Can Ministers and other approvers change grant award recommendations or are they just a rubber stamp?

Organisations often put a lot of time and effort into preparing a grant application which fuels expectations. They deserve to have their applications properly considered and for grants to be based on merit.

If this doesn’t happen, unsuccessful grant applicants may become annoyed and even complain. Ministers can face claims of bias or pork-barrelling. It is a story all too often in the media.

Use of a competitive, merit-based selection process can help avoid or defend such claims. So can application of probity principles:

• documented assessment processes demonstrating a transparent and accountable approach and supported by well-developed procedures
• conduct that demonstrates integrity, honesty, and impartiality.

The goals of the grant program should be clearly articulated. Make sure there is clarity about the funding available. For Commonwealth grants check that the grant program is legally permitted.

Follow any government guidelines or policies applying to the grant program, e.g. Commonwealth Grants Rules and Guidelines 2017 (CGRGs) and in Victoria the Local Jobs First Policy.

Specify eligibility or mandatory criteria as well as the primary assessment criteria (with any weightings). This information should be made available to prospective applicants. The criteria should reflect the grant program’s objectives and comply with government policies. The aim is to promote the goals of the program whilst achieving value with the relevant money.

Response requirements should align with the criteria. Don’t request information that won’t be considered. Make the application form proportionate to the size of the grants – avoid seeking extensive responses for small value grants. Eliminate repetition. Consider the abilities of prospective applicants when designing the application form. If an online application form is used, will the applicants have good access to internet, computers and necessary skills? Will the form be reliable and accessible? There are many stories of online forms being complex or not working properly. Downloadable forms sometimes are not compatible with other software versions and create problems. Some organisations may find spreadsheets difficult to use.

Consider the needs of applicants who may have difficulties with English or literacy. Make the response easy to assess e.g. by requesting a yes or no answer but avoid check boxes which can be unreliable.

Develop an assessment plan that reflects the criteria and the application form requirements. The plan should include scoring information and guidance. When qualitative scoring is required, the scoring information should provide a scale with descriptors for each score. If possible, a tailored scoring scale or rubric should be developed for each criterion to help assessors to score consistently. Sometimes a formula may be used to assess all or part of applications.

For qualitative scoring, assessors should meet and agree on scoring and the resulting rankings.

Retain evidence that the assessment process has been properly conducted and that assessors had appropriate capability and received appropriate training.

The assessment outcome should be documented in a report to the approver, recommending grants within budget and providing reasons for the recommendations.

Approvers have the responsibility to review recommendations and the right to vary the successful grant recipients. In all jurisdictions for transparency and accountability any changes of grant recipients should be consistent with the published criteria and assessment plan and the reasoning for any such changes explained in writing. The CGRGs go further and require the approver, including Ministers, to record, in writing, the basis for the approval relative to the grant opportunity guidelines and the key principle of achieving value with relevant money.

Approvers including Ministers are not just rubber stamping. They may have discretion to vary the successful grant recipients. However, the reasons for this need to be compelling and defensible. And, if grant awards are inconsistent with the published assessment criteria, there is a real risk of complaints and adverse media attention which can damage the reputation of the approver and the grant program. 

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CourtHeath Consulting provides services to government and not-for-profit organisations.

Our probity audit and advisory services help clients meet government probity standards especially regarding conflict of interest, confidentiality, ethical conduct and corruption risks.

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