Government advertising

Tabled: 6 April 2022

Snapshot

Do government advertising campaigns comply with the Public Administration Act 2004 and are they cost-effective?

Why this audit is important

The Victorian Government spends at least $80 million a year on advertising. 

Given the potential political sensitivity, public sector agencies must comply with the advertising laws and show how the public will benefit from these campaigns.

In 2017, the Victorian Parliament passed laws to ensure government advertising is in the public interest and to stop public sector agencies publishing political advertising.

What we examined

We looked at whether two government advertising campaigns complied with the 2017 laws and were cost-effective. They were:

  • the 2019 Our Fair Share (OFS) campaign, which advocated for more Commonwealth funding for Victoria
  • Victoria's Big Build (VBB), a multi-year campaign about major transport projects. 

We examined the six agencies involved in the campaigns. 

What we concluded

In our opinion, the campaigns did not fully comply with the 2017 laws. Most OFS and a small number of VBB advertisements were political, in that they could easily be seen to:

  • promote the current Victorian Government
  • in the case of the OFS campaign, criticise the current Commonwealth Government. 

The agencies interpret the 2017 laws differently. They maintain they complied with their obligations.

The conflicting interpretations show the laws are not sufficiently clear. This needs to be remedied.

In addition, the agencies could not show, nor is it clear, that the campaigns were cost-effective.
 

What we recommended

We made seven recommendations, including:

  • a review of the 2017 laws 
  • stronger oversight of government advertising
  • better evaluation and reporting of advertising cost-effectiveness.  

Video presentation

Video transcript

Key facts

This image shows key facts from the report.
Source: VAGO, based on information from the Department of Premier and Cabinet’s Victorian Government Advertising Report 2019–20 and agencies’ annual reports between 2017–18 and 2020–21 for Our Fair Share and Victoria’s Big Build campaign costs.

What we found and recommend

We consulted with the audited agencies and considered their views when reaching our conclusions. The agencies’ full responses are in Appendix A. 

Legal compliance

Compliance with the Public Administration Act 2004

In 2017, the Parliament introduced new laws into the Public Administration Act 2004 (PAA) to regulate government advertising and communication. The laws aim to ensure government advertising is in the public interest and not party political. They also limit government advertising on television to certain purposes, such as promoting public safety or promoting economic development. 

Before the Parliament passed the laws, it added extra clauses. The extra clauses were meant to stop other types of political advertising, particularly advertising promoting the government of the day. They require public sector agencies to ensure advertising is not designed or intended to influence public sentiment for or against the current Victorian or Commonwealth governments. 

We audited two government advertising campaigns against the laws:

  • The 2019 OFS campaign, which advocated for more Commonwealth funding for Victorian schools, health care and transport projects.
  • The VBB campaign, a multi-year campaign about the Victorian Government's major transport projects and related travel disruptions. We looked at two phases of the campaign—one from 2018 and part of a later VBB campaign from 2019–20.  

The two campaigns met most of the requirements in the laws, including the public interest requirements. However, in our opinion, they did not always comply with the Parliament's extra clauses on political advertising:

  • Most OFS advertisements included statements that could easily be seen as criticising the Commonwealth Government’s funding for schools, health and transport in the lead-up to the 2019 federal election. 
  • Most OFS advertisements, and a small number of VBB advertisements, included messages that could be easily seen as promoting Victorian Government spending on projects. 

It is also our opinion that the OFS campaign did not comply with the limits on television advertising. 

Conflicting interpretations of the law

We sought independent legal advice from the Victorian Government Solicitor’s Office (VGSO) about the 2017 laws. Its advice informed our interpretation of the laws, our assessment of the campaigns and our conclusions. 

The audited agencies interpret the laws differently. They have their own legal advice, obtained prior to campaign launch and during this audit. The agencies state that they were motivated either solely or in part (Department of Education and Training (DET)) by the public interest and believe they complied with their legal obligations. 

The conflicting legal opinions show the intent and operation of the laws are not sufficiently clear. We support an independent review of the laws to assess whether they provide clear standards. 

Internal compliance systems 

The Department of Premier and Cabinet (DPC) helps to promote compliance with the 2017 laws by publishing guidance for agencies. But its information for agencies, and for the public, does not mention the extra clauses added by Parliament. 

The agencies involved in the campaigns told us they were aware of the 2017 laws. But their internal compliance systems were not always:

  • clearly documented—except for DET and Major Transport Infrastructure Authority (MTIA)
  • proportionate to the risks involved in the campaigns. 

Whole-of-government oversight arrangements

Government advertising campaigns also go through a central approval process. An officer-level committee—the Advertising Approval Group (AAG)—assesses campaigns to ensure they comply with legal and policy requirements. 

In the case of these two campaigns, DPC (which chairs the AAG and provides its secretariat) did not always ensure the process was robust. DPC:

  • did not ensure that the AAG's terms of reference and responsibilities were clear
  • did not ensure the AAG had adequate information about legal risks involved in the campaigns, or sufficient time and expertise to discharge its responsibilities
  • allowed officers involved in developing the campaigns to sit on the AAG when it reviewed the campaigns. This meant those officers effectively reviewed their own work, undermining the oversight arrangements.

The AAG secretariat in DPC is small and lacks the resources needed to support the AAG’s functions effectively.  

Accountability for compliance 

In the case of the OFS campaign, one of the agencies involved—DPC—did not accept it was legally responsible for the campaign.

DPC prepared the campaign with DET, the Department of Health (DH) and the Department of Transport (DoT). DPC initiated the campaign, helped develop the advertisements and arranged the media bookings. 

The three other agencies accept that they caused the campaign's publication and that they were legally responsible for compliance. DPC does not. We disagree.

Recommendations about legal compliance

We recommend that:   Response

Department of Premier and Cabinet

1. commissions and publishes an independent expert review of the government advertising laws in the Public Administration Act 2004 (including section 97C(a)(iv) and (v)) that:

  • consults relevant stakeholders
  • assesses whether the laws are clear
  • provides a report including any recommended legislative changes 
  • and advises the government on any recommended changes (see Section 2.2).

Not accepted by: Department of Premier and Cabinet

2. updates its information for agencies, and the public, about the government advertising laws in the Public Administration Act 2004 to include section 97C(a)(iv) and (v) (see Section 2.3).

Accepted by: Department of Premier and Cabinet

3. strengthens the whole-of-government oversight arrangements for government advertising to:

  • clearly describe the respective responsibilities of public sector bodies, the Advertising Approval Group and Department of Premier and Cabinet in ensuring compliance with the Public Administration Act 2004
  • ensure the Advertising Approval Group has sufficient information, time, expertise and resources to fulfil its terms of reference 
  • require officers involved in developing campaigns to excuse themselves from Advertising Approval Group meetings when the Advertising Approval Group is reviewing and approving their campaigns  
  • keep clear records of all approvals (see sections 2.4 and 2.5).

Accepted by: Department of Premier and Cabinet

Department of Premier and Cabinet
Department of Education and Training
Department of Health
Department of Transport
Major Transport Infrastructure Authority

4. document risk-based processes for checking advertising campaigns’ compliance with the Public Administration Act 2004. In particular, for high-risk and/or sensitive campaigns, agencies should:

  • seek detailed and/or external legal advice 
  • ensure that the agency head confirms compliance with the Public Administration Act 2004 (see Section 2.3). 

Accepted by: Department of Education and Training, Department of Health, Department of Transport, Major Transport Infrastructure Authority

Partially accepted by: Department of Premier and Cabinet

Cost-effectiveness 

Cost-effectiveness of the audited campaigns

The agencies involved in the two campaigns could not demonstrate that the campaigns were cost-effective. This was partly due to inadequate planning. The agencies did not always set clear and measurable campaign objectives and performance targets.

In addition, agencies did not evaluate their campaigns once they had finished, to check whether they met their campaign objectives and targets. A review was undertaken for VBB only; however, the conducted assessment was not systematic or objective enough to be considered an evaluation.

This meant agencies could not show that their spending on the campaigns was effective or provided value for money.

We found similar problems in our last audit of government advertising in 2012, but agencies are yet to adequately address the issues. DPC provides some guidance to agencies on evaluations, but it must be strengthened to promote better practice. 

Public reporting

Under government financial reporting rules, agencies must report publicly on all campaigns over $100,000 in their annual reports. DPC also publishes two reports every year—one summarising all major government advertising campaigns and one reporting on whole-of-government advertising expenditure.  

MAMS refers to the Master Agency Media Services media buying contract through which Victorian Government media strategy, planning, buying and reporting services can be procured.

These reports promote accountability and transparency, but they can be improved. 

The agencies’ public reports were often incorrect and incomplete. Some reports contained errors, such as figures that did not add up or figures that did not match paid invoices. DPC's reporting on whole-of-government advertising expenditure excludes significant costs, such as creative development, and Master Agency Media Services (MAMS) fees. Therefore, it does not reflect the true cost of government advertising. Agencies also publish data mostly in Portable Document Format (PDF) reports, which makes comparison and analysis difficult. As a result, agencies are not reporting campaign costs in an accountable and transparent manner.

Recommendations about cost-effectiveness 

We recommend that:   Response

Department of Premier and Cabinet

5. revises the Governance Guidelines and associated processes to ensure that:

  • it assesses agency compliance with the Governance Guidelines  
  • agencies provide a cost–benefit analysis when seeking approval for high-risk or high-cost campaigns 
  • minutes of the Advertising Approval Group meetings record the Advertising Approval Group’s deliberations regarding the responsibilities in its terms of reference, including ensuring value for money, compliance with legislation and appropriate evaluation of campaigns
  • agencies have sufficient guidance to ensure that campaigns are evaluated in an objective and systematic way against campaign objectives. At a minimum this should include better practice for evaluations identified in this report
  • agencies and the Advertising Approval Group have sufficient guidance on how to assess:
    • public benefit, value for money and effectiveness, and financial performance
    • whether a campaign is likely to be sensitive and/or high-risk (see sections 2.4 and 3.1).

Partially accepted by: Department of Premier and Cabinet

Department of Premier and Cabinet 
Department of Treasury and Finance

6. include reporting guidance to agencies on: 

  • reporting campaign expenditure, to ensure consistent and complete reporting of campaign costs
  • requirements for ensuring the accuracy of public reporting, including ensuring documentation of underpinning calculations and use of the Master Agency Media Services dashboard to check accuracy
  • public reporting on campaign evaluation summaries in their annual reports and acquitting costs against approved budgets (see Section 3.2).

Accepted by: Department of Premier and Cabinet, Department of Treasury and Finance

Department of Premier and Cabinet

6. in its whole-of-government reporting:

  • provides total campaign advertising in more accessible formats such as online dashboards 
  • ensures that its reporting on whole-of-government advertising expenditure reflects total campaign expenditure, including creative and campaign development, Master Agency Media Services fees and other costs (see Section 3.2).

Accepted by: Department of Premier and Cabinet

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1. Audit context

The Victorian Government uses advertising to communicate with the public about important issues, such as government services, changes to the law and health and safety. It spent at least $84.6 million on advertising in 2019–20. 

In 2017, the Victorian Parliament introduced new laws to ensure government advertising is in the public interest, and to stop public sector agencies publishing political advertising. 

Agencies are required to evaluate their campaigns to show whether they were cost-effective. DPC and agencies are required to report publicly on their advertising costs.

1.1 Government advertising in Victoria

Governments use advertising to communicate with the public about issues such as government services, changes to laws and health and safety. 

The Victorian Government classifies advertising into three categories:

  • Campaign advertising is intended to inform, educate, motivate or change behaviour. Examples are road safety and regional tourism campaigns.
  • Functional advertising includes simple, one-off advertisements such as legal notices and requests for tender. 
  • Recruitment advertising promotes job vacancies in government.

Government spending on these categories varies from year to year. Figure 1A shows publicly reported expenditure on advertising from 2012–13 to 2019–20 (the government is yet to publish its 2020–21 expenditure). Campaign advertising accounts for most of the expenditure.

FIGURE 1A: Victorian Government advertising expenditure 

Figure 1A shows publicly reported expenditure on advertising from 2012–13 to 2019–20 (the government is yet to publish its 2020–21 expenditure).

Note: The Victorian Government's publicly reported advertising expenditure does not reflect total costs (see Section 3.2). 
Source: VAGO, based on Victorian Government Annual Advertising reports.

1.2 Legal requirements  

Government advertising must comply with a range of Victorian and Commonwealth laws. In this audit, we looked at the PAA. 

In 2017, the Victorian Parliament added new laws to the PAA to regulate government advertising and communication. The objects of the laws include ensuring advertising is in the public interest and not party political. 

Before the Parliament passed the laws, it added some extra clauses. They were intended to stop other types of political advertising, particularly advertising that uses public money to promote the government of the day. The extra clauses require public sector agencies to ensure advertising is not ‘designed or intended to directly or indirectly influence public sentiment for or against’: 

  • the current government of the state
  • the current government of the Commonwealth.

In the PAA and Regulations, public sector communication means information, material or messages published by or on behalf of a public sector body. 

The government at the time opposed the extra clauses at first, noting that they might stop the state government advocating for Victorians against the Commonwealth. But it later agreed to the amendments and they passed into law. 

In 2018, the Victorian Government added more detailed standards through the Public Administration (Public Sector Communication) Regulations 2018 (the Regulations). 

The legal requirements in the PAA and Regulations apply to 'public sector communication'. For simplicity, in this report we use the term ‘advertising’ to refer to all paid public sector communication.

The agency that publishes the advertising, or causes it to be published, is responsible for complying with the legal requirements.

FIGURE 1B: Main legal requirements in the PAA and Regulations

Legal requirements in the PAA and Regulations

Public interest requirements

Section 97B requires public sector agencies to ensure publication of government advertising is in the public interest. 

The Regulations list 12 examples of purposes that are in the public interest. They include:

  • informing the public of new, existing or proposed policies, projects or legislation
  • promoting public safety, personal security or behavioural change
  • advocating on behalf of Victoria to advance Victoria's position or interests. 

Political advertising requirements

Section 97C requires public sector agencies to ensure that government advertising is not ‘designed or intended to directly or indirectly influence public sentiment for or against’:

  • a political party
  • a candidate for election
  • a member of Parliament
  • the current government of the state
  • the current government of the Commonwealth.

The Regulations set out further restrictions. For example, they prohibit advertising that refers to a political party or includes a political party’s slogan, image or brand. 

Television advertising requirements

Section 97D requires public sector agencies to ensure that the purpose of government advertising on television is one of the following:

  • promoting public safety, personal security or behavioural change
  • promoting social cohesion, civic pride or community spirit within the general public
  • promoting commercial or economic development within the state
  • generating revenue for public sector bodies or for the state through consumption of products or services delivered by or in partnership with public sector bodies
  • promoting compliance with legislative requirements.

Other requirements

The PAA and the Regulations also have other requirements for government advertising. For example, government advertising must not:

  • denigrate without grounds, individuals, groups or organisations
  • present information as fact if the information ‘is not reasonably able to be substantiated as fact’
  • promote services, activities or infrastructure projects for which funding is not yet approved. 

Source: VAGO.

1.3 Whole-of-government oversight arrangements

The Victorian Government also has whole-of-government oversight arrangements for its campaign advertising. 

Planning, approval, evaluation and reporting

The oversight arrangements include central processes for planning, approving, evaluating and reporting on government advertising. 

DPC outlines the arrangements in the Victorian Government Advertising Planning and Approval Process. In this report, we call this document the Governance Guidelines.

The Governance Guidelines say the government maintains ‘robust review and governance processes’ to maximise the efficiency and effectiveness of government advertising, and ensure advertising is undertaken ‘for an appropriate purpose that delivers a genuine public benefit’. 

There are four main bodies involved in the arrangements:

  • Departments each have a senior communications executive (SCE) who coordinates the process for their department and its portfolio agencies. 
  • DPC provides secretariat support for the arrangements. It also issues other guidelines and standards on government advertising. 
  • AAG is an officer-level committee chaired by a DPC executive officer. Its members include two SCEs from departments (membership rotates every six months) and two members nominated by ministers. It undertakes ‘detailed peer review’ of campaigns. 
  • The Advertising and Communications Planning Committee (ACPC) is a Cabinet committee responsible for government advertising and communication. 

Figure 1C gives an overview of the arrangements and the main responsibilities of these bodies.

FIGURE 1C: Overview of the Victorian Government advertising process 

Figure 1C gives an overview of the arrangements and the main responsibilities of these bodies.

Source: VAGO, based on Victorian Government Advertising Planning and Approval Process, DPC, 2019. 

Expenditure controls

Funding envelope, in this context, means the total amount that the government allocates for campaign advertising during the financial year.

To help control and track advertising expenditure, the government has a central state purchase contract for MAMS. Agencies must use the appointed MAMS contractor to plan and buy advertising space. The government sets an annual funding envelope for MAMS expenditure during its annual planning process. 

Agencies can develop creative material in-house or engage an external creative agency through the state purchase contract for marketing services. 

1.4 The two audited campaigns

This is our first audit of government advertising since the Parliament introduced the 2017 laws in the PAA. 

We looked at two government advertising campaigns—the OFS campaign and the VBB campaign. We examined whether the campaigns complied with the 2017 laws and related regulations, and whether the campaigns were cost-effective.

Our Fair Share 

The OFS campaign ran from April to June 2019. Its objectives included securing more Commonwealth funding for Victorian public schools, health care and transport projects.

The OFS campaigns grew from a February–March 2019 radio campaign called Fairer Funding. DET funded that campaign, which focused on funding for schools. 

In March 2019, following discussion with the Premier’s Private Office, DPC asked three agencies—DET, DH (which was then part of the Department of Health and Human Services) and DoT—to prepare a broader integrated campaign that covered funding for schools, health and transport. The Premier’s Private Office advised us that it is common practice for it to have discussions with DPC on major advertising campaigns. 

The Premier launched the school and health parts of the campaign on 14 April 2019. The transport part of the campaign began a week later, on 21 April 2019. The campaigns involved advertisements on television, radio, print media and digital platforms and on ‘live banners’ at football stadiums. 

The publicly reported cost of the campaign in 2018–19 was $1.7 million. 

The OFS campaign coincided with the 2019 federal election, which was announced on 11 April 2019 and held on 18 May 2019. This led to complaints that the campaigns involved political advertising.

FIGURE 1D: Timeline for the OFS campaign

Figure 1D shows the timeline for the OFS campaign.

Source: VAGO, based on department records. 

Victoria’s Big Build

The VBB campaign is a multi-year campaign that launched in February 2018. Its objectives include informing Victorians about travel disruptions associated with major transport infrastructure projects. 

DoT (which was then part of the Department of Economic Development, Jobs, Transport and Resources) started the campaign in 2017. It was concerned that individual transport projects were running separate campaigns on travel disruptions, creating clutter and confusion for people affected by the projects. It wanted an integrated campaign covering all major transport projects and disruptions. 

In January 2019, the Victorian Government created MTIA to take responsibility for major transport infrastructure projects. The MTIA also took over responsibility for the VBB campaign.

The publicly reported cost of the VBB campaign between 2017–18 and 2020–21 was $11.5 million, out of a total $33.75 million spent on advertising related to disruptions from transport construction during the same period. 

Out of the many VBB campaign phases since 2018, we selected two for examination:

  • the initial Travel Plan B phase that ran from February to June 2018. This campaign involved television, radio, newspaper, digital and outdoor (billboard) advertising.
  • the Summer Blitz phase that ran from December 2019 to February 2020. This campaign involved television, radio, newspaper and digital advertising.

FIGURE 1E: Timeline for the VBB Travel Plan B campaign and Summer Blitz phases

Figure 1E shows the timeline for the VBB Travel Plan B campaign and Summer Blitz phases.

Source: VAGO, based on DoT and MTIA records.

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3. Cost-effectiveness

Conclusion

The agencies involved in the two advertising campaigns could not show that the campaigns were cost-effective. Systems for assessing cost-effectiveness were inadequate. Agencies did not always set clear campaign objectives and targets for assessing the campaigns’ performance. They did not evaluate systematically and objectively whether the campaigns met their objectives.   

Inadequate reporting on campaign costs limits accountability and transparency around these issues. Public reporting is often incorrect, incomplete, inconsistent and hard to access.

3.1 Cost-effectiveness of the audited campaigns

Campaign objectives are the outcomes or impacts that the agency is trying to achieve.
A target is a measure for expected or desired level of activity.
A benchmark is the industry or sector-level standard that agencies use to assess their own performance.
Cost-effective means that agencies achieve their campaign objectives for the least cost.
Value for money means achieving the desired outcome at the best possible price. It requires consideration of non-financial factors, such as quality, as well as financial factors.
Evaluation involves an objective and systematic assessment against campaign objectives.

The Governance Guidelines say that the Victorian Government is committed to maximising the efficiency and effectiveness of advertising expenditure. The Guidelines require agencies to set objectives and measures for campaigns, and to evaluate campaigns against those metrics. This ensures agencies are accountable for their spending, and that they document lessons learned to improve future campaigns.

In the case of the OFS and VBB campaigns, agencies could not show that the campaigns were cost-effective. They could not show that the campaigns met their campaign objectives or that they provided value for money. This situation arose because of: 

  • inadequate planning of objectives and measures by agencies
  • missing or inadequate evaluations
  • inadequate whole-of-government guidance and oversight by DPC. 

Inadequate planning of campaign objectives and measures by agencies

Before campaigns begin, agencies are meant to plan how they will evaluate campaign effectiveness. DPC’s Campaign Strategy Approval Form, which agencies submit to the AAG when seeking approval for campaigns, requires them to list campaign objectives, along with benchmarks and target measures for judging their success.  

In the case of the OFS and VBB campaigns, these plans were incomplete or inadequate. 

One agency involved in the OFS campaign—DH—did not develop any plan for how it would evaluate its campaign. It left this section of its form blank. 

In other cases, agencies used measures that did not fairly represent performance. Their objectives and measures were not always clearly defined or measurable. Figure 3A provides an example for each of these.

FIGURE 3A:Example of a campaign objective, target and benchmark that were not clearly defined or measurable

Category Agency statement Issue

Objective

Raise awareness of the health funding challenges within Victoria and advocate for better funding for Victorian health care provision, particularly hospitals (OFS)

DH did not identify:

  • whose awareness needed to be raised
  • what the health funding challenges were 
  • who it would advocate and how it would do this
     

Target

Positive anecdotal evidence from staff on the ground at disruption (VBB)

DoT and MTIA did not include details on how they would measure or assess this. 

Benchmark

Low awareness of school funding sources (OFS)

DET did not describe how it rated or measured ‘low’ awareness. The benchmark also did not provide a clear baseline against which DET could measure any change in awareness.

Source: VAGO.

The inadequate planning increased the risk that agencies could not effectively evaluate the cost-effectiveness of their campaigns. 

Missing or inadequate evaluation 

Agencies are meant to evaluate their campaigns against their campaign objectives within three months of the campaign’s conclusion. DPC’s form asks agencies to:

  • report whether they met their campaign objectives, benchmarks and targets
  • acquit their final expenditure against their planned expenditure for each objective.

The agencies involved in the OFS campaigns did not comply with these requirements. DPC did not consistently follow up with agencies to ensure compliance.

Where agencies reviewed the campaigns, these reviews were not systematic and objective assessments against campaign objectives. For example:

  • In the case of the VBB campaign, DoT sought to evaluate against its objectives. It concluded that Travel Plan B met its objectives. However, one of DoT’s targets was to achieve 90 per cent awareness among public transport and road users. In the review, DoT did not show it had achieved that target. Another target measure said DoT would consider anecdotal evidence from staff on the ground at project sites. The evaluation did not include such evidence. 
  • For Summer Blitz, MTIA commissioned other research on the VBB campaign, including survey and focus group feedback on their advertisements. However, this research was also not an objective and systemic evaluation of the campaign. 
  • For all the campaigns audited, the agencies received a post-campaign report from the MAMS provider after the completion of the campaign. The report included cost, reach and engagement analytics. However, it did not constitute an objective and systematic assessment against campaign objectives.

We reported similar problems in our last audit of government advertising in 2012. That audit identified that agencies were either not evaluating campaigns or that their evaluations were inadequate. It also found that DPC was not requiring agencies to acquit their expenditure against approved budgets.

Agencies are yet to properly address these issues.

Inadequate guidance provided by DPC

DPC needs to improve its guidance to agencies to ensure that evaluations are appropriately planned and completed. The Governance Guidelines did not provide sufficient guidance on how to:

  • ensure public benefit
  • evaluate campaigns
  • monitor campaigns’ value for money and effectiveness.

SMART objectives are specific, measurable, achievable, relevant and time-bound.

Program logic is the framework for the relationships between resources, activities and results. In the case of advertising, it may be one of many activities that contributes to the achievement of results.

DPC changed the Governance Guidelines from 2019. It now advises agencies to ensure their campaign objectives are SMART and to set targets covering both the implementation and impact of their campaigns. The Guidelines also provide examples of possible objectives, benchmarks and target measures. 

However, they do not require agencies to ensure evaluation plans:

  • are based on a robust program logic
  • include data sampling, collection and analysis details
  • include adequate evidence to show that the campaign was likely to be successful
  • include whether the campaign represented the least cost for the required quality
  • show each campaign’s contribution to whole-of-investment advertising objectives and compare to industry benchmarks.

DPC’s guidance on how to evaluate campaigns is also not consistent with better practice. For example, other jurisdictions require agencies to undertake:

  • cost–benefit analysis of high-cost campaigns before approval
  • evaluations using a preferred provider.

Inadequate whole-of-government oversight by DPC

DPC and the AAG are meant to oversee planning and evaluation of campaigns. In the case of these two campaigns, they did not effectively address agencies’ non compliance with requirements.

At the planning stage, the AAG’s terms of reference require it to ensure that campaigns provide value for money, set individual campaign quality benchmarks and ensure campaigns are appropriately evaluated. In the case of the OFS and VBB campaigns, the AAG approved the campaigns without recording any discussion about these issues. The AAG approved DH’s OFS campaign strategy, even though it was missing benchmarks or target measures.  

At the evaluation stage, the Governance Guidelines require agencies to submit evaluations to DPC for all campaigns over $100,000. The AAG’s terms of reference also require it to ensure appropriate evaluation of campaigns. DPC and AAG should have been aware that evaluations for the OFS campaign and the Summer Blitz phase of the VBB campaign were missing. DPC did not follow up with agencies to ensure compliance.   

DPC has not ensured that the AAG has the required expertise and guidance to fulfil this part of its terms of reference by:

  • assessing whether campaigns are strategic, coordinated and at an appropriate level of expenditure
  • ensuring that campaigns provide value for money
  • ensuring campaigns are appropriately evaluated.

DPC submitted that AAG members are properly qualified to perform their role and fulfil their terms of reference. We note that the AAG’s terms of reference involve several areas of specialist expertise, such as legal compliance, assessing value for money and evaluation. DPC did not provide evidence that AAG members all have such specialist expertise.  

3.2 Public reporting

Public reporting promotes accountability and transparency around how much agencies spend on advertising and whether that spending is cost-effective. 

The current arrangements involve two levels of reporting, shown in Figure 3B. 

Financial reporting directions are issued by the Minister for Finance under the Financial Management Act 1994. They set rules for agencies about financial policy and disclosure, as well as some non-financial matters such as annual reports. 

FIGURE 3B: Public reporting on government advertising expenditure

Agency reporting Whole-of-government reporting

Published by individual agencies

Published by DPC

Requirements in Financial Reporting Directions 22I (FRDs) and Governance Guidelines

Requirements in Governance Guidelines

Agency annual reports include details for all campaigns over $100,000:

  • name
  • start and end dates
  • a summary of the campaign
  • costs classified into five categories—
    • advertising (media buy)
    • creative and campaign development 
    • research and evaluation
    • print and collateral
    • other campaign costs.

Annual Victorian Government Campaign Activity Summary report collates details of all campaigns over $100,000 from agency annual reports.

Annual Victorian Government Advertising Report publishes an overview of all government advertising expenditure.

Deadline for reporting No deadline for reporting

Source: VAGO.

Incorrect, incomplete, inconsistent and inaccessible reporting

The agencies involved in this audit complied with reporting requirements overall. However, there were several problems with their public reporting that limited their transparency and accountability.

In this audit, public reporting was sometimes …

Because … 

For example …

incorrect 

agencies did not have reliable processes for recording and verifying campaign costs.

guidance does not require agencies to ensure reported costs are correct, or cover what steps they should take to ensure accurate reporting.

DPC replicated agencies’ information in its whole-of-government reports without checking its accuracy.

agencies' reported costs did not match invoices.
DoT’s OFS reporting had a calculation error. The total cost cited in its report was $40,000 higher than the sum of the various campaign costs.

incomplete

FRDs require agencies to report campaign advertising costs that relate to the MAMS contract. DPC only reports on partial spending on media buy (or MAMS) costs in its Annual Advertising Report’s overview of total government advertising expenditure.

some agencies are not covered by the FRDs. 

MTIA has not reported VBB letterbox drop costs.

DPC’s reporting on total government expenditure excludes some significant costs, such as campaign and creative development and fees and levies for MAMS costs.

Visit Victoria, which spends a significant amount on advertising, does not have to report on its campaign expenditure. It advised us that this is to maintain competitive advantage and to protect its commercial and intellectual property.

inconsistent

guidance does not define cost categories and/or provide guidance on how to classify costs.

guidance is not sufficiently clear on when similar or repeat campaigns should be reported in aggregate or individually.

for the OFS campaign, DH recorded its translation costs under the 'print and collateral' category. DET recorded its translation costs under ‘other’.

DET included the costs of its earlier Fairer Funding campaign in its OFS reporting, even though it was a separate campaign.

hard to access 

agencies mostly publish information in PDF format.

it is difficult to analyse and compare spending by different agencies, by different campaigns or by expenditure over time.

Our 2012 audit also identified problems with the way agencies record and report advertising expenditure. We recommended:

  • agencies introduce rigorous business operations processes to enable consistent and accurate reporting of their advertising expenditure
  • DPC make total advertising and communications expenditure publicly available. 

The Victorian Parliament’s Public Accounts and Estimates Committee also recommended enhancing reporting requirements so that agencies have to identify and report on performance against advertising budgets. 

Agencies are yet to adequately action these recommendations. 

Improving accuracy and accessibility

There are already resources within government that agencies could use to strengthen their reporting. The Department of Treasury and Finance (DTF), which manages the government’s MAMS contract, has several data dashboards that DPC and other agencies could use to cross-check their records and improve their reporting and accountability.

Agencies could also look to good practice in other states. South Australia’s public reporting on government advertising includes:

  • information about the campaign’s proposed budget as well as actual spending
  • a summary of campaign evaluations, which reports on whether campaigns met their objectives.  

An example of where advertising costs are more accessible is the Government Advertising Spend dashboard on our website (audit.vic.gov.au), which collates publicly available Victorian Government advertising spend data in an interactive format. Agencies could explore similar formats to make their public reporting more accessible and effective.

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Appendix A. Submissions and comments

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Appendix B. Acronyms, abbreviations and glossary

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Appendix C. Scope of this audit

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Appendix D. IBAC and Victorian Ombudsman joint letter to the Premier

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