Response to Discussion Paper
Enhanced Commonwealth Performance Framework
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:
Australian Reinsurance Pool Corporation
Contact name:
Alison Kelly
Contact position:
General Manager, Governance, Risk and Compliance
Telephone:
02 6279 2105
Email:
alison.kelly@arpc.gov.au
Australian Reinsurance Pool Corporation - Opening Statement
Thank you for the opportunity to provide comment on the Enhance Commonwealth
Performance Framework discussion paper.
The Australian Reinsurance Pool Corporation (ARPC) is a statutory authority established
under the Terrorism Insurance Act 2003 (TI Act), being subject also to requirements under
the Public Governance, Performance and Accountability Act 2013 (PGPA Act). ARPC is a
corporate Commonwealth entity under the PGPA Act; it is governed by a Board, which is
ARPC’s accountable authority.
ARPC established and continues to provide ongoing administration of a terrorism insurance
scheme, which will provide insurance cover for eligible terrorism losses and pay eligible
claims, should a declared terrorist incident (DTI) occur in Australia.
ARPC is wholly self-funding through prudent management of accumulated premium and
investment revenue. We have never received any Commonwealth appropriation. Our
annual operational budget must be approved by the Board; monthly financial reporting
against the approved Budget is provided to the Board. We currently do not report through
the Central Budgetary Management System (CBMS).
Due to the fact that we have never received Commonwealth appropriation, ARPC has never
been required to produce a Parliamentary Budget Statement (PBS), nor has it been required
to appear before Senate Estimates.
ARPC has a single, legislated function, which is to provide terrorism insurance for eligible
policies in the event of a DTI. Therefore we do not have programs or outcomes against
which we report. We provide an Annual Report to our responsible Minister, as was required
by the Commonwealth Authorities and Companies Act 1997 (CAC Act), and will continue to
do so under the PGPA Act.
ARPC is in agreement with the principles of the PGPA Act in providing a performance
framework for all Commonwealth entities. To this end, over the past twelve months the
ARPC Board and Executive Management have been working together to prepare our first
Corporate Plan, and are awaiting the finalisation of requirements for both the Corporate Plan
and the Annual Performance Statements. ARPC’s preference would be for the Corporate
Plan to be provided by 31 August each year.
Despite being in favour of more consistent performance reporting, ARPC is strongly of the
view that we do not need to provide a PBS. In particular, as ARPC does not receive
appropriation, and does not have programs or outcomes on which we report, ARPC believes
the Parliament would gain little or no value from a PBS, should we have the systems to
produce it. Providing a PBS each year would be considered additional red tape and an
unnecessary administrative burden for an organisation of our size.
ARPC has provided specific comments against subjects within the template provided, as
appropriate to our current operations.
Topic and key questions
Feedback
Portfolio Budget Statements
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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?
No
Yes , as appropriate to their
operations
Do not provide a PBS - no
comment.
Do not provide a PBS - no
comment.
Do not provide a PBS - no
comment.
Do not provide a PBS, but ARPC
would prefer the Corporate Plan is
due 31 August each year.
ARPC would prefer all Corporate
Plan information is provided at the
time of publishing - 31 August
each year.
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Topic and key questions
Feedback
More flexible performance planning, monitoring
and reporting arrangements
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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?
Terrorism insurance data is not
applicable to general government
decision making.
N/A
Perhaps case study analysis to
account for diversity of entity
requirements
Considering the potential volume
of KPI information, not sure of the
value-add for Government/the
public, particularly if they are not
conversant with the context.
N/A
N/A
N/A
N/A
N/A
No PBS, so no comment.
No PBS, so no comment
No PBS, so no comment.
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Topic and key questions
Feedback
Corporate plans
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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?
No
Do you have any suggestions on how to tier
existing performance reporting requirements?
No – but should be appropriate to
the risk rating applicable to each
entity.
Yes
There should be no duplication of
reporting. ARPC already reports
on many of the topics listed under
the Corporate Plan inclusions
through our Annual Report. We
would not want to be required to
duplicate our reporting. Thus the
Annual Report Rule must be
mindful of the Corporate Plan
requirements.
Timeframe for updates
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Would a four-year plan support medium- to
long-term 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?
Yes
Yes, but only for significant
changes to an entities operations,
otherwise annually.
See main comment above
Need to see new required
structure of Annual Report under
PGPA before we can comment
Annual performance statements
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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?
ARPC does not have Programs or
Outcomes. Hence our Annual
Performance Statement will need
to be specifically tailored. We
would like to discuss this one-onone with PMRA staff.
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Topic and key questions
Feedback
Cross-entity activities
Perhaps the Lead Agency inherits
the reporting requirement, with
others referring to the lead agency
report. Ensure NPPs do not make
shared outcome requirements of
agencies that are not provided for
in their AAOs
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How best can cross-entity activities be
measured?
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How should guidance be developed to assist
entities to improve their measurement and
reporting of cross-entity activities?
Utilise any best practice examples
which could be cherry-picked. Use
ANAO recommendations in their
Report No 29 2009.
Monitoring and evaluation
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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?
No – entity diversity may not be
well accounted for by a more
formal regime.
Yes, this would provide flexibility to
tailor practices that would account
for diversity of entity operations.
Performance plans
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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?
Proposed elements of a performance plan
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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
The comment below applies to the
concept of Performance Plans:
ARPC does not provide a PBS and
holds the strong view that this
should continue, for the reasons
provided in our Opening
Statement. Hence we would not
provide a performance plan,
should that be introduced.
Looking at Attachment I, the
example of a Performance Plan,
this clearly does not fit with ARPC
operations.
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Topic and key questions
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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?
Feedback
See comments on previous page..
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