Enhanced Commonwealth Performance Framework Discussion Paper — August 2014 Key points from the ARC perspective The ARC currently reports on much of the performance information highlighted in the discussion paper, all be it in a slightly different format from that proposed. However, the ARC, like other small government agencies, feels the impact of regulatory change to a greater extent than larger departments. We ask that the scope of the changes to performance information, Portfolio Budget Statements (PBS) and corporate plan as well as the level of guidance to be provided by the Department of Finance, takes this into consideration. Current ARC requirements Under the Australian Research Council Act 2001 (ARC Act), the CEO must prepare a corporate plan for approval by the Minister. The ARC Act has been amended in line with the requirements under the Public Governance, Performance and Accountability Act 2013. The ARC’s annual report must include an assessment of the CEO’s performance of his or her functions during that period. The ARC’s Annual Report and Corporate Plan must be tabled in both Houses of Parliament. Performance Framework We believe that the detailed performance information should be included in each entity’s corporate plan, not the Portfolio Budget Statements (PBS). The PBS is already a complex document and the primary focus should remain on resource allocation. The performance information will still be tabled in Parliament if it is published in the corporate plan instead of the PBS. Separating the publication of resource allocation and performance planning will improve readability and scrutiny of both. Separating the tabling of the two documents has the potential to improve the profile (and therefore scrutiny) of performance information that may be lost in the detail of the PBS. We note the proposed 31 August deadline for publication of corporate plans. A number of business and parliamentary-related factors could limit agencies’ ability to meet this deadline. Guidance material should allow entities to adopt performance measures to suit their business. We support allowing a degree of flexibility in measuring performance, and not relying solely on key performance indicators. We would like to note that measuring the outcomes of research, particularly basic research, are difficult to quantify and often have long lead times. The introduction of new regulatory requirements is a general concern for the ARC. A clear approach with appropriate supporting guidance on all facets of the framework is needed as soon as possible to ease the initial reporting burden. As a smaller agency the ARC is interested in the proposal for tiered reporting, but would like to see more detail on how this would work. Portfolio Budget Statements The proposed changes to the financial aspects of the PBS are not expected to have a large impact on the ARC. We support addressing the cash and accrual issues in the agency resourcing statement to achieve a clearer link with Appropriation Bill amounts as there is some confusion around this. Some caution should be shown in merging and rationalising the movement of funds table and the agency resourcing statement as this could add complexity and reduce readability. Consideration should be given to the AASB 1055 Budgetary Reporting requirements and the effect any changes to the PBS will have on the annual Financial Statement reporting. Corporate Plan There should be strict rules regarding the updating of corporate plans, in line with requirements to update the PBS (e.g. should be released annually and updated to reflect changes in the PBS). Reporting against the corporate plan should be incorporated into all relevant sections of the annual report, most likely parts two and three. Annual Performance Statement The annual performance statement has the potential to increase the reporting burden on agencies and related stakeholders, whilst not necessarily improving performance reporting or line of sight between the three key documents (corporate plan, annual report and PBS). We suggest including the structure of the statement in all three documents for planning and reporting performance to enable a clear line of sight. Performance Plan Producing a performance plan will likely introduce an additional burden on agencies. It is not clear what will be gained by providing this level of detail to stakeholders beyond the individual agency. The performance information provided by agencies should be meaningful and able to be reported against. Energy may be better focused on making sure this is the case rather than increasing the information available around performance. Audit The complexities of performance measurement and the variations behind how each agency can and will measure their performance would, in our view, make auditing performance information in a similar way to the annual audit of financial statements, unfeasible. A mix of ANAO performance audits, internal audits, and scrutiny from an agency’s audit committee is considered sufficient. Other There needs to be further guidance on the proposed inclusion of compliance information in the corporate plan, noting that compliance information is already contained in annual reports. We require further guidance on cross-agency reporting. If this reporting requirement is challenging to implement, it may be better to introduce this as a staged process, allowing agencies to focus on getting the rest of the framework in place initially.