WWDA Submission to the Department of Families, Community Services and Indigenous Affairs (FaCSIA) on the ‘Reducing Red Tape Initiative’


In 2006, the Commonwealth Department of Families, Community Services and Indigenous Affairs (FaCSIA) undertook a process to focus on reducing red tape whilst at the same time maintaining appropriate standards of transparency and accountability for government. FaCSIA assessed how its programs and processes might be streamlined to increase consistency and reduce unnecessary variations. This paper is WWDA’s response to the Department of Families, Community Services and Indigenous Affairs (FaCSIA) ‘Reducing Red Tape Initiative’. Copyright WWDA May 2006.


1. About Women With Disabilities Australia (WWDA)

Women With Disabilities Australia (WWDA) is the peak organisation for women with all types of disabilities in Australia. WWDA is run by women with disabilities, for women with disabilities. It is the only organisation of its kind in Australia and one of only a very small number internationally. WWDA is inclusive and does not discriminate against any disability. WWDA is unique, in that it operates as a national disability organisation; a national women’s organisation; and a national human rights organisation. The aim of Women With Disabilities Australia (WWDA) is to be a national voice for the needs and rights of women with disabilities and a national force to improve the lives and life chances of women with disabilities.

WWDA addresses disability within a social model, which identifies the barriers and restrictions facing women with disabilities as the focus for reform.

NB: More information about WWDA can be found at the organisation’s extensive website: www.wwda.org.au


2. Background

The Department of Families, Community Services and Indigenous Affairs (FaCSIA) has undertaken a process to focus on reducing red tape whilst at the same time maintaining appropriate standards of transparency and accountability for government. FaCSIA is looking at how its programs and processes might be streamlined to increase consistency and reduce unnecessary variations. Some areas which have already been identified are:

  • standardising reporting requirements, financial and other types of reports, including performance frameworks;
  • standardising funding arrangements, including standard funding agreements and applications;
  • consistency in review activities.

This paper is WWDA’s response to the Department of Families, Community Services and Indigenous Affairs (FaCSIA) ‘Reducing Red Tape Initiative’.


3. Context

Women With Disabilities Australia (WWDA) began in 1995 with a small seeding grant from the Commonwealth Office of the Status of Women (OSW). In 1996, the then Commonwealth Department of Health and Family Services (later to be restructured into 2 separate Departments – the Commonwealth Department of Health & Aged Care; and the Commonwealth Department of Family & Community Services) took over responsibility for WWDA’s operational funding. From 1996-98 WWDA was funded on a six monthly basis, and was required to reapply for funding twice a year. In 1998, the then Commonwealth Department of Family & Community Services (FaCS) agreed to provide WWDA’s operational funding on an annual basis. WWDA is currently funded annually through the National Secretariat Program (NSP) within the newly restructured Commonwealth Department of Families, Community Services and Indigenous Affairs (FaCSIA).

Other sources of funds for WWDA come from grants project funding (from both government and non-government sources), a small amount from donations, and some from membership fees.

WWDA receives only a small amount of operational funding from FaCSIA per year to run the national WWDA secretariat. The operational funding enables WWDA to employ only 2 staff – one full time Executive Director and 1 part time Administration Assistant.


4. Funding Processes & Related Issues

4.1. Funding Cycles/Funding Contracts

The Department of Families, Community Services and Indigenous Affairs (FaCSIA), through the National Secretariat Program (NSP) currently funds WWDA (and several other peak organisations) on an annual funding cycle (July 1 – June 30 each year).

The practice of funding an organisation on an annual basis is unworkable and detracts from optimal performance. For example, it is difficult to attract and retain quality staff where their tenure can only be assured for one year. Organisational planning processes are also hampered by one year funding contracts. Peak disability organisations need to be able to develop at least 3 year Strategic plans for their organisations and their constituents. WWDA’s Strategic Plan for 2004-2009 has been developed with careful consideration of the needs of our constituents and prioritises how WWDA wishes to address these identified needs. Copies of the WWDA Strategic Plan were forwarded to FaCS in 2004, and distributed widely to all Government Departments and Ministers and through our networks. Annual funding contracts detract from our ability to address the identified needs of women with disabilities in Australia, as detailed in the WWDA Strategic Plan. Annual funding contracts are burdensome on organisations like WWDA in respect to the administrative reporting requirements. Annual funding also impacts on areas such as the ability of the organisation to secure long term rental space (i.e.: WWDA could negotiate cheaper rental if it could secure a long term lease arrangement, however this is not possible when the organisation is not guaranteed of operational funding for more than one year at a time).

WWDA’s operational funding contract with FaCSIA has, as a requirement, the need for WWDA to ‘raise revenue to improve the viability of the organisation and diversify the financial base.’ However, it is unrealistic to expect an organisation to seek funding from sources such as philanthropic grants and other funding programs when the organisation has no guarantee of operational funding from one year to the next. This could potentially leave the organisation in a position where it has project grants to administer but no operational funding to run the organisation. WWDA believes that this acts as a disincentive for organisations funded annually by FaCSIA to actively seek funds from other sources such as project grants.

There appears to be inconsistency in the way that FaCSIA funds national secretariats and other services. For example, under the National Secretariat Program (NSP), there are a number of organisations which are funded on an annual basis and others which are funded on a triennial basis. The peak bodies funded through the NSP are also funded at different levels: some as National Secretariats, and some as Secretariat Support Organisations. It is not clear why this is the case, nor is it clear what processes are used by FaCSIA to make these decisions. For example, what criteria are used by FaCSIA to ascertain which organisations receive triennial funding and which organisations receive annual funding?

There is inconsistency across sections and programs of FaCSIA in relation to the signatories required on funding contracts. Some contracts require the signature of the organisation’s President and Public Officer, whereas for others it is acceptable for the CEO and the Business Manager to sign the contracts. For an organisation like WWDA, requiring the signatures of the President & Public Officer is administratively burdensome for the organisation. This is because the WWDA Office Bearers are spread throughout the country and all are volunteers. For contracts that require the signature of the President & Public Officer, it means that the contract has to be Express posted by the WWDA National Office (Tasmania) to the President (NSW) who then in turn has to Express post the contract to the Public Officer (ACT) who then has to Express post it back to the WWDA National Secretariat for the inclusion of the WWDA Seal (which is required by law to be applied after the contract has been signed by the relevant WWDA personnel). WWDA then has to Express post the completed contract back to FaCSIA. Clearly, this process is not only administratively burdensome on WWDA, it is also unnecessarily expensive.

WWDA’s Operational funding contract with FaCSIA runs on the financial year cycle (July 1 – June 30 each year). However, there are other funding programs within FaCSIA which run on different cycles that do not coincide with the financial year. This can present problems for organisations like WWDA, because funds have to be managed separately and financial management processes (such as audits) are duplicated. This puts unnecessary strain on the organisation and reduces the capacity of the organisation to be able to focus on its core business.

It is also important to look at the level of funding which WWDA receives. Despite significant expansion of the amount of work it does, the number of separate grants that it administers, and the number of project officers is recruits, WWDA has not had a substantive increase in its operational funding. In fact the operational funding level has not reached that of the Consumer Price Index (CPI), and certainly does not match our increasing staff needs. Every day, WWDA receives a large number of requests for information from women in crisis, many of whom take long hours of staff time because their real need is for a sympathetic, informed ‘ear’ on the other end of the line. WWDA also receives an increasing number of requests for information from a wide range of organisations and research institutions.

SUGGESTIONS FOR CONSIDERATION

    1. Once organisations like WWDA have established a sound track record and credibility with its funding body their funding contracts should be extended to at least 3 years. Service agreements could be developed which include performance measures and agreements on outputs during that three year term.

 

 

  • There should be clear, consistent and transparent criteria used by FaCSIA for funding peak bodies and other FaCSIA services. These criteria should be developed in consultation with the organisation’s FaCSIA funds, and should include criteria related to funding cycles.

 

 

 

  • There should be consistency in all contracts regarding the signatories required. Alternatively, there must be provision for organisations like WWDA, (which has volunteer Office Bearers) for the CEO to sign FaCSIA funding contracts. If it is deemed that FaCSIA funding contracts must be signed by Office Bearers, then consideration needs to be given to the processes and costs involved for this to occur. FaCSIA should also be required to provide the contract with sufficient lead time to enable this to occur.

 

 

 

  • FaCSIA funding contracts should be consistent in regards to the financial year funding cycle. For those funding programs that do not run on a financial year, there should be provision within the funding contract for the funding recipient to provide audit reports and project reports to FaCSIA at the end of the financial year.

 

 

 

  • FaCSIA needs to instigate a transparent process whereby the level of funding an organisation receives can be reviewed. Levels of funding need to be increased annually to at least match the CPI. There should be a mechanism for benchmarking the level of funding and level of outcomes delivered so that the operational funding an organisation receives can be increased to meet the increased workload of staff.

 

4.2. Payment of Grant Installments

As outlined earlier in this paper, WWDA receives operational funding annually from FaCSIA through the National Secretariat Support Program (NSP). The operational grant is paid to WWDA by FaCSIA in four installments over the year. For a number of years, WWDA has requested that FaCSIA pay WWDA’s operational grant in one lump sum at the beginning of the contract period (i.e.: July 1 each year). No rationale has ever been offered as to why this is not possible. Receiving the operational grant in four installments is problematic for WWDA and once again, places unnecessary strain on the organisation. For example, over the past few years WWDA’s insurance requirements (under the FaCSIA funding contract) have increased substantially. WWDA’s annual insurance premiums are extremely high and are must be paid in a lump sum annually to the insurance company. There is no provision to pay annual insurance premiums in ‘installments’. WWDA simply cannot afford to pay its annual insurance premium from one of the quarterly installments.

It is also extremely difficult for WWDA when operational grant installments from FaCSIA are delayed, late and/or incorrect. Unfortunately, this has been an all too common experience for WWDA. The funding contract between WWDA and FaCSIA has stipulated the date (day, month & year) that WWDA will receive the installment. This is a legally agreed clause, but there are no ramifications for FaCSIA if it breaches this part of the contract. An organisation like WWDA relies heavily on its operational funding grant to conduct its business. It is important for FaCSIA to recognize that an organisation representing women with disabilities has very limited scope to generate its own resources either from its constituency and membership who are generally amongst society’s poorest, or from business who generally find it difficult to envisage a beneficial partnership with such an organisation. Therefore, it is vital that WWDA’s operational funding from FaCSIA is received on time and is correct.

Erratic payment of grant installments is also a major problem. An example can be used here to highlight this:

WWDA applied for project funding under a Program Grant within FaCSIA. The Project funding was advertised as 12 month funding (i.e.: to conduct projects over a 12 month period), to be completed within the financial year. Announcement of the successful applicants was delayed and by the time this was made by the Minister, the project timeframe had already been whittled down to 9 months (as the Department had to expend the Program funds by the end of the financial year). WWDA was a successful applicant and contracts were prepared and signed by both parties. The contract stipulated that the Project commenced on the date of signing the contract, and that the first installment was payable to WWDA on the signing of the contract. However, eight weeks elapsed before receipt of the first grant installment. The urgency to commence work was apparent, even though WWDA does not have the funds to ‘float’ a Project. It then placed enormous strain on the organisation to commence the Project whilst waiting for that first installment to be processed. Effectively the 12 month project became a 7 month one. No concessions or amendments to the contract were given, meaning that WWDA had to face the possibility of compromising the quality of end product in order to meet the reduced 7 month timeframe. This is counter to WWDA philosophy, and means an additional imposition on volunteer members who need to assist to meet the deadline.

This is not an isolated example. It is WWDA’s experience that project funding payments from FaCSIA are often late, delayed and incorrect. FaCSIA procedures seem to preclude efficient and timely management of funds.

SUGGESTIONS FOR CONSIDERATION

    1. Operational funding from FaCSIA should be paid annually in one lump sum.

 

 

  • FaCSIA Project grant installments should be paid on time. The first installment of a FaCSIA Project grant should be paid promptly after the signing of the contract by both parties.

 

 

 

  • FaCSIA have greater flexibility to enable Grantee organisations to carry over committed grant funds, past the originally projected time frame in cases where Departmental holdups have caused the reduction of the originally negotiated end date.

 

 

 

  • FaCSIA needs to understand that smaller organisations do not have the capacity to ‘float’ projects until such time as FaCSIA pays the grant installments.

 

 

 

  • FaCSIA needs to examine its application assessment procedures, so that delays in identifying successful applicants and allocating funds are eliminated. This may mean having protocols in place to continue the assessment when relevant officers are absent or transferred.

 

 

 

  • There should be consistent processes and procedures throughout FaCSIA for the administration of grant funding.

 

4.3. Timing of Receiving Funding Contracts

WWDA has been funded by FaCSIA (and its predecessors) on an annual basis since 1996. WWDA’s funding contract with FaCSIA runs on the financial year cycle (July 1 – June 30 each year). Almost every year WWDA has experienced intense frustration with the timing of receiving the contract from FaCSIA. WWDA has repeatedly asked for more timely negotiation and delivery of successive funding agreements.

  • WWDA requires the next year’s funding contract at least 8 weeks prior to the end of June each year;
  • WWDA requires a standard meeting annually with FaCSIA personnel to review WWDA’s performance; discuss any issues; and negotiate any changes to the contract – such a meeting needs to occur at least three months prior to the end of the contract period;
  • Any changes to the contract, including performance measures, must be done in consultation with WWDA, in an agreed timeframe and process;

However, almost every year WWDA experiences some or all of the following:

  • The funding contract is late or delayed – despite the fact that WWDA’s situation remains unchanged from one year to the next;
  • The contract is not provided in electronic format despite written requests from WWDA for this;
  • The contract is changed by FaCSIA with no discussion, consultation and/or agreement from WWDA;
  • ‘Specific deliverables’ are added to the contract schedule by FaCSIA without any consultation with WWDA;
  • The contract is provided so late by FaCSIA that WWDA has little option but to sign it;
  • Inconsistent and/or incorrect advice, along with changes to the contract administration processes – this is exacerbated by the fact that there have been new personnel within the FaCSIA National Secretariat Funding Program (NSP) every year that WWDA has received operational funding from this source;

Example:
One year, despite repeated written and verbal requests from WWDA, FaCS still had not provided the funding contract to WWDA by 29 June. WWDA’s contract at the time expired the following day on June 30. Early in the year, WWDA had requested a meeting with FaCS personnel to discuss WWDA’s performance and negotiate the funding contract for the upcoming financial year. FaCS personnel eventually agreed to meet with WWDA and did so on June 29, one day before WWDA’s operational funding contract was to expire. Clearly, there was no opportunity for negotiation of the funding contract for the next year. Because FaCS was unable to organize the funding contract by the next day (June 30), there was a period in which WWDA had no contract and no operational funding from FaCS. After a period of some weeks, FaCS notified WWDA that we would be funded for a three month period (ostensibly an ‘extension’ to our contract of the previous year). We then had to sign a contract for three months (with no opportunity for even discussing the contract) and then three months later had to sign another contract for the remaining 9 months of the financial year).

SUGGESTIONS FOR CONSIDERATION

    1. Draft operational funding contracts should be provided by FaCSIA to the funding recipient at least 8 weeks prior to the end of the current contract period.

 

 

  • Draft operational funding contracts should be provided by FaCSIA in accessible, electronic formats (as well as hard copy).

 

 

 

  • Any intended changes to the operational funding contracts must be done in consultation with the funded organisation and should include an agreed process and timeframe.

 

 

 

  • FaCSIA personnel charged with the responsibility of managing the operational funding contracts should meet formally with the funded organisation at least three months prior to the end of the current contract period. Such meetings should occur annually and should have an agreed agenda.

 

 

 

  • FaCSIA put in place a schedule for face-to-face meetings with Grantees, and for drawing up and negotiating contracts. The contract schedule should be able to be followed independent of absence or transfer of personnel.

 

4.4. Funding Application Processes

WWDA has applied for a range of project funding from FaCSIA over the years. This funding has been from various programs within FaCSIA. There are a number of issues which WWDA has experienced as problematic and cumbersome when applying for funds from FaCSIA. These include:

    • Short timeframes – the timeframe between FaCSIA advertising the availability of program/project funding and the closing date for applications is far too short. Such impractical timeframes do not take into consideration the difference in resources between applicants – i.e.: large organisations with several staff will have a better capacity to apply for funds in a short timeframe. There is also no consideration given to, or accommodation of disability in the context of applying for project grants – i.e.: organisations made up of people with disabilities may require longer timeframes to apply for funding than organisations made up of people without disabilities. For example, consultation via email or teleconference with a group of people, such as the Management Committee, can take longer because at any one time individuals’ disability management issues may prevent or delay getting a consensus agreement. This does not affect the execution of project Once a project is under way, staff and Project Officer/s work together to ensure timely and efficient delivery of project outcomes. Most national community organisations have geographically disparate management committees. This necessitates allowing a longer time discussion online and/or by teleconference. In a number of places in this document, WWDA talks about the impact that short-timeframes (for making a funding application or signing a funding agreement) have on a disability community organisation.

 

 

  • Need to re-submit core information – WWDA is a well respected organisation and has a long standing relationship with FaCSIA. All WWDA information, reports, documents etc are routinely provided to FaCSIA, including for example: Annual Reports; Monthly Update Bulletins; Strategic Plans; Research Reports; Audit Reports; and more. It is frustrating in the extreme that each and every time WWDA applies for funds from FaCSIA; we are required to re-submit information that has already been supplied to FaCSIA. This is a waste of resources and unnecessary.

 

 

 

  • Numbers of copies required – It is a common experience for WWDA when applying for funds from FaCSIA (particularly for project grants), that we are required to provide a significant number of copies of the Application and all supporting documentation to FaCSIA. It is unclear why some FaCSIA grant programs require 6 hard copies of an Application plus 6 hard copies of all supporting documentation (WWDA has regularly found itself having to provide over 600 pages in the supporting documentation alone). There is clearly great inconsistency between programs within FaCSIA. Provision of multiple application forms is an unnecessary, resource intensive and expensive exercise.

 

 

 

  • Differing application procedures – there are significant differences between funding application procedures and processes throughout FaCSIA. It is very confusing especially when funding application processes vary within the same section of the Department (a common experience of WWDA).

 

 

 

  • Resource intensive – funding application processes within FaCSIA are more often than not, extremely resource intensive and the excessive amount of work (including paperwork) is simply not commensurate with the amount of funding being applied for. There is no accommodation given by FaCSIA for smaller, poorly resourced organisations, nor is there any consideration given by FaCSIA on the impact of disability on submission development.

 

 

 

  • Delays in announcing applicants – It is an all too common experience for WWDA that the announcement of successful applicants by FaCSIA is delayed. On more than one occasion, WWDA has been notified by FaCSIA that our Application for funding has been successful – more than one year after we had applied. Delays in payment of grant installments by FaCSIA are also an all too common experience for WWDA. Delays such as these can have significant implications for an organisation like WWDA.

 

 

 

  • Inconsistency in definitions and language – there is significant differences in the language and definitions used within and across FaCSIA Program areas. This creates unnecessary confusion.

 

SUGGESTIONS FOR CONSIDERATION

    1. FaCSIA should develop minimum timeframe standards for the advertising of program/project funds. Timeframe standards should also include the issue of announcements of successful (and unsuccessful) applicants. Any ad hoc funding rounds (e.g. towards the end of a financial year) should have reduced detail requirements in the application.

 

 

  • There should be a centralized point within FaCSIA for holding ‘core’ information on ‘known’ and/or ‘FaCSIA funded’ organisations. Core information could then be integrated with the Application process. Applicants should not have to re-submit information that is already held by FaCSIA (i.e.: Strategic Plans, Annual Reports etc).

 

 

 

  • FaCSIA should develop standardized Application Forms and processes. This should include the development of a two-stage Application process – an ‘Expression of Interest’ stage whereby FaCSIA shortlists potential providers; followed up by a more comprehensive Application if the Applicant is short listed. Any standardised application process should also address the need for consistency in language and definitions.

 

 

 

  • Applicants should only have to provide FaCSIA with one hard copy and one electronic copy of their Application. FaCSIA should take responsibility for providing the required number of hard copies of any application.

 

 

 

  • FaCSIA should provide support for smaller organisations to assist in the development of funding Applications.

 

4.5. Insurance Requirements

It is a requirement by FaCSIA that organisations must possess professional indemnity insurance, if they are to be eligible for National Secretariat Program (NSP) funding (and other FaCSIA funding programs). Purchase of professional indemnity insurance is not only a prohibitive impost on the FaCSIA funding to WWDA; it is also an utterly unnecessary one. The work that WWDA does exposes WWDA to liabilities covered by public officers and directors insurance, rather than professional indemnity insurance. WWDA has raised this issue with FaCSIA for a number of years. However, FaCSIA has continued its requirement that WWDA carry professional indemnity insurance. WWDA’s operational grant from FaCSIA does not cover the basic operational costs of the organisation and this requirement effectively means that we waste Government money. This does not sit well with WWDA’s philosophy and operational ethics. It is also of concern that the FaCSIA requirements for insurance coverage and amounts vary across and within programs. For example, WWDA’s operational funding contract with FaCSIA requires (in part) Professional Indemnity Insurance to the value of 2 million dollars. Other funding programs within the same section of the Department require Professional Indemnity Insurance to the value of 5 million dollars.

SUGGESTIONS FOR CONSIDERATION

    1. There are standard insurance policies which all FaCSIA funded organisations will be required to have (such as Workers Compensation, Public Liability etc) and these should be reflected in the funding contracts. However, the need for more specific insurance policies (particularly Professional Indemnity Insurance) should be negotiated with each funded organisation on a case by case basis.

 

 

  • FaCSIA requirements for insurance coverage and amounts should be consistent across the Department.

 

4.6. Variations to Funding Agreements

There is inconsistency between and within sections of FaCSIA in relation to the issue of variations to funding agreements. It appears from WWDA’s experience, that the process of making variations to funding agreements depends entirely on the attitude of the FaCSIA personnel at the time the variation is sought. WWDA has had cases whereby we have been required by FaCSIA to write formally to the Department explaining why a budget item (within a Project grant) was varied by twenty five dollars! It is WWDA’s experience that there is a lack of understanding (on the part of FaCSIA personnel) of the nature of disability and of the work WWDA does. WWDA has made it clear in every project funding application to FaCSIA that due to the nature of disability, it is impossible for WWDA to predict exact amounts of Budget items – WWDA has always made it clear that our Budget Items are indicative only and there may be movement between Budget Items. WWDA has found it cumbersome and unnecessary to have to formally request variations across Budget Items. For example, when organising a face-to-face meeting, it is impossible to know the travel and accommodation costs until the participants’ support requirements are known. It could be that extra airfares are needed to fund the travel, accommodation and per diem costs of a number of carers. This can double the projected meeting costs.

SUGGESTIONS FOR CONSIDERATION

    1. There should be inbuilt flexibility within each budget item for funded organisations to make variations across budget items as necessary. Funded organisations should not be required to formally request variations across budget items.

 

 

  • Funded organisations should only be required to demonstrate through an audited financial report, that the funds were expended for the purposes intended, in accordance with the Grant deed.

 

 

 

  • FaCSIA needs to understand the difficulty for disability organisations in being able to predict exact amounts of budget items. Due to the nature of disability, budget items can often only be indicative only, and organisations such as WWDA need flexibility to vary budget items as required.

 


Stakeholder Relations

5.1. High turnover of FaCSIA program personnel

WWDA’s effectiveness as an organisation has been (and continues to be) frustrated by the constant turnover of FaCSIA personnel within the sections with which it deals with (egg: Office of Carers & Disability; National Secretariat Program; Office for Women). Having to deal with new FaCSIA personnel every year (or more often than that) causes a number of problems and issues including:

  • WWDA has to spend additional time orienting the FaCSIA personnel to the work WWDA does etc;
  • There is a lack of understanding on the part of FaCSIA personnel as to the work WWDA has done in the past and the priorities for the organisation into the future;
  • There is a lack of understanding on the part of FaCSIA personnel as to the challenges and issues facing women with disabilities;
  • Each year FaCSIA personnel ‘promise’ WWDA that issues will be addressed (such as problems with timing of grant payments; receiving contracts; lack of communication from FaCSIA etc), yet no issues are ever addressed or resolved because the FaCSIA personnel move on and the ‘new’ FaCSIA personnel have no knowledge or understanding of the issues to be resolved;
  • New FaCSIA staff make decisions or provide advice that clearly conflicts with that given by their predecessors.

SUGGESTIONS FOR CONSIDERATION

    1. A centralized point should be established in FaCSIA which acts as the one coordinating point for peak bodies and organisations funded by FaCSIA.

 

 

  • FaCSIA should develop and maintain clear records for each organisation it funds. Records should contain detailed information about the organisation and should also include details on decisions made and advice given by FaCSIA.

 

 

 

  • FaCSIA personnel charged with the responsibility of managing the operational funding contracts should meet formally face to face with the funded organisation at least annually.

 

 

 

  • FaCSIA should have clear procedures regarding its relationship with the organisations it funds. Such procedures should include communication and information processes.

 

 

 

  • Staffing volatility in Government will always present a problem for continuity of interaction with Grantees. There is much greater stability in the personnel in community organisations. At the time of changeover of personnel, FaCSIA should make provisions for adequate handover, plus provision for an orientation period available for staff, with new staff given briefings on the nature and work of the organisations in their portfolios.

 

5.2. Lack of information about FaCSIA Programs/Sections

Over the past decade, WWDA has experienced constant changes in the Department from which it receives its operational funding. For example, the Department has been restructured and renamed a number of times; sections within the Department have changed, moved or completely disappeared; funding programs have been reviewed a number of times and have changed, moved or completely disappeared. More often than not, these changes occur with little or no formal information being given to the organisations and/or services which are affected by the changes. Often it is a departing desk officer who has had contact with WWDA who gives an informal update. For WWDA, this raises a number of issues:

  • Changes and the impact of changes are not communicated by FaCSIA to WWDA;
  • FaCSIA Program areas which have a relationship with WWDA, do not provide information to WWDA about the role, function, intentions etc of the Program area;
  • Often several sections of the Department have interest in a particular project;
  • More often that not, WWDA has no idea which area of the Department it is meant to be dealing with on particular issues;

SUGGESTIONS FOR CONSIDERATION

    1. A centralized point should be established in FaCSIA which acts as the one coordinating point for peak bodies and organisations funded by FaCSIA.

 

 

  • FaCSIA should produce a regular (fortnightly or monthly) update bulletin which is provided to the FaCSIA funded organisations and includes up to date information about the Department and/or relevant sections of the Department.

 

 

 

  • FaCSIA funded organisations should be provided with detailed information regarding Departmental changes. Such information should be provided when changes are occurring, not after the change has occurred.

 

5.3. Relationship between FaCSIA Program Areas

It is not clear to WWDA what the relationship is between the various sections of the Department with which we are required to deal. WWDA has raised this issue with both the National Secretariat Program (NSP) and the Office of Carers and Disability (OCD) a number of times in the past. We understand for example, that the Office of Carers and Disability is concerned with ‘policy’ issues and the NSP is concerned with the administration of the funding grants. However, there does not appear to have been clear delineation between the two sections in relation to how they deal with the organisations/services they fund. Consequently, WWDA finds itself sending the same information to both the NSP and Office of Carers and Disability because of the lack of delineation of respective roles and responsibilities, and because there does not seem to be established or guaranteed lines of communication between the two program areas. This is administratively burdensome for WWDA.

SUGGESTIONS FOR CONSIDERATION

    1. A centralized point should be established in FaCSIA which acts as the one coordinating point for peak bodies and organisations funded by FaCSIA.

 

 

  • FaCSIA should have clear procedures regarding its relationship with the organisations it funds. Such procedures should include communication and information processes.

 

 

 

  • FaCSIA should provide clear information (to the organisations it funds) about the role and function of the various sections within the Department and the relationships between the sections.

 

5.4. Lack of FaCSIA Feedback & Acknowledgment

WWDA’s annual funding contracts with FaCSIA have specified as an outcome:

‘Act as a two way conduit between the community and the Australian Government on social policy issues, specifically issues relating to or affecting the sector.’

One of the specific Performance indicators in the contract for this outcome is:

‘Feedback from FaCS’.

The use of the phrase ‘two way conduit’ would suggest a two way relationship between WWDA and its funding body (FaCSIA). However, it is WWDA’s experience that the relationship is in fact, only ‘one way’ – from WWDA to FaCSIA. It has been (and continues to be) a source of extreme frustration for WWDA that it never receives any feedback or acknowledgment from FaCSIA in relation to the information we provide, nor the outcomes we achieve.

WWDA has had far too many instances where basic correspondence from WWDA to FaCSIA has received no response at all. All WWDA submissions, publications, research reports, Monthly Update Bulletins, Progress Reports, Annual Reports, Audited Financial Statements, Conference papers etc, are routinely provided to three sections within FaCSIA (Office of Disability & Carers; National Secretariat Program; Office for Women) as well as to the Minister, Minister’s advisers and other key stakeholders. WWDA never receives any feedback or even an acknowledgment of receipt from FaCSIA.

It is also a common experience for WWDA that FaCSIA does not report back to organisations on outcomes of consultations, reviews etc – despite the contributions to such processes by the FaCSIA funded organisations.

Nearly all contact with FaCSIA is initiated by WWDA, with the exception being the notification of a face-to-face meeting, when.

The lack of feedback and acknowledgment from FaCSIA creates additional and unnecessary work for WWDA i.e.: following up with FaCSIA personnel to see if WWDA information has been received; chasing up FaCSIA for outcomes of consultations, reviews etc.

It is also WWDA’s experience that FaCSIA personnel take little notice or interest in the work WWDA does. WWDA consistently delivers more than is every outlined in a project brief, and treats seriously its Grant Deed requirement to dissemination information. However, it has had one case in the past where a FaCSIA officer (on a site visit to WWDA at our request) complained that WWDA provided “too much information and we don’t read it”.

SUGGESTIONS FOR CONSIDERATION

    1. A centralized point should be established in FaCSIA which acts as the one coordinating point for peak bodies and organisations funded by FaCSIA.

 

 

  • Delegated personnel within the centralized point should establish regular mechanisms for contact with the FaCSIA funded peak bodies.

 

 

 

  • FaCSIA should develop clear procedures for responding to information it receives from the organisations it funds.

 

 

 

  • WWDA is efficient in the dissemination of information about its activities and projects. It takes pride in the work it does and in the material it routinely sends to Ministers and advisers and key stakeholders. It often gets positive feedback from other areas of government. This is gratifying, and it is discouraging that no feedback is forthcoming from the Department with which we ostensibly have the closest contact.

 

5.5. Communication & Information

WWDA has experienced a range of problems and issues relating to poor communication and lack of information from FaCSIA. Issues include:

  • Lack of information provided by FaCSIA to WWDA about FaCSIA’s role, priorities, strategic vision etc;
  • Lack of information provided by FaCSIA regarding FaCSIA policy initiatives;
  • FaCSIA not inviting WWDA to contribute to or participate in reviews, consultations etc;
  • FaCSIA not updating basic contact information for WWDA despite our requests for the past five years for this to be routinely done when there are changes;
  • FaCSIA website not providing clear, easy to navigate, nor up to date information about the current work of FaCSIA or its program areas;
  • FaCSIA website based information is not always in accessible format and therefore does not meet the basic national accessibility guidelines as set out by the Australian Government Information and Management Office;
  • FaCSIA information which is provided electronically (via email) is not always provided in accessible formats (i.e.: PDF files are often sent when this is in clear breach of accessibility guidelines for people with disabilities);
  • Timeframes given by FaCSIA for input into Reviews, Inquiries, etc are extremely short.

These type of issues create creates additional and unnecessary work for WWDA.

SUGGESTIONS FOR CONSIDERATION

    1. A centralized point should be established in FaCSIA which acts as the one coordinating point for peak bodies and organisations funded by FaCSIA.

 

 

  • FaCSIA should develop clear procedures and protocols for responding to information it receives from the organisations it funds.

 

 

 

  • The FaCSIA website should provide up to date information on policy initiatives, current work of FaCSIA program areas; FaCSIA reviews, inquiries, consultations etc. The website should be easy to navigate and should meet international and national standards for accessibility.

 

 

 

  • FaCSIA should develop minimum timeframe standards for FaCSIA Reviews, Inquiries, Consultations, etc.

 


Reporting Processes & Issues

6.1. Financial Management & Reporting

As outlined earlier, WWDA receives its operational funding from FaCSIA on an annual basis. From time to time, WWDA also receives one off project funding through FaCSIA program areas. There are a number of FaCSIA imposed requirements in relation to financial management that create unnecessary strain on WWDA. These include:

    • Separate bank accounts – it is a requirement of FaCSIA that our operational grant be managed in a dedicated bank account. This has meant in practice that WWDA has to have more than one bank account, an unnecessary expense to the organisation.

 

 

  • Separate audit reports – it is a requirement of FaCSIA that our operational grant is audited separately from any other WWDA funds. This is an unnecessary process and an unnecessary expense to the organisation. FaCSIA also requires any FaCSIA project funds to be separately audited at the completion of each project. This again is an unnecessary and expensive requirement, as well as being resource intensive. Because WWDA is funded annually by FaCSIA, it is a legal requirement that the WWDA appointed Auditor review the funding contract in detail to ascertain that WWDA has complied with the grant deed. This makes the Audit more expensive for WWDA and is an expense that could be reduced if the organisation was funded on a triennial basis.

 

 

 

  • Remittance slips – FaCSIA remittance slips (or payment advice slips) do not contain enough information, i.e.: no breakdown of the payment amount (base amount, GST, CPI), no Reference numbers etc. WWDA has often had to ‘chase up’ the Remittance Slip because FaCSIA has ‘forgotten’ to send it.

 

 

 

  • Inconsistency across Department sections – it has been WWDA’s experience that different sections within FaCSIA have different financial reporting requirements. This can make it difficult and confusing for the Grantee organisation.

 

SUGGESTIONS FOR CONSIDERATION

    1. Financial accountability should be limited to ensuring that the money provided by Government has been spent for the purpose/s intended. Accountability could be simplified by permitting organisations like WWDA to nominate their overhead/administration charges at a fixed rate or proportion of funds received and simply deduct these from the moneys received, leaving the organisations to account only for material items of project expenditure (the level of materiality could be set in guidelines) outside our general administrative costs. In general at the time of project approval, it is determined that the amount of funds applied for accords with the purposes set out in a proposal. Once the level of funding for achievement of the purposes has been agreed as reasonable, the primary accountability should be whether the activities funded were undertaken satisfactorily; whether the purpose was met.

 

 

  • Synchronize deadlines for financial reporting across programs, regardless of the end date, so that organisations can have all program funding received in that financial year, audited at the same time. Financial reporting should run on the financial year.

 

 

 

  • FaCSIA should allow Grantees to have a single bank account, and to use financial accounting software to manage the individual project’s funds separately.

 

6.2. Performance Reporting

There are a significant number of issues relating to Performance Reporting that create unnecessary work and strain on WWDA and which impact on the capacity of the organisation to concentrate its efforts on its core business of improving the status of women with disabilities in Australia. The multitude of issues includes:

  • There is no recognition of the individual advocacy work WWDA does on a daily basis assisting women with disabilities in crisis. Nor is account taken of the extent of the advisory role which WWDA has with state and regionally based organisations, or the demands on staff and management committee members in time and energy expended in providing information to its constituents about disability, health and other services, and to answering enquiries from personnel in those services.
  • The outcomes, outputs and performance indicators (contained in the annual operational funding contract) do not reflect the nature of the work WWDA does, particularly the nature of systemic advocacy where meaningful outcomes can take more than one year (the contract term) to achieve;
  • The outcomes, outputs and performance indicators are too prescriptive, inflexible and appear to focus too much on quantitative measures of performance, e.g. ‘Number of submissions written’ and ‘Number of members’ are not indicative of level of performance or achievements. Clearly, outputs and outcomes should be understood to represent both quantitative and qualitative results of work undertaken. Whilst WWDA could restrict its reports to the quantitative measures required, its policy is to also assess and report on qualitative outcomes;
  • FaCSIA assessments should recognize the importance of qualitative measures in performance reporting and this lack of understanding is reflected in the funding contract;
  • Outcomes, outputs and performance measures within a single Grant Deed should be commensurate with the amount of funds received. Often performance indicators are too numerous and unrealistic;
  • Similarly, the amount of reporting required for small grants is disproportionately high;
  • Across all levels of funding, the amount of reporting required by FaCSIA is excessive. This leads to unnecessary duplication of information and is administratively burdensome, especially for small organisations;
  • The Outcomes Based Agreement (within the annual funding contract) is full of bureaucratic jargon and concepts which need definition or explanation;
  • There is no standard reporting framework/format provided by FaCSIA. Performance Reporting formats; frequency, standards etc vary within and between sections and programs of the Department. Ideally all these requirements could be standardized between different Departments;
  • There is a lack of understanding on the part of FaCSIA personnel as to the work WWDA does and what it achieves and this is compounded by the high turnover of FaCSIA personnel within the sections of the Department with which WWDA has to deal;
  • FaCSIA does not provide any feedback or acknowledgment to WWDA on the reports it receives from the organisation, nor does FaCSIA give any recognition to the outcomes achieved by WWDA. There is no evidence that FaCSIA personnel read any of the Reports provided by WWDA.
  • There is no indication from FaCSIA as to how it uses the information it is provided in the performance reports.
  • Excessive requirements for accountability detract from the performance of both the funded and the funding organisation.

SUGGESTIONS FOR CONSIDERATION

    1. Reporting requirements must be streamlined and simplified. Given that WWDA is an established, highly regarded organisation, which has demonstrated its capacity to competently manage government funds, it should only be necessary to provide a written report to FaCSIA on an annual basis. The written report provided to FaCSIA should incorporate the annual audited financial statement and/or Audit Certificate. If the organisation’s Annual Report covers the reporting requirements of the Funding Contract, then this should be sufficient.

 

 

  • Accounting for public moneys should be achieved in a way which gives the appropriate level of accountability for the materiality of the expenditure.

 

 

 

  • Outcomes, outputs and Performance measures should be developed in consultation with the funded organisation, should reflect the nature of the work the organisation does (i.e.: systemic advocacy) and should be for a minimum three year term. Outcomes, outputs and Performance measures need to be flexible and include qualitative components.

 

 

 

  • FaCSIA should develop standard Performance reporting frameworks/templates for use across the Department.

 

 

 

  • A centralized point should be established in FaCSIA which acts as the one coordinating point for peak bodies and organisations funded by FaCSIA.

 

 

 

  • In consultation with the peak advocacy organisations it funds, FaCSIA develop advocacy practice standards to define and describe the requirements for quality and effectiveness in national peak advocacy organisations;

 

 

 

  • FaCSIA should give written acknowledgement of the receipt of a final report, and feedback on its content.

 

 

 

  • FaCSIA should recognize both qualitative and quantitative outcomes achieved by the Grantees.

 


7.0. Summary

WWDA thanks FaCSIA for giving Grantees the opportunity to comment on their relationships and interactions with the Department. The WWDA Management Committee and Executive Director are available to discuss how the changes suggested in this document might be implemented, and looks forwarded to reduction of Red Tape, and the development of streamlined consistent practices in all programs Department-wide.