docs/Guidelines-on-Information-and-Advertising-Campaigns-by-Australian-Government-Departments-and-Agencies-March-2010.pdf> [accessed 24 November 2011].

[16]   Principle 1: campaigns should be relevant to government responsibilities. Principle 2: campaign materials should be presented in an objective, fair and accessible manner and be designed to meet the objectives of the campaign. Principle 3: campaign materials should be objective and not directed at promoting party political interests. Principle 4: campaigns should be justified and undertaken in an efficient, effective and relevant manner. Principle 5: campaigns must comply with legal requirements and procurement policies and procedures. The five principles contain additional requirements set out in 18 sub-paragraphs.

[17]   The three members are Dr Allan Hawke AC (chair), Ms Helen Williams AO and Ms Anthea Tinney PSM. Ms Barbara Belcher AM, a foundation member of the committee, resigned in June 2010 and was replaced by Ms Tinney in October 2010.

[18]   The ICC’s terms of reference provide that its specific responsibilities include: overseeing the operation of the Guidelines to ensure compliance with their integrity and spirit, providing advice to chief executives on compliance of proposed campaigns with Principles 1 to 4 of the Guidelines, publicly providing assessments of campaigns’ compliance with the Guidelines, reporting on trends or emerging issues associated with advertising campaigns, and considering and proposing revisions to the Guidelines in light of experience.

[19]   Paragraph 14 sets out the documentary requirements for the certification process. Paragraph 17 provides for the publication of campaign research reports and for the details of advertising campaigns to be published in agency annual reports.

[20]   The 2008 Guidelines provided for exemptions on the basis of a national emergency, extreme urgency or other extraordinary reasons the Cabinet Secretary considered appropriate. The Auditor-General was to be informed of exemptions and they were to be formally recorded and reported to the Parliament.

[21]   The Cabinet Secretary approved an exemption for the Treasury’s Tax Reform Campaign in May 2010, which is considered later in this audit report. The 2010 Guidelines provide that the ICC will be informed of an exemption and it will be formally recorded and reported to the Parliament.

[22]   The exemption was granted on 17 August 2009 for campaign advertising regarding federal elections, by‑elections or referenda. The AEC did not seek to renew its campaign exemption when the revised Guidelines were released in March 2010, and relied on its 2009 exemption as a basis for not undergoing ICC certification processes for the 2010 Federal Election Campaign. While internal legal advice received by Finance concluded that the exemption continued to be effective, it would have been prudent for the AEC, in consultation with Finance, to seek to refresh the exemption following the release of the 2010 Guidelines and the commencement of the revised campaign advertising framework.

[23]   In September 2010 the previously combined roles of Cabinet Secretary and SMOS were split, resulting in the SMOS having responsibility for campaign advertising. The wording of the 2010 Guidelines was amended to reflect the revised ministerial responsibilities.

[24]   The Peer Review Group, to be chaired by the Department of the Prime Minister and Cabinet, was introduced to improve the quality and timeliness of campaigns by exposing individual departments to scrutiny through a regular peer review process.

[25]   Agencies are no longer required to seek campaign development advice or involve Finance in campaign advertising tender processes. Finance will engage with agencies only if they specifically seek its assistance.

[26]   The certification process did not apply to the AEC’s 2010 Federal Election Campaign or Treasury’s Tax Reform Campaign. It did apply to DCCEE’s Clean Energy Future Campaign, FaHCSIA’s Paid Parental Leave Campaign and DoHA’s Health Reform Campaign.

[27]   The ICC does not provide advice on compliance with Principle 5, which is considered to relate to the regular responsibilities of chief executives. To receive additional comfort on compliance with Principle 5, agencies sought internal and/or external legal advice.

[28]   In practice, the campaign exemptions provided to Treasury for the Tax Reform Campaign and the AEC for the 2010 Election Campaign were partial exemptions from the 2010 Guidelines, as SMOS indicated that the agencies were expected to continue to adhere to the ‘intent’ of the Guidelines. Moreover, the exemption mechanism cannot exempt campaigns or agencies from legal requirements, which operate independently of the Guidelines.

[29]   There was an incomplete Treasury and AEC record available for the purpose of assessing compliance with the non-exempt elements of the 2010 Guidelines, requiring the ANAO to rely on a combination of internal and external sources of information to assess compliance.

[30]   These include the 2010 Guidelines and the half-year and full-year reports on campaign advertising by departments and agencies, which report on the Australian Government’s campaign advertising framework and expenditure.

[31]   The 2010 Guidelines suggest that agencies need to distinguish between requirements that ‘must’ be complied with, those which ‘should’ be complied with, and those that ‘will’ be complied with, although these terms are not defined or otherwise explained. In contrast, the Commonwealth Procurement Guidelines and Commonwealth Grant Guidelines issued by Finance clearly define these key terms—obligations which must be complied with, in all circumstances, are denoted by use of the term must, while use of the term should denotes matters of sound practice. The ANAO adopted these definitions to analyse the status of requirements in the 2010 Guidelines.

[32]   The Treasury and AEC campaigns were exempt from the certification process.

[33]   The final version of the matrix provided to the ICC referenced sources for 142 discrete statements made in the various campaign elements—including television, radio and print advertisements. The final version of the matrix was attached to DCCEE’s Statement of Compliance for the household mail-out booklet, which is discussed below.

[34]   Australian Government, What a carbon price means for you: the pathway to a clean energy future. Available from <http://www.cleanenergyfuture.gov.au/wp-content/uploads/2011/08/What_a_carbon_price_means_to_you.pdf> [accessed 9 December 2011].

[35]   The headline statements at page 2 of the household mail-out were: ‘What the carbon price package means for Australian households…[i] 9 in 10 households will receive some combination of tax cuts and increased payments to help them with the cost of living impact of the carbon price. [ii] Over 1 million extra Australians will no longer need to lodge a tax return. [iii] Almost 6 million households will be assisted to meet their average price impact. [iv] Over 4 million households will get assistance that is at least 20 per cent more than their average price impact.’

[36]   The three key statements were: [i] The carbon price package will ensure that by the end of the decade Australia will cut 160 million tonnes of pollution from the atmosphere each year. That’s the equivalent of taking 45 million cars off the road’. [ii] ‘…over half of the money raised from the carbon price will be used to fund tax cuts, pension increases and higher family payments’. [iii] ‘…the biggest polluters will pay for every tonne of carbon pollution they put into the atmosphere’.

[37]   The comparable statements were: [i] ‘By 2020 the carbon price package will take 160 million tonnes of pollution out of the atmosphere every year. That’s the equivalent of taking forty‑five million cars off the road’. [ii] ‘… over half of the money raised under the carbon price will be used by the Government to cut taxes and increase payments to assist households, as detailed in this booklet’. [iii] ‘A carbon price is not a tax on households—it will be paid by Australia’s biggest polluters. This means around 500 big polluters will be required to pay for their pollution’.

[38]   Only the following statement was supported by the source cited in DCCEE’s matrix: ‘… over half of the money raised under the carbon price will be used by the Government to cut taxes and increase payments to assist households, as detailed in this booklet’.

[39]   In the case of the key statement relating to the 500 biggest polluters paying the carbon tax, the source cited in the matrix only provided a starting point for further calculation and presumed prior knowledge of the operation of related legislation in order to undertake that calculation.

[40]   Such as press material and scripts for radio and television advertisements.

[41]   The print advertisement for the Health Reform Campaign stated that: ‘For the first time the Australian Government will take dominant funding responsibility for our health system—providing a secure funding base into the future’. At the time DoHA was developing the campaign, the amendments required to the Federal Financial Relations Act 2009 around GST funding had not been introduced. Nor had the Western Australian Government agreed to the proposed reforms or GST funding arrangements. Some other elements of the reforms did not require legislation for their implementation.

[42]   The new Prime Minister cancelled Treasury’s campaign earlier than planned, on 24 June 2010, to facilitate negotiations with industry on an alternative policy approach. An agreement with the mining industry was subsequently reached on a new Mineral Resources Rent Tax to replace the Resource Super Profits Tax, which had been the subject of the campaign.

[43]   ANAO Audit Report No.24 2008–09, The Administration of Contracting Arrangements in relation to Government Advertising to November 2007; ANAO Report No.2 2009–10, Campaign Advertising Review 2008–09; and ANAO Report No.38 2009–10, Campaign Advertising Review July 2009–March 2010.

[44]   Finance also advised agencies on 20 May 2010 that initial consideration of proposed campaign costs, effectiveness and impact would take place at the budget approval stage, with the Cabinet Handbook to be amended accordingly. In the course of the audit Finance advised the ANAO that while the Cabinet Handbook has not been amended, PM&C has been provided with information about implementing the recommendation and PM&C’s development of the next edition of the Cabinet Handbook is underway.

[45]   The reference to efficiency and effectiveness in Principle 4 alludes to the requirements of the FMA Act and Regulations—which operate independently of the 2010 Guidelines—for the ‘proper use’ of all Commonwealth resources, which until recently meant efficient, effective and ethical use that is not inconsistent with the policies of the Commonwealth. As discussed below, the definition of proper use in section 44(3) of the FMA Act was amended with effect from 1 March 2011.

[46]   The financial framework requirements apply to all spending proposals, including the purchase of goods and services relating to the delivery of advertising campaigns, such as the media buy undertaken by the MMA, developmental research services, campaign creative development, printing and distribution.

[47]   Amendments to the definition of ‘proper use’ in section 44(3) of the FMA Act, which took effect on 1 March 2011, added the requirement for ‘economical’ use in addition to the existing requirements for efficient, effective and ethical use. While the term ‘economical’ is not defined in the FMA Act, Finance has advised agencies that ‘economy’ relates to ‘minimising cost’, and that while the concepts of efficiency and effectiveness already encompassed the concept of economy, the addition of the term economical was ‘intended to emphasise the requirement to avoid waste and increase the focus on the level of resources that the Commonwealth applies to achieve outcomes.’ Finance Circular No. 2011/01, Commitments to spend public money (FMA Regulations 7 to 12), 31 March 2011, pp.11–12, available from <http://www.finance.gov.au/publications/finance-circulars/2011/docs/Finance-Circular-2011-01-FMA-Regulations-7-12.pdf> [accessed 3 December 2011].

[48]   The amended definition of ‘proper use’ also applies to FMA Regulation 9, which now requires that an approver must not approve a spending proposal unless the approver is satisfied, after making reasonable inquiries, that giving effect to the spending proposal would be a proper use of Commonwealth resources, within the meaning of section 44(3) of the FMA Act. While the amended FMA Regulation 9 came into effect on 1 July 2010, broad transitional and savings provisions gave agencies until 1 July 2011 to update internal procedures, guidance and delegations.

[49]   The FMA Act amendments took effect on 1 March 2011 and therefore post-dated the FaHCSIA, DoHA, AEC and Treasury campaigns. DCCEE could rely on broad transitional and savings provisions intended to give agencies an opportunity to update internal procedures, delegations and guidance.

[50]   This shortcoming resulted from the departmental practice of only scanning into the ministerial correspondence system the cover page of ministerial briefs and relying on officials to place the full version on local files. As a consequence, the ANAO was provided with composite briefs comprising a scanned front page sourced from the ministerial tracking system, with the remaining pages sourced from elsewhere. Further, while the front pages of ministerial briefs were signed and dated by the Minister, the majority of briefs provided to the ANAO were not signed or initialled by the official tendering the advice. Ministerial briefs tendered by the Secretary were an exception. In a number of cases ministerial briefs were stamped as ‘signed’ above the responsible official’s signature block—a practice which lends no additional authority to a document.

[51]   For the purposes of FMA Regulation 9.

[52]   FMA Regulation 12 provides that if approval of a spending proposal has not been given in writing, the approver must record the terms of the approval in writing as soon as practicable after giving the approval. The written record of the approval should be an accurate record.

[53]   Under FMA Regulation 9.

[54]   FMA Regulation 8 requires that Regulation 9 approvals be given before an arrangement is entered into.

[55]   DCCEE advised that a number of financial delegates could potentially give approvals for spending proposals within the relevant Division, and this had led to the wrong official being recorded as the approver.

[56]   Finance Circular 2011/01, Commitments to spend public money (FMA Regulations 7 to 12), 31 March 2011, p.21. Available from <http://www.finance.gov.au/publications/finance-circulars/2011/01.html> [accessed 3 December 2011].

[57]   In correspondence to agency chief executives dated 20 May 2010, the Finance Secretary noted that: ‘Ultimately, compressed timelines increase the risk that the justification for, and quality of campaigns, will be negatively affected.’

[58]   The indicative timeline was circulated by the Finance Secretary on 20 May 2010 with his correspondence to agencies on changes to the government advertising framework. Finance advised that television campaigns developed from ‘scratch’ generally take between 20 and 27 weeks, while the timeframe for print and online campaigns ranges from 8 to 12 weeks, depending on existing research and the complexity of the message.

[59]   Finance correspondence with DCCEE, 8 December 2011, confirming discussions between the ICC and DCCEE on 28 November 2011.

[60]   DoHA Minute to the Minister, 18 March 2010.

[61]   Much of the campaign development work occurred in the 58 days (approximately eight weeks) between the government decision of 15 March 2010 to undertake the campaign and the time that advertisements appeared on 13 May 2010.

[62]   Joint Committee of Public Accounts and Audit, hearings on reference into the Role of the Auditor‑General in Scrutinising Government Advertising, 26 October 2009.

[63]   Finance Secretary’s correspondence to agency chief executives, 4 October 2011. Finance also advised agencies that they would be required to document reasons if multicultural or indigenous media is not used as part of an advertising campaign. The information will be included in Finance’s future reports on campaign advertising.

[64]   Special Minister of State, parliamentary statement on the exemption, 28 May 2010.

[65]   Treasury undertook much of the development work for the campaign (for press, radio and online) in the 39 days (approximately 5.5 weeks) between the government decision of 20 April 2010 to undertake the campaign and the time that press and radio advertisements appeared on 29 May 2010. Forty–six days (approximately 6.5 weeks) elapsed between the government decision of 20 April 2010 and the time that television advertisements appeared on 6 June 2010.

[66]   However, the creative material provided for testing was generally in a pre‑production stage and full suites of the creative material were not used for concept testing. Moreover, the planned third phase of concept testing was only conducted after the campaign had launched.

[67]   In a similar vein, the CGGs establish an expectation that agencies take appropriate and timely steps to advise Ministers. The approach adopted in the CGGs was informed in part by the ANAO’s findings in ANAO Performance Audit Report No.24 2008–09, The Administration of Contracting Arrangements in relation to Government Advertising to November 2007 (p.23), which highlighted the role of departments in providing advice to Ministers of obligations associated with their decisions.

[68]   Finance correspondence with DCCEE, 8 December 2011, confirming discussions between the ICC and DCCEE on 28 November 2011.

[69]   As reflected in the small number of calls to the call centre and visits to the Clean Energy Future website.

[70]   The average for the campaigns examined as part of the audit was 24 working days, with the shortest period being two days and the longest period being 72 days.

[71]   Department of Finance and Deregulation, Campaign Advertising by Australian Government Departments and Agencies Half Year Report 1 July to 31 December 2008. Available from <http://www.finance.gov.au/advertising/campaign-advertising-reports.html>, [accessed 8 December 2011].

[72]   Department of Finance and Deregulation, Campaign Advertising by Australian Government Departments and Agencies Full Year Report 2008–09. Available from <http://www.finance.gov.au/advertising/campaign-advertising-reports.html>, [accessed 8 December 2011].

[73]   Expenditure on ‘consultants, services and other costs’ is reported on at an individual agency and campaign level in the full year report, but is not currently aggregated.

[74]   The 2009–10 and 2010–11 full year reports itemise, in Table 1, gross Australian Government media placement expenditure (GST exclusive) as $114.7 million in 2009–10 and $116.9 million in 2010–11.

[75]   In providing comments on an extract of the proposed audit report, PM&C did not agree that there is a lack of clarity or transparency in the roles and responsibilities of key participants in the evolving framework. See further discussion in Chapter 3 of this report.