Early childhood grants management procedure

Audience

Early Childhood Division

Purpose

This procedure outlines the responsibilities and processes for the consistent management of grants administered by the Department of Education (the department) through the Early Childhood (EC) division. This procedure applies to all centrally based and regional staff involved in the end-to-end management of grants, including grant program design, administration and evaluation. The department is committed to managing grants in a manner that complies with the Human Rights Act 2019(Qld).

Overview

EC provides grant funding to organisations to support all children and families across Queensland to have access to high quality early childhood education and care services that provide safe, inclusive and nurturing learning environments. Types of grants may include but are not limited to grants that provide for the delivery of services; grants that help fund infrastructure or assets; or grants that strengthen capabilities of families, children, workforce and the sector.

This procedure sets out the mandatory management and operational processes required to support the administration of all grant programs. The practical steps, decision points and control arrangements will vary depending on the grant program’s size, scope, risk and complexity and are set out in internal documents including process maps, work instructions, templates and guides.

This document builds on broad guidance about the administration of grant programs contained in the Queensland Treasury Financial accountability handbook 2024, Volume 6 - Grant management and sits under the Early childhood grants management framework, supporting the Early childhood grants management policy.

Responsibilities

Minister

• Approves project commencement for projects funded from $5,000,000 - $10,000,000 GST inclusive.
• Makes funding declarations under the Community Services Act 2007 (Qld).

Director-General

• Approves Service Agreements where the total contract value for an organisation exceeds the Deputy Director-General's delegation.
• Delegates powers under the Community Services Act 2007 (Qld) to department officers to carry out administrative and finance functions to support the department's business.
• Considers human rights when making decisions related to early childhood grant management, and makes decisions that are compatible with the Human Rights Act 2019(Qld).

Deputy Director-General Early Childhood

• Undertakes functions under the Community Services Act 2007 (Qld) delegated by the Director-General.
• Refers funding/investment proposals to the Early Childhood decision making body, the Early Childhood Leadership Team (ECLT).
• Approves grant program specifications, budget, grant recipients (Grantees) and funding arrangements.
• Authorises Service Agreement variations and terminations.
• Considers human rights when making decisions related to early childhood grant management, and makes decisions that are compatible with the Human Rights Act 2019 (Qld).

Early Childhood decision making body (Early Childhood Leadership Team)

• Measures and monitors matters of strategic significance to ensure the EC Division meets its strategic planning, governance and accountability requirements, including grants and their management.
• Provides advice and direction on financial and program investment principles, frameworks and practices to ensure return on investment.
• Assesses the performance of existing EC investments and program initiatives.
• Considers human rights when making decisions related to early childhood grant management, and makes decisions that are compatible with the Human Rights Act 2019 (Qld).

Executive Directors (delegated authority)

• Undertakes functions under the Community Services Act 2007 (Qld) delegated by the Director-General.
• Executes Service Agreements and variations.
• Approves grant recipients (Grantees) and funding arrangements.
• Specified Executive Director position (Executive Director, Early Childhood Programs and Funding (ECP&F)) can grant an extension for the submission of financial and/or performance reporting under a Service Agreement.
• Specified Executive Director position (Executive Director, ECP&F) can determine and implement an appropriate remedial action where a funded provider has not met their contractual obligations.
• Authorises the release of payments in the grants management system as per the Finance delegations matrix.
• Authorises Service Agreement variations and terminations.
• Approves alternative application processes for grant submissions.
• Approves Kindergarten Program Provider (KPP) applications.
• Considers human rights when making decisions related to early childhood grant management, and make decisions that are compatible with the Human Rights Act 2019(Qld).

Directors

• Undertakes functions under the Community Services Act 2007 (Qld) delegated by the Director-General.
• Validates grants budget and cost centre expenditure.
• Ensures sufficient and appropriate grant management practices are operating to ensure the program delivers its objectives.
• Ensures grant claims and payments are accurately recorded and can be substantiated.
• Specified Director position (Director, Grants Management and Funding (GM&F)) can grant an extension for the submission of financial and/or performance reporting under a Service Agreement.
• Specified Director positions can authorise the release of payments in the grants management system as per the Finance delegations matrix.
• Specified Director position (Director, GM&F) can determine and implement an appropriate remedial action where a funded provider has not met their contractual obligations.
• Resolves discrepancies or disputes regarding grants management in a timely manner.
• Authorised to withhold or recoup funds based on the Periodic Financial Return or Financial Accountability Form.
• Considers human rights when making decisions related to early childhood grant management, and make decisions that are compatible with the Human Rights Act 2019 (Qld).
• Periodically reviews grants management activities to identify opportunities for continuous improvement and better practice.
• Oversees the operational management of stakeholder relationships.

Managers

• Ensures sufficient and appropriate contract management practices are operating to ensure the program delivers its objectives.
• Ensures grant claims and payments are accurately recorded and can be substantiated.
• Resolves or escalates discrepancies or disputes regarding grants management in a timely manner.
• Periodically reviews grants management activities to identify opportunities for continuous improvement and better practice.
• Considers human rights when making decisions related to early childhood grant management, and make decisions that are compatible with the Human Rights Act 2019(Qld).

All staff involved in administering grants

• Maintains appropriate and accurate records in the approved record keeping system to support each decision in the grants management process and enable departmental reporting.
• Complies with financial, system and internal control procedures and requirements when completing grant management activities.
• Discloses any relationships or interests which may or could be perceived to be in conflict with or impact on the impartial administration of the grant program.
• Exercises proper diligence, care and attention when assessing and processing claims for payment to identify and report suspected fraudulent use of grant funds and/or non-compliance with grant funding terms and conditions.
• Considers human rights when making decisions related to early childhood grant management, and make decisions that are compatible with the Human Rights Act 2019 (Qld).

Process

End to end grants management must follow the cycle outlined in the Early childhood grants management framework.

Image 1 - Early childhood grants management framework

1. Grant program design

The Early Childhood Strategy and Performance (ECS&P) branch within EC designs grant programs and initiatives. ECS&P works collaboratively with stakeholders, internal and external to the department, to ensure grant programs are designed to achieve policy objectives and deliver benefits to recipients in an efficient, effective and economical manner.

Types of grants and subsidies

EC provides:

• Queensland Kindergarten Funding subsidies to approved Kindergarten Program Providers (KPPs) in the long day care and sessional kindergarten sectors;
• Early Childhood grants to peak organisations, such as workforce initiatives;
• Early Years Services (EYS) grants to small local services, state-wide organisations and other entities (e.g. local government) to deliver a range of early years and bespoke services across the state; and
• other grant funding programs in response to emerging departmental and divisional objectives.

Define grant program

Program designers within ECS&P must:

• undertake research and planning (including jurisdictional analysis, as determined by the business unit) to identify and define new grant programs that are evidence-based and aligned to the strategic objectives of the department and EC investment principles.
• consult and collaborate with the Early Childhood Programs and Funding (ECP&F) branch as well as other key stakeholders internal and external to the division, to co-design the grant program.
• define the scope of the grant program, taking into account:
  • program objectives that are specific, realistic and measurable
  • evidence/background for investment
  • link to Government and departmental objectives
  • risk
  • funding type (e.g. capital, recurrent, non-recurrent)
  • program budget
  • funding source (Australian Government and/or State)
  • target group/cohort
  • eligibility and selection criteria and assessment process
  • service model parameters, and
  • service provider selection process (e.g. open, negotiated, targeted).

Program planning and development

Program designers within ECS&P will:

• identify any overlap or duplication of grant programs being administered by other funding bodies (e.g. other Queensland Government agencies, the Australian or local governments).
• identify and address general and program specific risks for the whole grant program, from planning to evaluation, including conflicts of interest - perceived or actual. Risk mitigation strategies and controls must be developed, documented and adopted in accordance with the department’s Enterprise risk management framework. High level risks/risks that cannot be adequately managed, in relation to grants at all stages of a grant program, need to be reflected in the department's operational/enterprise risk registers. This requirement is reflected in the workings of the Grant Program Risk Assessment Cycle (GPRAC) tool as it specifies that risks escalated to a high level cannot be adequately managed using the GPRAC tool.
• develop performance measures prior to implementation that reflect the size, complexity and risk associated with the program in consultation with the other areas of the division. Performance measures must be monitored throughout the life of the grant, and a monitoring strategy must be developed prior to implementation. An evaluation plan must also be developed to determine the impacts of the program.
• develop program documentation in collaboration with other areas of the division to support the eligibility and implementation of the program. Examples of the documentation may include but are not limited to funding requirements, category guidelines and service particulars outlined in Service Agreements.
• develop clear eligibility criteria that are transparent and consistent with the department's objectives.
• establish and document the EC appeals process for grant outcomes prior to the commencement of grant programs and communicate to potential applicants, to allow for prompt and effective resolution of issues that may arise from the assessment and awarding process.

Program approval and initiation

Program designers within ECS&P will:

• consider human rights in grant program design, document their assessment of any human rights impacts (department employees only) and save this assessment in the department's records management system.
• prepare a paper seeking ECLT endorsement for the grant/program.
• when endorsed by ELCT, prepare a Briefing Note to the Deputy Director-General (or delegated authority) to seek approval for grant program specifications and budget, noting that:
  • appropriate delegates have been engaged in the process;
  • government priorities, targets, commitments and EC investment principles have been considered; and
  • financial implications and cost centres have been endorsed by the Early Childhood Office of the Deputy Director-General.
• prepare a Briefing Note to the Deputy Director-General EC to approve promotion of the grant program and application and assessment processes. Attachments for approval must include, but are not limited to:
  • funding information paper
  • application form
  • application guidelines
  • assessment plan
  • communication and media documentation, and
  • resolution and appeals process.
• notify relevant EC work units to:
  • publish and promote the grant funding program as directed, including the grant application form and associated materials; and
  • manage enquiries relating to the grant program, including provision of high-level advice and support regarding application lodgement (ECS&P and ECP&F).

2. Grants administration

The ECP&F branch within EC manages the administration of grants and subsidies. Where appropriate, the ECP&F branch will consult and collaborate with other divisions and departments to maximise program benefits and ensure efficiencies and transparency in processes and decision making. All grants must follow the Funding Category Guidelines listed in the Ministerial Funding Declaration (No.1) 2018.

ECP&F must develop, document and implement risk mitigation strategies and controls in accordance with the department’s Enterprise risk management (ERM) framework, using the GPRAC tool in conjunction with the ERM Framework, for high level risks identified after the grant program planning and development phase.

Review grant applications received

To be considered eligible, all applicants must submit grant funding applications using the approved form and process, which must be clearly advertised for all potential grant applicants.

The Executive Director, ECP&F, may approve alternative lodgement arrangements under special circumstances, provided the request is made in writing prior to the application closing date.

The ECP&F branch will receive all grant funding applications and undertake completeness and eligibility checks. Only those applications that satisfy all criteria will be progressed for assessment.

Assess applications and select program provider

Assessment

Grant applications will be assessed against specific eligibility requirements and/or selection criteria specified in the approved program specification. When developing eligibility requirements and/or selection criteria the human rights impact must be considered. Grant applications are assessed by either an individual assessor or an assessment panel, as specified in the assessment plan.

• When an assessor or assessment panel is appointed, the panel will, after the assessment and moderation process, recommend applicants for approval by the Deputy Director-General, EC (or delegated authority).
• The assessor or assessment panel must comply with terms and conditions set out in the assessment plan, including:
  • the function of the assessor or assessment panel;
  • the role of the assessor or assessment panel members;
  • the assessment criteria;
  • the assessment process;
  • assessors' obligations to maintain confidentiality;
  • declaring and managing any conflicts of interest in accordance with the department's Conflict of interest procedure; and
  • assessor's obligation to comply with the Queensland Government Code of Conduct.
• Assessors must clearly demonstrate that grant decisions are equitable, transparent and represent value for money.
• All recommendations and decisions and the reasons for awarding (or not awarding) grants must be appropriately documented and recorded in the approved record keeping system.
• Decision-makers must consider human rights, document their assessment of any human rights impacts (department employees only) and save this assessment in the department's records management system.

Selection

• A competitive, merit-based selection process is the preferred option for selection. Where an alternative method is proposed, assessors must document why this approach has been used. This may occur when the ability to meet cultural needs, remote location access, subject matter expertise or other priorities is limited.
• Short-listed applications may be sent to nominated officials (e.g. regional EC Directors) for comment regarding suitability and risk, before final decisions are made.
• The ECP&F branch will prepare a Briefing Note to the Deputy Director-General, EC (or delegated authority) to approve the list of recommended applicants and funding expenditure. Attachments for approval must include, but are not limited to:
  • Schedule of Recommended Services;
  • Assessment Report or Performance and Financial Assessment Report (where applicable);
  • letters of advice to successful and unsuccessful applicants; and
  • communication material, as required (e.g. media points).

Communicating outcomes

• The grant administrator must update the status of applications in the grants management system at every decision point (e.g. eligible/recommended/approved).
• Applicants must be notified of the outcome, whether the grant application was successful or unsuccessful.
• Unsuccessful applicants must be provided with the opportunity to receive feedback about why they were unsuccessful.
• Any complaints received about a grants management activity or decision will be managed in accordance with the department's Customer complaints management procedure.

Prepare funding arrangement and process payments

Funding arrangements

• Queensland Kindergarten Program funding is administered through the KPP services' acceptance of the Queensland Government Standard terms on application and each time a claim is submitted.
• Long Day Care (LDC) providers with 10 or more services may enter into a Service Agreement to permit them to distribute their base subsidy funding across their services.
• LDC providers with less than 10 LDC services enter into Service Agreements by accepting the Small LDC - Funding and Service Details through the grants management system.
• Central Governing Bodies enter into a Central Governing Body Service Agreement.
• ECP&F’s Applications and Contract Execution (ACE) team will prepare and administer all Early Years Services and bespoke funding arrangements, including renewals, variations or terminations.
• Grant recipients must enter into a formal Service Agreement with EC which specifies the arrangements under which the grant is provided, received, managed, and acquitted.
• The Service Agreement will contain information including, but not limited to:
  • terms and conditions appropriate to the type of agreement
  • definitions
  • service agreement start and end date
  • roles and responsibilities
  • service particulars
  • required milestones/deliverables (if applicable)
  • funding information
  • payment schedule
  • performance measures
  • reporting requirements, and
  • any special conditions.
• The Executive Director, ECP&F, as the delegated authority, will execute the Service Agreements.
• Supplementary agreements may be required for specific matters relating to assets purchased with grant funding, such as a Motor Vehicle Specific Security Agreement.
• The Deputy Director-General or the delegated authority must approve any variation or termination of Service Agreements via a Briefing Note.
• Once funding arrangements have been approved, the ACE team must notify relevant staff within ECP&F and respective contract managers to prepare for payments, monitoring and reporting.
• Extensions and contract renewals will require new Service Agreements.

Variations

• A grant recipient may, due to changed circumstances, request a variation to the terms and conditions in a Service Agreement. For example, a recipient may request a change in the timing of grant payments, or in milestone due dates or similarly, a variation can also be initiated by the department such as extending the end date of a Service Agreement for legitimate reasons.
• The information required for a grant variation may depend on the recipient's circumstances. However, each request must be assessed and documented to ensure that program objectives are being achieved and will continue to be achieved and to ensure the conditions/level of risk is acceptable to the department. Variations must be approved in line with the department’s delegations and documented accordingly.
• Variations may take the form of a Notice, Variation Agreement, or Deed of Variation, depending on the type of variation and/or Service Agreement and associated terms and conditions.

Payments

• Grant payments will be made in accordance with the approved program and funding guidelines and executed Service Agreement.
• The ECP&F Contract Management team will recommend whether funding can be released for executed Service Agreements.
• The GMF team within ECP&F will administer grant payments, which are paid via electronic transfer in the grants management system.
• System controls are in operation to ensure that the payment process steps of determining that a payment is eligible, recommended and approved in the grants management system are appropriately segregated. 
• A delegated officer will authorise the release of payments in the grants management system in accordance with the department’s Finance delegations matrix.
• It is the Grantee's responsibility to ensure all account information in the grants management system, including bank details, is up to date with effective security controls in place.

Withholding or recovery of funds

• Grantees must advise ECP&F via email of any errors in their claim/payment as soon as detected.
• If the error results in an overpayment, the GM&F team will issue a Recipient Created Adjustment Note (RCAN) to the service to recoup the incorrectly claimed funding.
• The ECP&F Contract Management team and/or Assurance Review team in ECS&P will make recommendations to withhold or recover funding.
• The Director, GM&F or the Executive Director, ECP&F, will review each request, taking into account the requirements of the Service Agreement and appropriate program and funding guidelines. This applies only to Service Agreements which have financial acquittals, not for assurance reviews.
• Unless there is an agreement between the department and the grant recipient, the department will recover any unspent funds at the end of the funding period (Service Agreement end date) for Service Agreements requiring submission of financial acquittals or when identified through an assurance review.

Monitor performance and acquit funding

Monitoring

The ECP&F Contract Management team will actively monitor the performance of funded services to ensure that expenditure, activities and expected outcomes are being or have been achieved, in accordance with the terms of their Service Agreement.

Monitoring and contract management activities include, but are not limited to:

• utilising contract management frameworks, procedures and guidelines (where applicable) to guide monitoring activities
• implementing universal, targeted and intensive methodologies of contract management
• ensuring performance targets and reporting deadlines are achieved
• undertaking service visits and meetings (virtual, telephone, face-to-face) to proactively support the delivery of early childhood programs, services, initiatives and activities, and
• providing information and advice to enhance program delivery and reporting.

The ECP&F Contract Management team will liaise regularly with other EC units, service providers, EC stakeholders and the regions to:

• ensure that the monitoring approach effectively accounts for variations in program delivery and enables compliance with Service Agreement terms and conditions, including objectives and reporting deadlines being achieved; and
• oversee financial and operational risks that may impact a service’s capacity to deliver program objectives.

Assessment and acquittal

Grant recipients must submit financial and performance reports and deliverables (if applicable) in accordance with the terms of the Service Agreement. The department uses this information to evaluate the performance of grantees in achieving program objectives as well as their compliance with provisions of the executed Service Agreement. The Director, GM&F and Executive Director, ECP&F, are the only positions delegated to grant extensions to reporting timeframes.

ECP&F Contract Management and GM&F teams will monitor the submission of outstanding reports. The ACE team will manage the non-compliance process which will be invoked for grant recipients that do not meet their contractual reporting obligations.

The ECP&F Contract Management team will assess reports in accordance with the requirements of the program and funding guidelines.

Officers responsible for managing grants must:

• exercise due diligence, care and attention when assessing and processing claims for payment to identify and report suspected fraudulent use of grant funds and/or non-compliance with program and funding guidelines (e.g. the Queensland Kindergarten Funding Essentials), short-form Terms and Conditions or Service Agreement - Standard Terms and the Community Services Act 2007 (Qld) or other relevant legislation; and
• refer inadequate claims or suspicious behaviour by funded providers to the Assurance Review team in ECS&P for further review. More information can be found in the Reporting fraud and corruption procedure.

Where a funded provider has not met their contractual obligations, the ECP&F Contract Management team will refer the matter to the ACE team to determine the appropriate contractual remedy. The Director, GM&F, and the Executive Director, ECP&F, will determine and implement the appropriate remedial action.

Assurance reviews

The department may undertake a range of assurance reviews to ensure a service is complying with its contractual obligations, including targeted, defined and emergent review processes which may include a site visit component. Authorised Officers under the Community Services Act 2007 (Qld) in a designated team within EC will undertake these reviews using a risk-based methodology for initial scheduling each year. This team also receives referrals on a case-by-case basis (through a number of avenues including regional EC staff and ECP&F), when there are concerns raised regarding compliance with the eligibility criteria, appropriate expenditure of funding and/or meeting operational requirements.

3. Program review, analysis and evaluation

Develop an evaluation plan

Program evaluators within EC must develop an evaluation plan to identify:

• Why the evaluation is being undertaken?
• What will be evaluated?
• What information/data will be collected and how will it be securely stored?
• Who will lead the evaluation?
• Which stakeholders will be involved?
• What will be the evaluation approach/method?
• When the evaluation will be commenced and completed?
• What resources are required?

The Executive Director ECS&P must approve the evaluation plan. The evaluation approach must be considered in the grant program design phase to ensure sufficient and appropriate information is available to support the evaluation.

ECS&P must enact an evaluation action plan in accordance with the department's GPRAC tool (department employees only) at this point with a view to improve exposure to risks in future grant rounds, by evaluating whether prior controls and actions were effective and whether any risks were omitted.

Refer to the Queensland Government Program Evaluation Guidelines for more information.

Conduct evaluation

Evaluators must be sufficiently skilled and independent from the grant program, and its recipients and beneficiaries to ensure impartiality and transparency. When conducting evaluations, consideration must be given to:

• EC performance and investment principles;
• management of risk factors;
• compliance with ethical standards (e.g. informed consent, confidentiality);
• embedding quality assurance processes (e.g. systematic, data-based inquiries);
• applying standards of evidence (e.g. quality, quantity, impact, utility);
• efficient management of documentation and data (collection, handling, privacy, accessibility); and
• ensuring flexibility to adapt or respond to emerging findings or needs.

Report findings and recommendations

An evaluation report must be produced to communicate key findings with the service provider, internal stakeholders and decision-makers, ensuring that the content, language and mode of communication is appropriate to address the expectations and information needs of the target audience. These factors must be determined in the evaluation planning phase. The decision-making body (ECLT) will consider evaluation outcomes and recommendations.  

Developing strategies for continuous improvement

The ECP&F Contract Management team will work with funded services to ensure they are meeting their contractual obligations and that the service delivery model is sustainable.

Discussions with funded services will have a compliance focus, informed by findings from the assessment and acquittal process.

At the end of each reporting period and when a grant program ceases, the ECP&F Contract Management team:

• will prepare an overview of contractual performance and provide this to ECLT and ECS&P to inform program review and improvement;
• conduct a review of internal controls and accountability mechanisms to determine if they operated as intended;
• conduct a review of performance measures to determine if they were adequate for monitoring and achieved the grant's intended outcomes; review the risk rating of services and update corrective action required to support at risk services; and
• prepare an overview of grant management activities to confirm compliance with agreed service level standards, and to identify any opportunities to improve the efficiency, effectiveness and economy of grant administration practices.

Before the end of each financial year:

• ECP&F will conduct a self-assessment against Queensland Audit Office's Grant Management Maturity Model to assess and identify areas for improvement in grants management processes against five components of the grants management life-cycle. These include: establishing a grant program; applying for a grant program; approving grants and making payments; acquitting how grants are spent; and monitoring and evaluating grant program performance.

Definitions

Legislation

• Financial Accountability Act 2009 (Qld)
• Financial and Performance Management Standard 2024
• Education (General Provisions) Act 2006 (Qld) 
• Community Services Act 2007 (Qld) 
• Public Sector Ethics Act 1994 (Qld) 
• Human Rights Act 2019(Qld) 
• Information Privacy Act 2009(Qld)
• Right to Information Act 2009(Qld)

Delegations/Authorisations

• Minister's Funding Declaration (No.1) 2018 under Community Services Act 2007 (Qld) 
• Delegation of Director-General’s powers under Community Services Act 2007 (Qld)
• Delegation of Director-General’s powers under Education (General Provisions) Regulation 2017
• Delegation of Director-General’s powers as Accountable Officer under Financial Accountability Act 2009 (Qld)
• Financial Delegations

Other resources

• Code of conduct 
• Complaints and grievances management policy 
• Conflict of interest procedure 
• Customer complaints management framework 
• Customer complaints management procedure
• Decision-making framework 
• Early childhood grants management framework 
• Early Years Services Funding Category Resources 
• Enterprise risk management framework 
• Enterprise risk management policy 
• Enterprise risk management procedure 
• Financial internal controls policy 
• Governance framework 
• National Principles for Child Safe Organisations 
• Queensland Audit Office Grant management maturity model 
• Queensland Government Program Evaluation Guidelines 
• Queensland Kindergarten Funding: Funding category guidelines 
• Queensland Kindergarten Funding Scheme: Funding requirements essentials  
• Queensland Treasury Financial accountability handbook 2024, Volume 6 - Grant management 

Superseded versions

Previous seven years shown. Minor version updates not included.

Early childhood grants management procedure v1.0