Feedback form
Finance is seeking consolidated feedback from each entity on topics covered in the discussion
paper. The key topic areas are identified in the table below, together with related discussion
questions. These questions have been included to stimulate broad consideration of options to
enhance the performance framework. It is not necessary to answer all of the discussion
questions, or to provide feedback on every topic.
Name of entity:
AOFM
Contact name:
Samantha Montenegro
Contact position:
Chief Risk and Compliance Officer
Telephone:
6263 1132
Email:
Samantha.montenegro@aofm.gov.au
General comments:
The paper seems to go beyond its stated remit of establishing a performance management
framework and what constitutes meaningful KPIs (which it does not pragmatically discuss in
the context of what the government is seeking to achieve through this work). Rather it seems to
be overly concerned with examining the appropriation, budget and financial reporting
frameworks and requirements, and the placement of information within existing documents
(PBS, AR, corporate plans) under these frameworks. We expected the paper to shed some light
on what information the government is seeking at a consolidated level as a means to
understanding how we can best design KPIs and place them within the existing documents to
meet our reporting and performance obligations.
We strongly object to the idea that the corporate plan is a compliance document. The corporate
plan is about our vision and future activities to meet our outcome requirements, not a document
to tick and flick on meeting legislative and policy requirements. We have a compliance
framework to manage this, and our reporting obligations under the PGPA Act (and other Acts
like the LSDs, FCGs) allow us to report meaningfully on compliance matters already.
We are confused over how much of the existing frameworks are up for modification. Ideally, we
would appreciate as little duplication in reporting requirements as possible – as the PBS has
similar requirements to the corporate plans, and then the Annual Reports have similar
requirements too (although the AR is more about reporting on the work done/results, rather
than the work planned/budgets).
We have attempted to respond to the questions posed in the tables following.
Commonwealth Non-Financial Performance Framework—Discussion Paper
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Topic and key questions
Portfolio Budget Statements
- Should all corporate and non-corporate
Commonwealth entities be required to complete
Portfolio Budget Statements?
- Should Commonwealth entities that don’t
prepare Portfolio Budget Statements place
performance information in their corporate plans
instead?
- Should the Portfolio Budget Statements contain
only non-financial performance information, with
all financial information published in the core
budget documents (Budget Papers 1 to 4)?
- Are the Portfolio Budget Statements the best
location for detailed entity performance
information?
- Would entities and the Parliament be better
served if all performance information was
removed from the Portfolio Budget Statements
and instead published as a core element of
entities’ corporate plans?
- If so, should corporate plans be published in
conjunction with the Portfolio Budget Statements
on budget night to expand the range of
information available to Parliament as it
considers the annual Appropriation Bills?
- Could non-financial performance information be
provided electronically on budget night and
published in the corporate plan?
Feedback
The need for PBS is a decision for
Finance. Is it useful to the
stakeholders you prepare it for?
Does it meet its purpose?
Performance targets should be in
the corporate plan, and results
reported in the Annual Report or
performance statement at year end
(or periodically during the year).
Outcome statements are often too
broad with factors outside agency
control to get meaningful KPIs
against – it is when the entity drills
down to programme objectives and
activities in support of outcomes
that clarity around measures is
possible. If the KPIs are in the PBS
it may suggest appropriation usage
is the more relevant measure of
success.
The financial information (other
than the budgeted statements as
they are too granular) could stay in
the PBS to support the
appropriations, with the Budget
Papers offering a consolidated view.
Potentially the budgeted financials
would be better placed in the
corporate plan to support the
resourcing proposed. If funding is
not provided, the impact of reduced
funding can then be related to the
programmes/activities of the entity.
Corporate plans could be submitted
in draft with the PBS, but the
information in the PBS is probably
sufficient as an overview – Finance
would know better than agencies if
this is the case.
Topic and key questions
Feedback
More flexible performance planning, monitoring and
reporting arrangements
- What is the scope for the internal datasets
currently collected in your entity being leveraged
for publishable data to support better tactical and
strategic decision-making in government?
- What considerations need to be taken into
account in growing new datasets ready for
publication?
- What sort of guidance should Finance provide on
performance measurement tools?
- What level of detail should Finance provide on
performance measurement tools?
- What level of guidance is appropriate regarding
which performance measurement tools work
best in particular circumstances?
- Should all KPIs be reported publicly on an annual
basis?
- Should entities plan and report on performance
at a programme level?
- Should entities plan and report on performance
at a sub-programme or major activity level?
- What level of performance reporting best serves
entities’ and Parliament’s purposes?
- What level of reporting delivers the best
outcomes for entities and Parliament in
comparison to the effort required to produce it?
- Should a programme expenditure materiality
threshold be applied to support a simpler
approach?
- Should the annual performance plans be subject
to coordinated and/or centralised review, or is
entity self-assessment sufficient?
- Who would be best placed to conduct
coordinated and/or centralised reviews?
There is scope for this, but there is a
need to understand what the
stakeholders view as meaningful.
We already use information to
inform our planning processes and
decision making.
Some considerations include data
quality (timely/relevant),
completeness, cost,
maintenance/ownership,
access/privacy, sharing data, IT and
people capability.
It may be useful if Finance did some
research and published guidance to
assist agencies, or ran info sessions.
Not all KPIs are relevant for
outcome performance, some are
used for internal management
decisions.
Outcome, or possibly programme,
level reporting externally is
sufficient and appropriate, but the
entity should maintain more
detailed information to manage
delivery.
Thresholds can be problematic –
but a trial could be undertaken to
explore its viability. The threshold
($ or %?) would no doubt change
over time – but how?
ANAO has the mandate to review
performance information. Would
Finance’s Budget Group program
reviews continue on a selective
basis as an independent process?
This may well be worthwhile (from
the government’s perspective to
confirm the programmes are
delivering and continue to be
relevant). Or Finance could seek
funding to run a “Gateway” style
service using suitable external
consultants, but perhaps with the
goal of helping agencies to set up
sound KPIs rather than to punish
agencies for their early efforts.
Topic and key questions
Feedback
Corporate plans
- Do you have any suggested inclusions or
deletions for the requirements of corporate plans
suggested in Section 2.2 of the discussion paper?
- Is the proposed list of inclusions in a corporate
plan appropriate?
- Do you have any suggestions on removing
existing duplicative reporting?
- Do you have any suggestions on how to tier
existing performance reporting requirements?
The Corporate Plan is not a
repository for compliance
information or a reporting tool.
It is the key planning document of
an agency that needs to articulate
matters such as its purpose, risks,
objectives, deliverables, resources
to be applied and projects. It could
articulate key KPIs, with lower level
plans having subsidiary KPIs that
feed into the key KPIs, which are
reported on periodically or at year
end via the Annual Report (incl
compliance levels).
Timeframe for updates
- Would a four-year plan support medium- to longterm strategic planning?
- Should corporate plans be a living document and
be updated as needed?
- Should the proposed corporate planning rule set
some of the requirements for updating corporate
plans?
- Should entities report progress against the
corporate plan under Part 3 (management and
accountability) of their annual reports?
The information from the CP will
inform the PBS summary, not vice
versa. The list of inclusions should
not be set in concrete, rather key
matters to be covered in a corporate
plan should be listed. This avoids
argument over style. For instance,
should a SWOT and risk assessment
discussion come before priorities –
as these will inform those decisions.
Sector outlook does not resonate
with all – use generic terms like risk
assessments which will better cover
all relevant considerations.
Performance information as it is
presented in your paper seems
more related to budget/
appropriation spend.
Corporate governance section
seems more relevant for the annual
report. The investment strategy
items highlight that the budgeted
financials probably belong in the
corporate plan, not the PBS.
A four year plan is achievable,
understanding that underlying
factors may change. At a WOG level,
setting the annual reporting date is
sufficient, then entities can review
as frequently as they need (as this
will differ). Performance against
the CP could be in the AR (and/or in
the following year CP).
Topic and key questions
Feedback
Annual performance statements
- Is the level of information proposed to be
reported in entities’ performance statements
appropriate?
- How should copies of annual performance
statements be included in annual reports?
The listed items seem reasonable,
although it is uncertain what
information the stakeholders want.
The actual spend could go with the
results achieved section – and
surely we don’t have to report on
“performance” since inception – a
plus/minus 4 years window is
probably sufficient otherwise it may
take a long time to notice a program
is in decline, as well as placing large
administrative burdens where this
information is not available for
existing long standing programmes.
Activities involving key partners is
problematic – confidentiality
/blame shifting/consistency/etc
would need to be resolved.
The statement can go in the AR –
maybe at part 2? Although maybe
part 2 and 3 should be switched as
we should report on our
governance/background, then
performance. The level of reporting
suggested in the discussion paper is
unclear – it could be onerous if
expectations are not clear and
managed.
Cross-entity activities
- How best can cross-entity activities be
measured?
- How should guidance be developed to assist
entities to improve their measurement and
reporting of cross-entity activities?
There should be an MOU
established that articulates the
information relevant to purpose and
performance.
Measurement principles are similar
within and across entities if purpose
and responsibilities are clear. A
complication comes when trying to
measure across time or for largely
qualitative outcomes (eg
behavioural).
Topic and key questions
Feedback
Monitoring and evaluation
- Is there a benefit in having a more formal regime
that identifies areas for review in a more
coherent manner than currently exists?
- Is there a benefit in providing improved
consistent guidance material and allowing
entities to adopt practices based on that
guidance?
It is not clear what is being
proposed so difficult to comment.
Performance plans
- Would performance plans help to improve the
quality of non-financial reporting by
Commonwealth entities by improving front-end
planning?
- At what level should performance information
and performance plans be developed and
reported by entities?
- Would a performance plan draw out early
feedback on the appropriateness of particular
performance measurements?
The performance plans would
presumably be part of the corporate
planning process, and lead to the
population of the performance
statement. Whether a separate
detailed, published document is
needed is uncertain – agencies
would not appreciate having yet
another template to populate
without a clear justification of
purpose or need, which is not clear
from the discussion paper. A
worked example of the operation
and connectedness of the PBS, CP,
AR and other elements across the
frameworks would help to enable
an informed debate on this.
Proposed elements of a performance plan
- Could the financial information provided in the
current programme expenses table in the
Portfolio Budget Statements be restructured,
over time, to represent more of a resourcing
view, rather than an appropriation view?
- Could the table represent resources available to
an organisation under the broad headings of
‘Annual appropriations’, ‘Special appropriations’
and ‘Other’, and also show capital directly
attributable to the programme?
- Is the level of information proposed to be
included in performance plans appropriate and
useful? How can this be improved?
- How much information and effort should be
required at each level of reporting, especially
where the outcome, risk and complexity are
assessed as being low?
- If a performance plan was adopted, what would
be the key enablers for its success?
- If a performance plan was adopted, when might
be an appropriate time for its introduction?
PBS, ARs and even CPs are already
published, but isn’t this paper about
performance measurement? Isn’t it
the agency and minister’s role to
assess performance of its
programs? The Audit Committee is
not a decision making body and
cannot direct government policy, so
suggesting they can assess the
performance of programmes is
misplaced – they perform an
assurance role (evidence that risks
and controls are being managed
through effective governance).
The information proposed may
already exist in lower level
documents for programme
management so it may be a matter
of consolidation. Again – what do
stakeholders need or want to know?