Finance Circular
No. 2013/02
Australian Government Grants: Briefing and
Reporting
Key points
This circular:





provides guidance to Financial Management and Accountability Act 1997
(FMA Act) agencies on the reporting requirements under the Commonwealth Grant
Guidelines (CGGs)
is relevant for chief executives and agency staff involved in grants administration,
including agency staff who advise ministers on grants
reflects changes to the CGGs that take effect on 1 June 2013
replaces Finance Circular 2009/04 Grants - Reporting Requirements
is available on the Finance website at http://www.finance.gov.au/publications/financecirculars/index.html
Contents
Foreword ............................................................................................................................................................ 3
Key Concepts ..................................................................................................................................................... 4
Part 1
Requirements for agency staff .................................................................................................. 6
1.1
Reporting and documentation requirements for agency staff ....................................................6
1.1.1
Documenting decisions relating to grants ...........................................................................................6
1.1.2
Grant guidelines ..............................................................................................................................................6
1.1.3
Web-based reporting on grants ...............................................................................................................7
1.1.4
Reporting of special confidentiality clauses on agency websites...............................................7
1.1.5
Web-based reporting exemptions ...........................................................................................................8
1.2
Briefing requirements ..................................................................................................................................8
1.3
Other reporting requirements ..................................................................................................................9
Part 2
Requirements for ministers .................................................................................................... 10
2.1
Reporting requirements for ministers ............................................................................................... 10
2.1.1
Electorate reporting ................................................................................................................................... 10
2.1.2
Electorate reporting exceptions............................................................................................................ 10
2.1.3
Approval of grants that agency staff has recommended be rejected..................................... 11
Part 3
Requirements for grant recipients ....................................................................................... 12
3.1
Reporting requirements for grant recipients .................................................................................. 12
3.1.1
Performance measurement .................................................................................................................... 12
3.1.2
Proportionality ............................................................................................................................................. 12
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3.1.3
Report once, use often ............................................................................................................................... 13
Part 4
Frequently asked questions .................................................................................................... 14
Attachment A
Grant guidelines – Better practice checklist .................................................................. 17
Attachment B
Template – Publishing grant information on agency websites .............................. 19
Attachment C
Checklist for agency staff briefing ministers on proposed grants ........................ 20
Attachment D
Template – Grants awarded in minister’s own electorate ....................................... 22
Attachment E
Template – Annual ministerial report where a minister has approved a grant
that the relevant department or agency staff recommended be rejected ......... 23
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Foreword
Foreword
The objective of grants administration is to promote the proper use of Commonwealth
resources through collaboration with the non-government sector to achieve government policy
outcomes.
Grants administration encompasses all processes involved in granting activities, and includes:

planning and design

selection and decision-making

the making of a grant

the management of grant agreements

the ongoing relationship with grants recipients

reporting

review and evaluation.
Accountability arrangements in grants administration relate to both the process of grants
administration, including grants allocation processes and ongoing grants management, as well
as the achievement of government objectives. Ministers, chief executives, agency staff and grant
recipients all have their respective roles to play in achieving specific government objectives and
should be held accountable for the ways in which they fulfill their roles.
This circular provides guidance for chief executives and agency staff on reporting and briefing
requirements that apply to grants administration. It includes frequently asked questions and
more detailed technical information in the attached templates.
This circular reflects changes to the CGGs, which take effect on 1 June 2013, including:

amendments to the definition of a ‘grant’

extending the timeframe for agencies to publish information on their websites from
seven to 14 days

removing the requirement for ministers to report own-electorate grants where the
grants are awarded on the basis of a formula

new briefing requirements for agency staff

the introduction of a requirement for agency staff to report when special confidentiality
provisions are contained in grant agreements

a greater emphasis on agency staff applying the ‘report once, use often’ and
proportionality principles when designing reporting requirements for grant recipients.
The CGGs can be found on the Finance website at http://www.finance.gov.au/financialframework/financial-management-policy-guidance/grants.html.
Questions about this Finance Circular and the application of the CGGs should be directed to the
Grants Policy Team at grants@finance.gov.au or visit our website.
Kerry Markoulli
Assistant Secretary
Resource Management Branch
Governance and Resource Management Group
May 2013
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Key Concepts
Key concepts
agency means a department of state (including persons allocated to the department by the
Financial Management and Accountability Regulations 1997 (FMA Regulations)), a parliamentary
department, or any agency prescribed under the FMA Regulations (see section 5 of the
FMA Act).
agency staff means officials of the agency. This includes persons who are not employed by the
agency, but perform a ‘financial task’ for the agency. A ‘financial task’ is defined in
FMA Regulation 3 as ‘a task or procedure relating to the commitment, spending, management or
control of public money’.
allocated official means a person outside the Commonwealth who performs a ‘financial task’ in
relation to grants administration and temporarily becomes an official of the agency while they
are undertaking that task. As an allocated official, they are subject to all the requirements of the
financial management framework that apply to all officials, including: FMA legislation; the CGGs;
the policies of the Commonwealth; and the relevant agency’s Chief Executive’s Instructions
(CEIs).
approver means a minister or agency chief executive (including a chief executive’s delegate).
An approver is authorised to consider and approve spending proposals under FMA Regulation 9.
A person may also be authorised to approve proposals to spend public money under legislation
other than the FMA Act (see FMA Regulation 3).
arrangement means an arrangement, including a contract or agreement, under which public
money is payable or may become payable, other than:
(a) an arrangement for:
(i)
the engagement of an employee; or
(ii)
the appointment of a person to a statutory office; or
(iii)
the acquisition of particular property or services under a general arrangement
with the supplier of that property or those services, for the purposes of
providing a statutory or employment entitlement; or
(b) an international agreement governed by international law (see FMA Regulation 3).
An arrangement includes an arrangement under which public money is, or may become, payable
in the form of a notional payment.
assessment criteria are the specified principles or standards against which applications will be
judged. These criteria are also used to assess the merits of proposals and, in the case of a
competitive granting activity, to determine applicant rankings.
Commonwealth Grant Guidelines (CGGs) are issued by the Minister for Finance and
Deregulation (Finance Minister) under section 64 of the FMA Act and Regulation 7A of the
FMA Regulations. The CGGs establish the overarching Commonwealth grants policy framework
within which agencies develop their own specific grants administration practices. They also
articulate the expectations for all FMA Act agencies. The CGGs are split into two parts.
Part 1 contains the mandatory requirements. Part 2 contains information on the seven
principles of grants administration.
eligibility criteria refer to the mandatory criteria which must be met for a grant application to
qualify for a grant. Eligibility criteria may apply in addition to assessment criteria.
financial acquittal refers to a report of financial transactions relating to a grant. The report
may require recipients to provide item by item expenditure information. It is generally certified,
and may sometimes be independently certified.
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Key Concepts
grant is defined by FMA Regulation 3A(1) as an arrangement for the provision of financial
assistance by the Commonwealth:
(a) under which public money is to be paid to a recipient other than the Commonwealth;
and
(b) which is intended to assist the recipient achieve its goals; and
(c) which is intended to help address one or more of the Australian Government’s policy
objectives; and
(d) under which the recipient may be required to act in accordance with specified terms or
conditions.
The CGGs apply to all arrangements defined in FMA Regulation 3A(1). FMA Regulation 3A(2)
exempts certain arrangements from the definition of a grant (see paragraph 2.9 of the CGGs for a
list of these arrangements), and therefore from the requirements of the CGGs. See
Finance Circular 2013/01 Grants, Procurements and other Financial Arrangements for further
guidance.
granting activity(ies) refers to the process of providing public money to potential grant
recipients, whether through a grant program or other grant giving exercises. Granting activities
can take a variety of forms, including payments made: as a result of competitive or
non-competitive selection processes; where particular criteria are satisfied; or on a one-off or
ad hoc basis.
grant agreement sets out the relationship between the parties to the agreement, and specifies
the details of the grant.
grant guidelines may consist of a suite of documents that relate to one or more granting
activities, such as overarching guidelines, specific application or expression of interest
documentation and/or documentation covering the ongoing operation of the grant, such as a
grant agreement.
grant project/task/services refers to a combination of activities undertaken by grant
recipients funded by the grant money.
Minister means a minister of state, including a parliamentary secretary.
one-off or ad hoc grant refers to a grant that generally does not involve a planned selection
process, but is designed to meet a specific need, often due to urgency or other circumstances.
These grants are generally not available to a range of applicants or on an ongoing basis.
proper use means efficient, effective, economical and ethical use that is not inconsistent with
the policies of the Commonwealth (see section 44(3) of the FMA Act).
proportionality involves striking a balance between the complexity of a granting activity and
managing the risks for beneficiaries and the Australian Government.
public money means
(a) money in the custody or under control of the Commonwealth; or
(b) money in the custody or under control of any person acting for or on behalf of the
Commonwealth in respect of the custody or control of the money;
including such money that is held on trust for, or otherwise for the benefit of, a person other
than the Commonwealth (see section 5 of the FMA Act).
selection criteria comprise eligibility criteria and assessment criteria.
selection process is the method used to select potential grant recipients. This process may
involve comparative assessment of applications or the assessment of applications against the
eligibility criteria and/or the assessment criteria.
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Part 1 – Requirements for agency staff
Part 1 Requirements for agency staff
1.1 Reporting and documentation requirements for
agency staff
1.
Effective disclosure and reporting in grants administration are essential to ensure
transparency and public accountability. Reliable and timely information on grants
opportunities and awarded grants helps to provide both the public and the Parliament
with confidence in the quality and integrity of grants administration.
Accountability in grants administration depends on the development, maintenance,
awareness and public availability of appropriate grants documentation, processes and
information. Reporting and record keeping by agency staff is therefore a key component
of good grants administration. Agency staff involved in grants administration should
ensure that all grant documentation is clear, concise, well-designed and consistent with
the CGGs.
Agency staff who make recommendations to ministers on grants administration, must
ensure that they provide the minister with sufficient information to make an informed
and transparent decision, particularly in relation to awarding specific grants and
approving the expenditure of public money.
2.
3.
1.1.1
Documenting decisions relating to grants
4.
5.
Agency staff must establish and document whether a proposed activity is a grant prior to
applying the CGGs (see Finance Circular 2013/01 Grants, Procurements and other
Financial Arrangements for further information).
Agency staff should use competitive, merit-based selection processes to allocate grants,
unless specifically agreed otherwise by a minister, chief executive or delegate. If an
alternative process is used, agency staff should document why this approach was taken
and who made the decision.
1.1.2
Grant guidelines
6.
Agency staff must develop grant guidelines for all new granting activities, and revise
guidelines where significant changes have been made to a current granting activity.
Agency staff must ensure that grant guidelines, and any related operational guidance, are
consistent with the CGGs.
 Where grant guidelines have been in place for a considerable time, agency staff
should review the content and structure of the guidelines to ensure they are in
accordance with the relevant legislative provisions and the CGGs.
 Agency staff should identify opportunities to appropriately accommodate one-off
or ad hoc grant giving activities within the structure of a grant program. This will
also assist with the requirement to have legal authority for these payments.
 Finance should be consulted about the need for grant guidelines for a significant
one-off or ad hoc grant, or when agency staff are considering approving a
number of one-off or ad hoc grants for similar purposes, whether in the same
round or over a period of time.
Agency staff should ensure that the rules of granting activities are simply expressed,
clear in their intent and effectively communicated to stakeholders. Agency staff should
consider testing the clarity of grant guidelines with stakeholders prior to their release.
At a minimum, grant guidelines should provide potential grant applicants access to
adequate information to submit a grant application. The guidelines should also include a
statement of the granting activity objectives; an outline of the selection and assessment
7.
8.
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Part 1 – Requirements for agency staff
processes, including who will be responsible for making the final recommendations and
approval decisions; any reporting and acquittal requirements; and a description of
appeal and review mechanisms. The checklist at Attachment A1 contains further
information on what should be included in grant guidelines.
Grant guidelines must be publicly available on agency websites, except where:
 there is a specific policy reason not to publicise the grant guidelines
 grants are provided on a one-off or ad hoc basis.
Before grant guidelines are published, agencies must ensure they have complied with
the Australian Government’s process for approval of new or revised program
guidelines.2
9.
10.
1.1.3
Web-based reporting on grants
11.
Agencies must publish information on individual grants on their website no later than
14 working days after the grant agreement takes effect (date of effect). Finance
recommends agencies use the web-based reporting template at Attachment B.
12.
The date of effect may mean different things for different types of grants and agency staff
should document why they have chosen a specific date of effect. Agency staff may decide
that the date of effect is the date that the grant agreement is entered into or the date of
the first payment, depending on the granting activities. However, there may also be
instances where the date of effect is another specified date. For example, the date of
effect may be set to coincide with the announcement of successful grant recipients or
there may be a planned delayed start for grant projects to coincide with the
commencement of the financial year.

Agencies should adopt a consistent approach for grants awarded in the same
program
 Where the nature of the grant means that a grant agreement is not required, then
the 14 working days would apply from the relevant date of effect, for example,
the date of the first invoice or payment.
Grants information must be retained on agency websites for two financial years. Where
it is not practicable to do so, agencies must retain appropriate records and ensure that
they are readily available when requested. Agencies should generally keep information
on grant programs and successful recipients electronically in a searchable, easily
obtainable and useable format.
13.
1.1.4
Reporting of special confidentiality provisions on agency websites
14.
There are generally two broad types of confidentiality related clauses used in grant
agreements:
15.

general clauses referencing confidentiality requirements in legislation, such as
under the Privacy Act 1988

special confidentiality provisions, which protect the confidentiality of: all or part
of the grant agreement; or information obtained or generated in relation to the
grant project.
The CGGs require agencies to report on special confidentiality provisions contained in
grant agreements. References to requirements in other legislation do not need to be
1
See http://www.finance.gov.au/financial-framework/financial-management-policyguidance/grants.html for the latest version of the checklist.
2
See Estimates Memorandum 2011/19 – Process relating to the approval of new or revised program
guidelines.
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Part 1 – Requirements for agency staff
reported. There is no threshold for reporting on special confidentiality provisions in
grant agreements. An example of how to report on a special confidentiality provision is
included in the web-based reporting template at Attachment B.
16.
Reporting of special confidentiality provisions should allow agencies to align the
reporting requirements of Procedural Orders of Continuing Effect: 11 Departmental and
agency contracts with the web-based reporting requirements for grants.
17.
When agencies publish information on individual grants, as part of web based reporting,
they must include information identifying whether a grant agreement contains any
special confidentiality provisions and, if so, provide the reasons why they are included.
18.
For additional information on reporting of confidentiality provisions, agency staff can
draw from information provided for procurement contracts at:
http://www.finance.gov.au/procurement/procurement-policy-andguidance/buying/reporting-requirements/reporting-confidentiality/practice.html.
1.1.5
Web-based reporting exemptions
19.
Where agency staff determine that publishing grants information on agency websites
may jeopardise government policy outcomes, then the responsible minister can write to
the Finance Minister seeking an exemption to the web-based reporting requirements.
The letter should detail the rationale and include information about whether the
exemption is to apply for a one-off grant, for the whole of the grant program or granting
activity or a particular grant round, or on an ongoing basis for a particular group of
grants. An example of a rationale is where Privacy Act 1988 considerations are prevalent.
Agency staff should consult the Grants Policy Team (grants@finance.gov.au) prior to
commencing this process.
1.2 Briefing requirements
20.
Ministers must not approve a grant or grants without first receiving written advice from
agency staff on the merits of the grant or grants.
21.
Where the minister is the grant approver, agency staff must provide written advice and
the minimum briefing requirements apply. Agency staff can include additional
information in the brief. At a minimum, the brief must include:
 information that the spending proposal is a grant
 applicable requirements of the FMA Act, FMA Regulations and the CGGs
 the legal authority for the grant
 information on the grant application and selection processes used
 the merits of proposed grants relative to the grant guidelines and value with
public money considerations.
When briefing ministers on the merits of a grant or group of grants relative to the grant
guidelines and achieving value with public money, agency staff should indicate: which
grant applications fully meet the selection criteria; which applications partially meet the
criteria; and which applications do not meet any of the criteria. Any specific
recommendations regarding grant applications for approval can be in addition to this
information.
22.
23.
In addition to the requirements in the CGGs, there are further requirements in the
FMA Act and FMA Regulations that apply to ministers, chief executives and agency staff.
For example, FMA Regulation 9 provides that an approver must not approve a spending
proposal unless the approver is satisfied, after reasonable inquiries, that giving effect to
the spending proposal would be a ‘proper use’ of Commonwealth resources.
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Part 1 – Requirements for agency staff
24.
Agency staff should refer to Attachment C, which outlines the minimum briefing
requirements and provides a checklist for agency staff to use when preparing advice
where ministers are approving grants.
25.
Where the approver of the grant or grants is a chief executive or delegate, agency staff
advising such approvers should still have regard to the minimum briefing requirements,
particularly in relation to advising on the merits of the proposed grant relative to the
grant guidelines and the key consideration of achieving value with public money.
1.3 Other reporting requirements
26.
In addition to the reporting requirements contained in the CGGs, there are other
Australian Government reporting requirements relating to grants, for example, the
Senate requires regular reporting of grant information in relation to:
 Procedural Orders of Continuing Effect 11: Departmental and agency contracts
 Procedural Orders of Continuing Effect 14: Departmental and agency grants.
27.
Further information on the Orders is available at:
http://www.aph.gov.au/About_Parliament/Senate/Powers_practice_n_procedures/stan
dingorders/d05.
28.
The Joint Committee of Public Accounts and Audit (JCPAA) sets the requirement for
agencies to include grants information in their annual reports. Information on the
requirement is available from the Department of the Prime Minister and Cabinet’
website at http:www.dpmc.gov.au/guidelines/.
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Part 2 – Requirements for ministers
Part 2 Requirements for ministers
2.1 Reporting requirements for ministers
29.
The CGGs apply to grants administration performed by: ministers; chief executives;
agency staff; and other bodies or third parties who are responsible for grants
administration on behalf of an agency. Granting activities should be underpinned by
solid governance structures and clear accountability for all parties involved in grants
administration, including ministers.
30.
The reporting requirements in the CGGs that apply to ministers were determined by the
Cabinet and are co-located in the CGGs for the purposes of clarity and transparency.
2.1.1
Electorate reporting
31.
Ministers can approve grants in their own electorate. If a minister (excluding a senator)
approves a grant within his or her own electorate, he or she must write to the Finance
Minister advising of the details as soon as practicable, unless an exemption applies
(see paragraphs 36 to 39 of this circular). A template letter is at Attachment D.
32.
Agency staff should advise their minister on whether a grant will provide for activities in
the minister’s own electorate. This should be identified in the brief to the minister when
advising on grants approval options, in line with the minimum briefing requirements.
33.
Circumstances where ministers must report on own electorate grants include where:
 the grant recipient’s address is in the minister’s own electorate
 the address of the recipient is outside the minister’s own electorate, but the grant
project (wholly or partly) will occur or be delivered in the minister’s electorate.
-
In the case where part of the grant is being delivered in the minister’s own
electorate, agency staff should report the amount to be delivered, if it is
known, otherwise report the whole amount.
2.1.2
Electorate reporting exceptions
34.
Senators who are ministers are not required to report to the Finance Minister where
they approve a grant in their own state or territory.
35.
Ministers do not need to report to the Finance Minister if the grant was approved by
someone else, for example:
 another minister in the portfolio
 the agency chief executive or
 agency staff, including a member of an expert panel.
36.
Ministers do not need to report to the Finance Minister grants they awarded in their own
electorate that are allocated on the basis of a formula Australia-wide, state-wide, or
regionally. For example, grants awarded in the minister’s own electorate do not need to
be reported in an Australia-wide program where grants are awarded solely on
population numbers.
37.
Even if a grant is reported to the Finance Minister, or is exempt from electorate
reporting, all grants must be reported on agency websites (see paragraphs 11 to 19 of
this circular).
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Part 2 – Requirements for ministers
2.1.3
Approval of grants that agency staff has recommended be rejected
38.
Ministers may approve grants that are not recommended by agency staff or that agency
staff has recommended be rejected.
39.
Recommendations or advice by agency staff must meet the minimum briefing
requirements (see paragraphs 21 to 25 in this circular).
40.
Where a minister, including a senator, approves a grant that the relevant agency staff has
recommended be rejected, he or she must report each instance annually to the Finance
Minister. Ministers must report by 31 March each year, for the preceding calendar year,
and the report must contain the details of the grant and the reason for the approval of
the grant.
41.
There are two circumstances of grant approvals that should be reported:
 where agency staff have made recommendations that a grant not be approved,
and the minister chooses to award the grant
 where no recommendations have been made, however, a minister chooses to
approve a grant where the application did not meet the eligibility and
assessment criteria.
42.
If a minister (excluding a senator) approves a grant, as described above, in his or her
own electorate, he or she must also report that grant to the Finance Minister (see
paragraphs 34 to 37 in this circular).
43.
The information that should be included in the annual report to the Finance Minister is
outlined at Attachment E.
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Part 3 – Requirements for grant recipients
Part 3 Requirements for grant recipients
3.1 Reporting requirements for grant recipients
44.
Granting activities affect not only the Australian Government and grant recipients, but
also the beneficiaries of a grant. Granting activities should be designed and implemented
so that grant recipients focus on outcomes and outputs for beneficiaries, while seeking
the most efficient and effective use of inputs.
45.
Grants administration processes should be proportional to the scale and risk profile of
the granting activity. Agency staff should ensure that grant processes appropriately
reflect the capabilities of grant recipients and accommodate the Australian
Government’s need for robust and accountable processes, consistent with the risks
involved.
46.
The CGGs do not mandate any reporting requirements for grant recipients. That said,
access to appropriate performance and other information from grant recipients is vital.
It can help evaluate whether a granting activity has achieved the desired outcome, and
whether a particular grant has achieved value with public money.
3.1.1
Performance measurement
47.
Performance reporting requirements and other information sought from grant
recipients are key inputs used by agency staff in evaluating whether outcomes have been
achieved and whether a particular grant has achieved value with public money.
Evaluation activities and performance measures should be specified in grant guidelines
and agreements.
48.
Agency staff should establish an appropriate performance framework, which can help
identify the key types of information from which to evaluate granting activities.
Performance measures should be a combination of performance indicators, activity
measures and evaluation. They should demonstrate: how much was done; how well it
was done; and whether the intended outcome was achieved.
49.
Any grants performance framework should be developed in consultation with key
stakeholders. Agency staff should work in partnership with grant recipients and other
stakeholders to ensure the performance measures are realistic, achievable and will track
progress against the outcomes for individual grants and overall granting activity.
3.1.2
Proportionality
50.
Agency staff should use the proportionality principle to inform the choice of the
application and selection process, the grant agreement to be used and the reporting and
acquittal requirements. In particular, agency staff should apply the proportionality
principle when determining the reporting and acquittal requirements for grants. Agency
staff should determine the volume, detail and frequency of reporting requirements,
proportional to the risks involved and policy outcomes being sought.
 Subject to transparency considerations and risk assessment, where a grant is
used to support the ongoing delivery of services from the same organisations
over a period of years, agency staff should consider streamlining reporting
requirements and evaluation measures, where the recipient has an established
record of compliance and performance. For example, by allowing for the
aggregation of reports and less frequent milestone reporting.
51.
While each agency will have its own risk framework and approach, the CGGs use three
broad categories: granting activity or grant program; the grantee or recipient; and the
projects, tasks or services. For low-risk granting activities, more streamlined reporting
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Part 3 – Requirements for grant recipients
requirements and evaluation measures should be developed and the low-risk grant
agreement template should be used. A further consideration is the agency’s reporting
requirements. That said, inappropriately or inflexibly applied agency standards and
accountability frameworks could impact on grant recipients.
3.1.3
Report once, use often
52.
Agency staff should apply the ‘report once, use often’ principle, when designing grants
application and reporting requirements. Agency staff should not seek information from
grant applicants and recipients that has already been provided to an Australian
Government entity and is available to agency staff. Agency staff must not request
information provided to the Australian Charities and Not-for-profits Commission (ACNC)
by an organisation regulated by them.
 Agency staff should discuss with the ACNC and other regulators the availability of
relevant information that could be used for application, reporting and acquittal
purposes. If an entity is registered with the ACNC, then a financial acquittal
should not be required, unless the granting activity is higher risk.
53.
The risk rating for a granting activity should be determined through considering risks to
the granting activity or grant program; the grantee or recipient; and the
project/task/services.
54.
If the granting activity risk is assessed by agency staff as low, and the entity is regulated
by the ACNC, then a financial acquittal of the grant should not be sought. However,
agency staff may seek a declaration or certification from the recipient that the funds
were spent on the purposes specified in the grant agreement, as well as requiring them
to identify any underspends.
55.
Whilst a financial acquittal may not be sought by agency staff, this does not prevent or
restrict the need for recipients to maintain financial and other records that would enable
a review of financial information, if circumstances required it. This is in line with the
requirement of the CGGs that a grant recipient’s own policies and procedures should
support the grant agreement and ensure effective and efficient governance and
accountability for the grant money they receive.
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Part 4 – Frequently asked questions
Part 4 Frequently asked questions
Q.1.
My minister awarded (approved) a grant in his own electorate last year, which
was not reported to the Finance Minister. Does he still need to write to the Finance
Minister?
Yes. Ministers who are members of the House of Representatives are required to report all3
grants awarded in their own electorate to the Finance Minister. The letter should include
the reason for the delay.
Q.2.
My minister approved a grant without a specific recommendation from agency
staff. Does she need to report this to the Finance Minister?
No. Whilst your minister may approve a grant under FMA Regulation 9 without a specific
recommendation by agency staff, the minister must not approve a grant without first
receiving written advice from agency staff on the merits of the proposed grant or group of
grants (CGGs paragraph 4.2).
If agency staff had recommended that a grant be rejected, then your minister would be
required to report the instance in his or her annual report to the Finance Minister (see
paragraphs 38 to 43 in this circular).
Q.3.
My minister decided to approve a grant that our agency recommended be rejected.
However, the grant was not awarded. Does he still need to report this decision?
Yes. The requirement to report grants against agency advice applies to the decisions of
your minister, and is not dependent on whether the grant was eventually awarded, or
whether a grant agreement was entered into.
Similarly, if your minister approves a grant within his or her own electorate, but the grant
is not awarded, your minister must still report his or her decision to approve the grant to
the Finance Minister.
Q.4.
Do variations to grant agreements need to be reported on agency websites?
Yes. Agency staff should reflect any major variations to grant agreements on their website,
especially if the variation involves additional funding or a significant extension in time.
Q.5.
Does the 14 day web-based reporting rule apply to variations to grant
agreements?
No. It is better practice for agency staff to amend the website to reflect the variation as
soon as is practicable.
Q.6.
Our agency has decided to co-fund a grant with another agency. Do we publish all
details of the total grant on our website, or only the amount that our agency is
funding?
The agency that enters into the grant agreement should report the whole grant on their
website. In the situation where both agencies enter into the grant agreement, then the lead
agency should report the grant.
In cases where there is both Australian Government and private sector funding for a
specific grant project, agencies are required to report only on the Australian Government
contribution.
3
Except for the situations described in paragraphs 34 to 36 in this circular.
Page 14 of 23
Finance Circular 2013/02
Department of Finance and Deregulation
Part 4 – Frequently asked questions
Q.7.
Q.8.
My minister awarded a grant that will benefit her own electorate, and also the
neighbouring electorate. Does she need to report the whole grant to the Finance
Minister?
Yes. Your minister should report to the Finance Minister4 the whole grant, noting the
amount of the grant that will benefit his or her electorate. If it is difficult to determine the
exact amount that will benefit his or her electorate, then your minister should note that the
exact amount benefiting his or her electorate cannot be quantified.
Our agency has undergone some machinery of government (MoG) changes and
now has responsibility for programs that have been moved from another agency.
Should we report on our agency’s website, the grants that were awarded by the
previous agency?
Yes. With MoG changes, the general principle is that records follow functions. Grants
information must be retained on agency websites for two financial years, regardless of
whether the functions that relate to the grants are transferred to another agency, or cease
to exist. An agency transferring functions should agree with the gaining agency as to the
date of transfer and then transfer the grants information accordingly.
The Australian Public Service Commission has provided comprehensive guidance on
implementing MoG changes http://www.apsc.gov.au/publications-and-media/currentpublications/implementing-machinery-of-government-changes.
There may be cases where the functions relating to the grants are being abolished or
transferred to an entity outside of government. If this is the case, then agency staff should
contact the National Archives of Australia http://www.naa.gov.au/recordsmanagement/help/index.aspx for further guidance.
The above does not apply to ministerial reporting requirements for grants
(CGGs paragraphs 4.2 to 4.4). The start date for ministerial reporting requirements is
linked to the date on which a minister is sworn-in as the responsible minister.
Q.9.
Is there a mandatory requirement to acquit a grant?
No. The CGGs do not mandate that a financial acquittal is required for a grant. Agency staff
should determine whether a financial acquittal is required. This decision should be based
on: the risks involved; consultation with the grant recipient; the cost of compliance; and
whether the entity has provided relevant information to an Australian Government
regulator and availability of this information to agency staff.
Q.10. Are audited financial statements required for financial acquittals?
No. Agency staff should determine whether a financial acquittal is required and what is
appropriate for a particular grant, taking into account the risks involved. Agency staff
should be aware that independently audited financial statements may be expensive and
difficult to source in rural and remote areas, or may comprise a large proportion of a low
value grant. If an entity is regulated by the ACNC, then a financial acquittal should not be
required, unless the granting activity is higher risk. Agency staff may instead seek a
certification from the recipient that the grant money was spent for the purpose and
information on any underspends.
4
Except for the situations described in paragraphs 34 to 36 in this circular.
Page 15 of 23
Finance Circular 2013/02
Department of Finance and Deregulation
Part 4 – Frequently asked questions
Q.11. Our agency has a grant program that has been in place for a number of years. All
grant agreements are in place and there will be no further funding rounds, new
grant agreements or variations. Do we have to review our guidelines to ensure
that they are consistent with the new CGGs?
No. You will only need to review your grant guidelines where a significant change occurs,
such as a new funding round, or an extension of the current funding round that would
result in new grant agreements being entered into. Another example of a significant
change would be the changing of the risk profile associated with the granting activity if it is
ongoing. You can contact Finance (grants@finance.gov.au) for advice on the need to revise
your grant guidelines if you are unsure.
Q.12. The CGGs require agencies to develop grant guidelines for all new granting
activities. Does this requirement apply to one-off or ad hoc grants?
It depends. A one-off or ad hoc grant generally does not involve planned selection processes
and is designed to meet a specific need, often due to urgency or other circumstances. These
grants are generally not available to a range of applicants or on an ongoing basis. These
granting activities generally do not require specific grant guidelines unless the grant is
significant.
However, if your agency is proposing a significant grant, a number of potential one-off or
ad hoc grants that relate to similar purposes, or are of a recurring nature, you should look
for opportunities to incorporate those grants within a program where practicable. You can
contact Finance (grants@finance.gov.au) for further advice.
Where your agency provides one-off or ad hoc grants on a regular basis, agency staff
should develop an overarching set of generic grant guidelines, consistent with the CGGs,
which set out how such granting activities will be conducted.
Page 16 of 23
Finance Circular 2013/02
Department of Finance and Deregulation
Attachment A
Grant guidelines – Better practice checklist
Grant guidelines should be a single reference point for all potential applicants. They should be clear,
consistent and fit for purpose. They should include information on the outcomes and objectives of
the grant; governance arrangements, including roles and responsibilities; application and selection
requirements and processes, performance monitoring; reporting and evaluation; funding amounts
and arrangements; grant agreement arrangements; operational issues; legislative authority and
complaint handling.
The list below identifies the type of information that should generally be included in grant guidelines.
It is not an exhaustive list, but provides a guide to assist agency staff to prepare guidelines.
Heading
Objective
Eligibility
Application
process
Information guidelines should contain

Are the purpose, outcomes and objectives of the granting activity(ies) clearly
defined?

Do the objectives link to government policy outcomes?

Do the guidelines clearly identify the key priorities – e.g. targeted regions?

Do the guidelines clearly identify who is eligible to apply – e.g. individuals, specific
business structures, government entities, certain groups or industry?

Is there anyone who cannot apply for funding?

Are there any provisions to allow for one-off or ad hoc grants?

Are there specific eligibility criteria that must be met – e.g. must have an ABN/ACN?

Are there cases where the eligibility criteria can be waived?

Do the guidelines list the opening and closing dates for applications? Is it clear if late
applications will be accepted, and if so, under what circumstances?
Are the methods of applying and lodgement clearly outlined – e.g. email, online,
post?
Are all relevant forms, templates and other documents included or are there web
links to where materials can be found?
Do the guidelines identify processes, should a state or territory entity apply? How will
these applications be considered?



Funding

Will applicants need to submit a detailed budget as part of their proposal?

Are all the necessary contact details provided to allow applicants to apply?

Do the guidelines specify any other attachments that must be included – e.g. letters
of support, detailed technical specifications etc?

Do the guidelines outline the total funding that is available and over what period of
time?
Do the guidelines specify how much funding is available per grant or whether there
are limitations on the amount that can be applied for? Are there any exemptions?
Are the guidelines clear about what items are eligible for funding? Are there items
ineligible for funding?



Do the guidelines specify timeframes – e.g. are multi-year grants available?

Do the guidelines discuss any relevant tax implications – e.g. whether goods and
services tax applies?
Page 17 of 23
Finance Circular 2013/02
Department of Finance and Deregulation

Attachment A
Heading
Grant
agreement
Selection
process
Information guidelines should contain

What are the terms and conditions that recipients would need to comply with – e.g. is
there an example grant agreement? Will the terms and conditions be varied for
different types of organisations, such as state government entities?

What are the record keeping, reporting and acquittal requirements that recipients
would need to comply with?

How will the grant be monitored? Are there any performance reporting
requirements recipients would need to comply with? Will there be milestone
payments?

What is the process where recipients fail to meet obligations?

Do the guidelines clearly outline the selection process – e.g. open competitive,
targeted, open or closed non-competitive, demand-driven selection (See CGGs para
13.11)?
Do the guidelines detail the selection criteria against which eligible applications will
be assessed?
Do the guidelines specify what applicants need to address for each of the selection
criteria? Do word limits apply?
Do the guidelines detail the weighting attached to each selection criterion? Do
applicants have to successfully address all selection criteria?
Do the guidelines state how value with public money considerations will be taken into
account in the awarding of grants?
Is an external advisory panel used to provide input? If so, which and what type of
bodies or industries are on it?





Decision
making

Are the roles and responsibilities of all parties clearly defined? What roles do the
agency and minister have? What role do external experts have?

Is the assessment made by a panel? If so, who comprises the panel?

Do the guidelines discuss conflict of interest, bias and associated obligations on
agency staff and applicants, and how these will be managed?
Do the guidelines identify who will make recommendations – e.g. departmental staff,
independent subject matter experts?
Who will be the ultimate decision maker – e.g. the minister, agency chief executive or
a delegate?


Other

How will the successful and unsuccessful applicants be advised?

What are the feedback and complaint handling mechanisms? Do the guidelines set
out the avenues of appeal?

Do the guidelines discuss how the grant activity or grant program will be evaluated?

Do the guidelines discuss the Privacy Act 1988 and associated obligations on agency
staff and applicants?
Are program specific issues, such as the provision of equipment or premises by the
Commonwealth clearly explained?
Do the guidelines set out any additional requirements, such as relevant qualifications
for grant recipient staff or applicable legislation?


Page 18 of 23
Finance Circular 2013/02
Department of Finance and Deregulation

Attachment B
Template – Publishing grant information on agency websites
Use the program title contained in the
Portfolio Budget Statements/Central Budget
Management System (CBMS). One-off grants
not aligned to a grant program should
include the word ‘one-off’ in the program
title. Sub-program can also be the program
component or other identifier.
Agency
DEEWR
Enter the
portfolio/
agency.
CBMS
program
title
Framework
Education
Program
Subprogram
Higher
Education
Research
Fund
Project
title
Use the
recipient’s
legal name
and
ABN/ACN, if
applicable.
Grant
recipient
Are there special confidentiality
provisions in the grant
agreement? For guidance, see
http://www.finance.gov.au/proc
urement/procurement-policyand-guidance/buying/reportingrequirements/reportingconfidentiality/principles.html.
Purpose
Education
Finmaville
Provide 10 computers
and Training College Pty Ltd for a training course.
for the
Unemployed
Use the project title in the grant
agreement, letter of offer,
contract or instrument, as
appropriate.
Enter the purpose for which
the grant money has been
provided.
Use the date the grant
agreement takes effect,
which can be either the
date that the agreement
is entered into, or a
specified starting date.
Special
confidentiality
provisions
(Y/N), and
reason
Value
Y – Intellectual
property
$20,000
Enter the total
number of months
that the grant
agreement is for.
Commencement
date
15/06/2013
Enter the total amount approved
for the grant across all years of the
grant in whole dollars, GST
inclusive.
Grant term
(months)
24
Use the postcode
where the grant
money will be
primarily used.
Grant funding
location
Postcode
Dickson, ACT
Enter the state and suburb where the grant
money will be primarily used. For grants that
are provided to multiple postcodes (e.g.
Australia-wide, state-wide or regional
grants), provide details that best describe the
area where funding is to be provided. For
example: Riverina, NSW, national.
Note: if personal information is omitted due to the Privacy Act 1988, insert ‘Privacy Act’ in
relevant columns where privacy information has been omitted.
Page 19 of 23
2602
Finance Circular 2013/02
Department of Finance and Deregulation
Attachment C
Checklist for agency staff briefing ministers on proposed grants
The Commonwealth Grant Guidelines (CGGs) require that ministers must not approve a grant before
receiving written agency advice on the merits of the proposed grant, and this advice must at a
minimum:
a. explicitly note that the spending proposal being considered is a ‘grant’
b. provide information on the applicable requirements of the Financial Management and
Accountability Act 1997 and related Regulations; the CGGs (particularly any ministerial
reporting obligations), including the legal authority for the grant
c. outline the application and selection processes, including the selection criteria, that were
used to select potential grant recipients
d. include the merits of the proposed grant or grants relative to the grant guidelines and the
key consideration of achieving value with public money.
There are many considerations that a minister needs to take into account before deciding to award a
grant. This checklist contains a list of items that agency staff should consider when preparing the
brief for ministers. Note that the list provided is not exhaustive and agency staff can include
additional information in the brief.
Heading
Information that should be considered when preparing briefs
Recommendation
section of the
brief
Supporting
information in
the brief or
relevant
attachments

Is FMA Regulation 9 approval identified?






Recommendations for proposed grant(s) or group of grants has
been outlined?
While flexibility exists for agency staff on how they present grant
recommendations, it needs to be clear which grant applications fully,
partially or did not meet the selection criteria.
Is there an explicit statement identifying that the spending
proposal is a ‘grant’?
a) It is not sufficient to simply refer to a ‘spending proposal’.
You may wish to refer to the decision tree and matrix included in
Finance Circular 2013/01 Grants, Procurements and other Financial
Arrangements, to confirm that the financial arrangement is a grant
Has the legal basis for the grant been identified? Legal basis can
be provided by:
a) section 44 of the FMA Act
b) specific legislation
c) section 32B of the FMA Act, and Schedule 1AA of the
FMA Regulations.
 Has information been included to meet the applicable
requirements of the FMA Act and FMA Regulations:
a) FMA Regulation 8
b) FMA Regulation 9
c) FMA Regulation 10, where offering multi-year grants or
grants that span two or more financial years
d) FMA Regulation 12, which requires ministers to record the
basis for the approval of the grant when approving it.
Refer to Finance Circular 2011/01 Commitments to Spend Public Money
(FMA Regulations 7 to 12)
Page 20 of 23


Finance Circular 2013/02
Department of Finance and Deregulation
Attachment C

Is there information that advises the minister on approving
grants in their own electorate; and grants that have been
recommended be rejected by the agency?
a) Proposed grants in the minister’s own electorate have been
identified
b) It is clear which grants have been rejected by the agency.
This may be met by identifying which grant applications
did not meet the selection criteria.

Has the selection (eligibility and assessment) criteria and the
relative weights been included?
 Has the type of application and selection process been
identified? Some examples include:
a) open competitive assessment
b) targeted competitive assessment
c) closed non-competitive selection
d) eligibility criteria are met, no competitive assessment
e) one-off or ad hoc basis.
For more information on types of selection processes, refer to
paragraph 13.11 of the CGGs.


Page 21 of 23
Is there information on the merits of the grant applications?
While there is flexibility for agency staff in how to present the
merits of grants:
o is it clear which grant applications fully, partially or did
not meet the selection criteria? Applications that fully
met the selection criteria can be further categorised
using the rating scales used in the appraisal process.
Has information outlining how the proposed grants represent
value with public money been included?
Consider the following items:
o how the proposed grants will achieve Australian
Government policy objectives
o agency grants management risk approach to all phases
of grants administration
o consultation undertaken with non-government sector,
in particular, when planning and designing the granting
activity
o co-funding arrangements (if applicable)
o length of term of grant agreements
o recipient capability to deliver on outcomes sought.





Finance Circular 2013/02
Department of Finance and Deregulation
Attachment D
Template – Grants awarded in minister’s own electorate
Minister for Finance and Deregulation
Parliament House
CANBERRA ACT 2600
Dear Minister,
I am writing to notify you of a grant that I approved in my electorate, as required by
paragraph 4.3 of the Commonwealth Grant Guidelines.
The grant was assessed as part of [an open, competitive, merit–based process] [a targeted
process] and was recommended for approval by [the expert panel engaged to assess the grant
on its merits][agency staff within my agency].
Details of the grant are [included in the table below][contained in the copy of the attached
letter to the grant recipient].
Please contact [agency staff] on [phone] if you have any queries regarding this grant.
Program
title
Project
title
Grant
recipient
Grant
funding
location
Grant
amount
Grant
term
Commencement
date
Yours sincerely
Page 22 of 23
Finance Circular 2013/02
Department of Finance and Deregulation
Attachment E
Template – Annual ministerial report where a minister has approved a grant that the relevant department or agency staff
recommended be rejected.
Use the program title contained
in the Portfolio Budget
Statements/Central Budget
Management System (CBMS).
Sub-program can also be the
program component or other
identifier
Use the recipient’s legal
name and ABN/ACN, if
applicable.
Enter the postcode
where the grant money
was primarily
provided.
CBMS
program
title
Sub-program
Project title
Grant recipient
Total grant
value
Grant
funding
location
Postcode
Framework
Education
Program
Higher
Education
Research Fund
Education
and Training
for the
Unemployed
Finmaville
College Pty Ltd
$20,000
Dickson,
ACT
2602
Use the project title in the grant
agreement, letter of offer, contract
or instrument, as appropriate.
Page 23 of 23
Enter the total amount approved
for the grant across all years of
the grant in whole dollars, GST
inclusive.
Record the reasons why the minister decided to award the
grant. Include the key factors underpinning the decision that
are specific to the grant. It would not be sufficient to make a
general statement such as ‘would make an effective and
efficient use of resources’, ‘met the selection criteria’, or ‘did
not agree with agency advice’, etc. The reason recorded
here may be different to recording the basis of the approval
as required by FMA Regulation 12.
Brief statement of reason for decision
Consistent with the Government’s policy on education and training, I
considered that greater emphasis should be placed on access to training for the
unemployed. Finmaville College specifically targets the unemployed in its
programs, and does so cost effectively.
Enter the state and suburb where the grant money
will be primarily used. For grants that are provided
to multiple postcodes (e.g. Australia wide, statewide or regional grants), provide details that best
describe the area where funding is to be provided.
For example: Riverina, NSW, national.
Note: FMA Regulation 12
requires the approver of a
spending proposal relating to a
grant also record the basis of
the approval.
Finance Circular 2013/02
Department of Finance and Deregulation