Poor record-keeping practices have continued through several machinery-of-government changes to live on in the Department of Home Affairs, reports auditor-general Grant Hehir, adding that a high level of senior executive turnover hasn’t helped the situation.
The information management issues go back over 10 years to well before the 2014-15 merger of customs and immigration agencies, which was swiftly followed by a rapid loss of corporate memory.
Almost half of the Department of Immigration and Border Protection’s senior executive service officers left between July 2015 and July 2017, Hehir confirms, and the exodus began months before that.
Half of the deputy secretaries employed at the start of that two-year period had left by the end of it, as had 61% at first assistant secretary level and 47% of assistant secretaries.
Home Affairs is providing nowhere near as much extra revenue as the business case for the merger promised, and has failed to verify efficiency savings the government has been banking on, by removing the predicted amount from the department’s budget. The department says it disputes some of the audit’s financial conclusions.
The auditors estimate the department will only provide less than one third of a big windfall in extra customs duty it committed to delivering, in its business case for integration.
The department put considerable effort into explaining and selling the integration, but never got around to implementing a detailed “benefits realisation plan” to make sure it was as successful as hoped. Home Affairs has now agreed to get right onto that, in response to one of three recommendations.
“The plan was not implemented despite several reviews identifying this omission,” Hehir reports. “As a result, the department cannot demonstrate to the government that the claimed benefits of integration have been achieved.”
In one extract of departmental responses throughout the report, a senior official says the reforms are still a “work in progress” and they expect the “processes will mature” further in the next year. “At this point, we have established benefits for each of the Programmes and all bar one has provided the detailed Benefit Profile information,” they add.
The report details how the department’s complicated reform plans have changed considerably since the integration was announced, making it increasingly unclear what success looks like and how it can be measured.
The more things change…
The loose information management practices encoutered by the audit team are nothing new. Their report notes the same sort of issues were identified in a 2005 review of the unlawful detention of Australian citizen Cornelia Rau by the organisation then known as the Department of Immigration and Multicultural and Indigenous Affairs.
The Australian National Audit Office report describes the kind of environment in which officers might be able to hide documents deliberately.
“In some cases, the ANAO was able to subsequently locate the documents through its own searches of the department’s systems, although key records forming parts of series were not able to be located. In a significant number of cases, the department was unable to locate the documents.”
As in many departments, a lot of staff don’t use the electronic document and records management system, TRIM, as they are supposed to. Instead they often store files on network drives, “which are not designed or approved for electronic document storage, retention or retrieval” as the report explains.
Perhaps to reduce the risk of embarrassment, the report writers hid this little tidbit away in a footnote:
“The ANAO found numerous non-personal network drives with names which give no indication of their contents such as ‘Random useful stuff’, ‘old stuff’, ‘Ministerial stuff’ and simply ‘stuff’.”
Quoting the National Archives, the next footote explains why this is not good enough in the public service. Essentially, an EDRMS is designed to create a reliable digital paper trail, at least as reliable as the physical version of the past, with its rubber stamps and carbon copies, if not more so.
The regular old Windows folders simply don’t cut it, for various reasons listed briefly in the report. Anyone with access to a regular networked storage drive can change or delete its contents, metadata is often missing or insufficient, the documents aren’t linked together coherently and there are often endless versions of the same thing, wasting space and causing confusion.
This is not to say public servants are refusing to use the TRIM software to avoid accountability – making an administrative system part of the daily routine is always easier in theory than it is in practice – but it should not even look like they could be hiding things.
“The department’s inability to locate some documents requested was not assisted by a high turn-over of senior staff, leading to a loss in corporate memory,” the auditors observe.
Hehir notes the department’s senior leaders have been told about its poor record-keeping over and over again, but multiple attempts to supposedly improve this have failed.
A November 2016 records and information management action plan submitted to the executive committee detailed these issues and the risks they posed to the department, proposing that it put two extra staff and $320,000 towards improving the situation, but this was not taken up.
“The audit found that the department did not maintain adequate records of the integration process. This finding repeats the outcomes of a substantial number of audits and reviews going back to 2005.
“The department’s own assessment is that its records and information management is in a critically poor state. The problems and their solutions are known to the department, and it has an action plan to address them, although numerous previous attempts to do so have not been successful.”
While ANAO explicitly reports that “record-keeping continues to be poor” in Home Affairs, the department only accepts it fell short of best practice “at that time” and claims to have already taken “significant steps” yet again to fix this.
The audit office says “urgent and significant action” is required, especially as the public service behemoth has taken on even more functions in its recent upgrade to Home Affairs.
The department responded:
“The Records Management Action Plan 2016–20 commenced in mid-2016 with a number of foundational activities having been completed. This included the introduction of mandatory online training, the development of a Business Classification Scheme and Taxonomy, and completed transition to a single records management System (TRIM RM8). There will be ongoing reviews undertaken to assess record keeping practices in high-risk business areas which will commence in 2018–19.”
Searching for the bright side
There are few positive lines in the report. Among them, Hehir reports the merger was completed “in a structural sense” and notes that sound and “largely effective” governance arrangements were put in place with adjustments in response to “emerging issues” over time.
It also has sound monitoring arrangements for a suite of 38 capability uplift projects, as noted in the brief response, the bulk of which appears to be contained in appendices that were kept out of the published audit report.
Home Affairs puts an optimistic spin on the findings, summarising of all of the report’s best points in a single pararagraph. It proudly notes the integration of customs and immigration functions was “successfully achieved” but there were plenty of shortcomings in the process.
This meant the wider transformation into a massive combined immigration and border protection entity did not live up to the promise of its 1000-page business case, described as “the department’s commitment to the government on what was to be achieved, by when, and the expected benefits of integration” in the report.
A Reform and Integration Task Force was broadly effective, but it was also abolished too soon, causing “a loss of momentum in the reform process and a drop-off in internal communication with staff” before a similar mechanism was reinstated.
At first, the departmental executive was not directly keeping an eye on the 38 specific capability reform projects, but this was picked up in a gateway review and the higher-ups were provided with performance dashboards in January 2016. The minister was also left in the dark about progress of the reforms.
The merger was a bonanza for consultants, but their contracts were not managed well, and this has drawn criticism of the government from the opposition.
“Despite a requirement to evaluate contracts upon completion, this did not occur in 31 out of 33 (94 per cent) contracts with a value of more than $1 million examined by the ANAO, and therefore it is unclear whether these services represented value for money.”
Home Affairs couldn’t tell the auditors which of its consultancy contracts were related to the integration, either, and which were business as usual.
The auditors found evidence of concerns in the department about the preformance of two of these contractors, but neither were evaluated. Both were eventutally cancelled, but only a few per cent of the total payment was saved in each case.
Home Affairs has agreed to “develop a business assurance approach to enforce its requirement in the Contract Management Manual that contracts be evaluated on completion” and says in its response that a new “procure to pay” system it is implementing will help.
The auditors note the project planning documents for this do not refer to the evaluation requirement.
In its brief summary response, the department suggests it disagrees with some of the report’s implications:
“Home Affairs disputes in some instances the financial conclusions drawn within the report, and whether or not certain elements were outside the scope of the audit, as well as statements made in regards to project management and the overall visibility of the Executive in relation to the integration project.”
Lessons in large-scale MoG changes
The auditors have drawn an unusually extensive list of “key learnings for other agencies” from looking at the creation of the Department of Immigration and Border Protection prior to its evolution into Home Affairs.
Its comment to other agencies, related to the benefits realisation plan that fell by the wayside, is particularly sharp:
“When drafting such plans, entities should think carefully about whether indicators designed to demonstrate benefits are ‘real’, measurable and reportable (as opposed to simply aspirational).
“Implementation work on plans needs to commence from the outset, not left until after the change (or project) is completed.”
The audit office also advises all entities to make EDRMS systems like TRIM mandatory, and train staff in how to use them, and not to skip elements of best practice change management in times of major organisational upheaval.
And, when hiring consultants, it adds a reminder to make sure you’re getting your money’s worth through end-of-contract evaluations.