For anyone new to Commonwealth grants administration, it can sometimes be confusing to work out what to do to ensure grant programs are designed and delivered in compliance with the Grants Framework and Finance Law. This page outlines key steps to guide you.
The Grants Framework is set out in the Commonwealth Grants Rules and Guidelines 2017 (CGRGs), which is a legislative instrument that is largely principles based, with some specific requirements.
Is it a grant?
It is important to determine the appropriate type of funding arrangement for the spending activity, i.e. grants, procurement or another financial arrangement. New spending activities need policy approval, which is often the result of the annual budget process or MYEFO [Mid-Year Economic and Fiscal Outlook, refer www.budget.gov.au], which may indicate the type of arrangement. The Department of Finance (Finance) has developed a simple tool to assist you when determining the type of financial arrangement: Grants decision tree tool.
Tip: if it is not clear what type of financial arrangement it is, think about the substantive purpose of the arrangement. Why is the funding being made available?
Note: There are some financial arrangements, which would normally be included in the definition of a grant, that are not subject to the CGRGs for policy reasons. Please see the exclusions in paragraph 2.6 of the CGRGs.
Resource Management Guide 411 provides useful information on a range of financial arrangements, including grants and procurement, and may assist further.
It is a grant
After making the decision that the type of financial arrangement is a grant, and the CGRGs apply, the next step is to develop the grant opportunity. The Department of Finance has developed a flow diagram that outlines the grant process.
If your entity is in scope to use a Grants Administration Hub (Grants Hub), your entity works with the Grants Hub to design the grant opportunity. Grants Hubs have design teams with a breadth and depth of experience to draw on, to guide an entity to get the best outcome and most effective administration for each grant program. Other entities that are not in scope can also use a Grants Hub. See more information below on the Business and Community Grants Hubs and entities in scope.
Tip: When you are thinking about the design of a program, think about the potential grant applicants and what is proportional for the specifics of the grant opportunity, such as the value of the grants. Think about how much red tape or burden you are placing on applicants and recipients and whether this is reasonable. Grants Hubs can help you to work through this.
Robust planning and design is a key principle of the CGRGs ( Chapter 7). Matters to consider include:
- establishing the rationale for the grant opportunity, in particular what outcomes are required and how these will be measured;
- defining the operational objectives;
- consulting with key stakeholders;
- undertaking risk identification, mitigation and engagement;
- designing the grant opportunity to achieve value with relevant money, considerations for this include:
- developing eligibility and assessment criteria that reflect the operational objectives and policy intent and are easily assessable;
- identifying any considerations which will impact on the decision making;
- ensuring the application and selection processes are proportional and accountable and meet probity and transparency requirements;
- establishing performance and evaluation measures;
- identifying the capabilities required for assessment, who will assess applications and who the decision maker will be;
- selecting an appropriate funding strategy and grant agreement/s taking into consideration the risks and objectives;
- considering legal, accounting and policy matters; and
- developing robust governance arrangements.
Grant opportunity guidelines must be developed for all grant opportunities. Grant opportunity guidelines are the authoritative documents which potential grantees engage with that provide all information required to understand the purpose of a grant opportunity and how to make an application.
The Department of Finance, in consultation with granting entities, has developed whole of government grant opportunity templates to assist when developing grant opportunities. These templates guide users to meet the better practice administration requirements of the CGRGs and allow speedier timeframes for approval and publication of the grant opportunity, to open the grant opportunity for applications.
This Grants template wizard can help you decide which template to use:
The Grants template wizard tool a key element of grants administration to identify and engage with risk. Entities are required to prepare a risk assessment for each grant opportunity and consult with Finance and the Department of the Prime Minister and Cabinet (PM&C) on the risk rating prior to release of the grant opportunity guidelines (more on this below).
Entities are required to conduct a self-assessment risk analysis of the grant program and related guidelines. Risks assessed include the program, implementation, grantee and activity risks. Considerations also include: complexity of the grant opportunity’s design, the expected number of eligible applicants and constitutional and legislative risk.
For the majority of grants, once the entity has determined a risk rating, they are required to provide the draft grant opportunity guidelines and the risk assessment to Finance and PM&C to consult on the risk assessment and agree the risk rating. This risk rating determines the approval process for publishing the grant opportunity guidelines. The key steps are:
- Entities prepare a risk assessment and grant opportunity guidelines
- Finance and PM&C review and agree on a risk rating for the grant opportunity
- The relevant portfolio minister either:
- approves the grant opportunity guidelines if the risk rating is agreed as low and the whole of government template was used;
- writes to the Finance Minister notifying of the intent to release the guidelines when the risk was agreed as low but the guidelines were not developed using the whole of government template; OR
- seeks the Finance Ministers’ agreement to release the Guidelines for medium or high risk rating agreement.
- The entity then publishes the grant opportunity guidelines on GrantConnect.
Guidance material on how to prepare a risk assessment is available, please contact the grants team for the self-risk assessment template (firstname.lastname@example.org).
Streamlined approval process for grant guidelines
The Government has streamlined the process for grant opportunity guidelines to be agreed and published, when the whole of government template is used and the agreed risk is “low”. The streamlined approval process aims to reduce the time spent by entities on administrative processes, enabling guidelines to be released more quickly and to allow the focus to be on achieving the best outcomes for Australians.
Once the grant opportunity guidelines have been approved, they are published on GrantConnect, which is a requirement of the CGRGs.
In using the whole of government template, responsible Ministers may approve grant opportunity guidelines where the relevant entity, Finance and the Department of the Prime Minister and Cabinet (PM&C) agree the risk is “low” and the templates have been populated as instructed. This process and the correct use of templates enables entities to engage in better practice grants administration in a consistent and transparent way. The templates also aim to reduce the time spent by grant applicants reviewing guidelines by providing a common format and structure making it easier for grant applicants to navigate and understand the requirement they will need to satisfy to apply for a grant.
The table below outlines the key requirements for each grant opportunity
|Quick Reference Guide||Competitive and Non-competitive selection processes||Eligibility only or Demand Driven selection processes||One-off or ad hoc grants|
|Policy and legal authority required?||Yes||Yes||Yes|
|Grant opportunity guidelines are required?
The use of these templates is optional, but will enable low risk grants to use the streamline approval process to publicly release the guidelines.
|The risk rating from the self-assessment must be agreed in consultation with Finance and PM&C prior to the release of grant opportunity guidelines?||Yes||Yes||No|
|Grant opportunity guidelines must be published on GrantConnect.||Yes||Yes||Optional|
|The approver must record the basis of the approval relative to the grant opportunity guidelines and the key principle of achieving value with relevant money.||Yes||Yes||Yes|
|The entity is required to report grants awarded on GrantConnect.||Yes||Yes||Yes|
|Where a Minister approves a grant in his/her own electorate, the Minister must write to the Finance Minister. Where the Minister is the approver the Minister must write to the Finance Minister as soon as practicable.||Yes||Yes||Yes|
|Where a Minister approves a grant that the entity recommended be rejected, the Minister must report these grants annually to the Finance Minister.||Yes||Yes||Yes|
Streamlined Grants Administration
The government announced the Streamlining Government Grants Administration program in the 2015-16 Budget to deliver simpler, more consistent and efficient grants administration across government.
The program consolidated grants administration processes for 12 in-scope entities into two grants hubs - the Community Grants Hub and the Business Grants Hub. The hub model reduces duplication of effort and costs across government by consolidating grants administration services, developed areas of expertise and improved user experience (made it easier for grant applicants and recipients to find and apply for grants).
*The Community Grants Hub is managed by DSS and the Business Grants Hub is managed by DISER.
The 12 in-scope entities, must use a grants hub to administer their grants programs. Other Commonwealth entities are also welcome to use grant hub services for their grants administration.
In-scope entities should engage early with hubs to seek a quote for service delivery and optimise the grant design process. Early engagement with the hubs will help facilitate the design of grants for hub delivery and, should it be needed, support the exemption and deferral process.
Exemption and Deferral Requests
In exceptional circumstances the responsible minister may seek a temporary deferral or permanent exemption from hub delivery from the Minister for Finance.
A temporary deferral may be considered when:
- there are timing issues relating to legislative changes;
- hubs do not have the capacity or capability to on board in the required timeframe;
- the grant has a security classification higher than what the hubs can provide; or
- the grant has been delivered via a non-government third-party provider on a continuous basis since 31 December 2015.
A permanent exemption will only be considered where it can be demonstrated that exceptional circumstances cannot be overcome or resolved.
Neither a deferral nor exemption will be granted on the basis of costs.
For all enquiries relating to grant administration please contact:
- Department of Finance - email@example.com.
For all enquiries relating to the grants hubs including arrangement of quotes, services offered, and arrangements to transition existing grants please contact:
- Community Grants Hub - firstname.lastname@example.org
- Business Grants Hub - AusIndustryEngagement@industry.gov.au.