The Federal Department of Health has committed to implementing recommendations from an Australian National Audit Office (ANAO) investigation of the Medical Research Future Fund’s grants and governance.
However, many questions about the MRFF’s operations remain unaddressed, writes Associate Professor Lesley Russell, in an ongoing series on the MRFF.
Lesley Russell writes:
Within days of the recent publication by Croakey Health Media of my analysis of the funding and research priorities of the Medical Research Future Fund – see part 1 and part 2 – the Australian National Audit Office (ANAO) released its audit report on the Department of Health’s management of financial assistance under the MRFF.
The audit found that the Department of Health (DoH) management of the MRFF is largely effective and largely compliant with legislative and policy requirements.
But DoH does not have adequate performance measures for MRFF and has not effectively measured and reported on the performance of MRFF research funding.
Most notably, the ANAO states that there is no evidence of how the design of the MRFF 10-Year Plan was influenced by the MRFF Strategy and the MRFF Priorities.
The Auditor-General made three recommendations to DoH:
- To identify, assess and manage risks at the theme or initiative level of the 10-year Plan;
- To report grants in the way they are classified in the relevant grant opportunity guidelines; and
- To improve MRFF performance measures and reporting.
My reading of the audit report identifies further problems – arguably more serious – that relate to the management, expert guidance and oversight of the MRFF. It is not clear why these were not highlighted by the ANAO, perhaps because they fell outside the scope of the audit.
As I have previously written, there is an urgent need for greater transparency around the operations and expenditures of the MRFF.
These further problems, discussed below, only add to that urgency.
Australian Medical Research Advisory Board is not currently functioning
The Australian Medical Research Advisory Board (AMRAB) was originally constituted with eight members – seven (including the chair) who were Ministerial appointments, plus the CEO of the National Health and Medical Research Council (NHMRC).
Last year one board member resigned and in February 2021 the appointments of the six remaining appointed members expired. None of this is mentioned on the MRFF website, which has not been updated since November 2020.
Although the Minister for Health, Greg Hunt, was advised of the expiring terms in November 2020, new members were announced only on 17 September, and AMRAB has not met since October 2020.
This means that a central aspect of AMRAB’s work – development of the MRFF Strategy for 2021-26 – has yet to commence.
The ANAO report highlights some further issues that are disturbing and go to lack of transparency and consultation.
- Changes to AMRAB’s Terms of Reference (ToR) were approved in November 2020 but the ToR are not publicly available.
- The updated ToR apparently include matters on which AMRAB will be asked to provide advice to the Minister. Given the exigencies of the coronavirus pandemic, climate change, health inequalities and vaccine development, there is a raft of health and medical issues for which advice might be sought – but of course there is no-one to provide it. The Minister has apparently never sought AMRAB advice, although this is provided for under the MRFF Act.
- As I noted in my earlier analysis of the MRFF, only two communiques from AMRAB meetings are publicly available (the meetings attended by the Minister). Draft communiques for other meetings were prepared but not finalised or published.
- The collective experience of AMRAB’s previous members was rated low by the ANAO when it came to both consumer issues relating to health and management or delivery of health services.
The extent to which the Minister followed the advice and guidance of AMRAB in making research funding decisions was not part of this audit but is relevant to the effective management of the MRFF.
The ANAO did find that DoH has not consistently advised the Minister of the MRFF Priorities that the proposed grant opportunities would address.
Department of Health role, and what this means for transparency
The DoH role, as described by the ANAO, is “to support the Health Minister and AMRAB in the implementation of the MRFF Act and to effectively administer MRFF grants”.
A Health and Medical Research Office (HMRO) was established in the 2019–20 Budget, with a departmental budget of $5 million a year from 2019–20 to 2022–23, to manage financial assistance under MRFF. The HMRO sits within Health Economics and Research, a section of Strategic Evidence and Research Division in DoH.
Following an internal audit (not publicly available), in October 2019 DoH established a Program Assurance Group (PAG) to provide internal oversight of its management of the MTFF program. Having done this, DoH then closed all of the audit recommendations; the ANAO says “analysis of this audit does not support closure of some of the recommendations”.
The PAG chair is the First Assistant Secretary, Health Economics and Research, and the deputy chair is the head of HMRO. There are nine other members (presumably DoH staff, it’s not clear if they also have other work responsibilities), including an executive from Cancer Australia.
PAG’s terms of reference state that its role “is to provide assurance to MRFF implementation and to assist with the continuous improvement of assurance mechanisms, risk management practices and program assurance more broadly as a result of lessons learnt and to increase consistency across MRFF initiatives”. (All of this information is from the ANAO report – as far as I can determine, none of it is publicly available).
It is a reasonable assumption that one reason why the MRFF 10-Year Plan is so divorced from the MRFF Strategy and Priorities is because it was generated in-house by the PAG, with no input from the AMRAB (and increased opportunities for political interference).
Given that the MRFF annually handles research funding of the same order of magnitude as the NHMRC, there are stark disparities in management approaches and resources between the two organisations.
The NHMRC is an independent government agency. For 2020-21, it had an operating budget of some $56.5 million and 185 staff. Its work is reported annually in some detail in the DoH Portfolio Budget Statements.
The MRFF program is run in-house by DoH and it’s not possible to know what funding and staffing resources are provided for its management (that includes AMRAB, HMRO, PAG, other DoH activities such as coordination of consultations, and the work done by implementation partners NHMRC, the Department of Industry, Science, Energy and Resources’ Business Grants Hub and Cancer Australia).
The Finance Department Portfolio Budget Statements provide annual management costs for the MRFF ($58.6 million in 2020-21) (see Table 1 in Part 1 of my MRFF analysis). There is no breakdown of these management costs, which potentially include not just DoH costs but also Future Fund management fees.
The ANAO found that, overall, the PAG “provides a suitable forum for coordination of MRFF responsibilities within DoH and oversight of the program”.
It was noted that PAG meeting outcomes should be reported to the relevant DoH deputy secretary at least quarterly but so far only two such reports have been provided. It was also recommended that information about the MRFF program be included in the Portfolio Budget Statements.
The recently re-appointed chair of AMRAB (Professor Ian Frazer) advised the ANAO that he considered that “there is a need for MRFF to be supported by an organisation with a similar structure and capacity to that of NHMRC and expert advisory committees, and a business team that would manage potential overlaps between MRFF, NHMRC and Industry”.
I would argue that should be seen as an imperative.
Lack of consultation and coordination
The ANAO audit found that DoH has “effectively supported” consultations by AMRAB and the expert advisory panels associated with the Research Missions and that stakeholder views have been considered in developing the MRFF Strategy and Priorities and the roadmaps for the Research Missions.
It would be valuable to know if that was the opinion of those consulted and if there were key stakeholder groups which were not consulted.
The ANAO highlights one major omission in these consultations, finding that DoH and AMRAB have not consulted with state and territory governments. They are key stakeholders in the implementation and delivery of the MRFF program and its outcomes; they are eligible for research funding and indeed several such grants have been made.
Obviously, a key partner for consultation and cooperation with the MRFF is the NHMRC as there is considerable overlap in their funding of health and medical research, to the extent that both organisations are often funding the same researchers on similar research topics.
The DoH has a Memorandum of Understanding (MoU) with NHMRC around its role as a grant hub, but the MoU is silent on coordination arrangements. The recently released Corporate Plan that covers the next four years of operation of the NHMRC barely mentions the MRFF (see Appendix for more information).
ANAO states that coordination might include analysis of the outcomes of NHMRC research and the implications for MRFF research priorities (and, I would add, vice versa).
As I have previously written, there is a huge need for more research in areas such as primary care, public health and health services delivery, yet these areas are neglected by both NHMRC and MRFF.
A recent article in Croakey Health Media from Dr Arnagretta Hunter expands on this issue and calls for a radical rethink and restructure to deliver on the opportunities presented by the MRFF.
Grant opportunities not necessarily chosen on basis of MRFF priorities
An examination of the grants funded shows that these often do not map clearly against MRFF Priorities and Initiatives (see my MRFF analysis, Part 1).
It seems that this is because the grant opportunities are selected by DoH (the ANAO report does not make clear if this means PAG). There does not appear to be any involvement by AMRAB.
DoH advised ANAO that the factors which influence the objectives and scope of grant opportunities include:
- Advice from relevant experts within Health, such as the Pharmaceutical Benefits Advisory Committee and the Medical Services Advisory Committee;
- The outcomes of Senate inquiries; and
- For Research Missions, the advice of the expert advisory panels and committees. Six of the eight expert advisory panels have developed proposed roadmaps, which identify priority areas for investment and implementation plans for each mission.
There is no published explanation from DoH of how grant opportunities are identified or a list of priorities for future research and innovation, particularly for non-mission initiatives. There is also no published timetable for grant opportunities.
One of the MRFF funding principles is that disbursements from MRFF will reference the MRFF Strategy and related Priorities. This has not been done routinely; between mid-2019 and early 2021 the ANAO found that DoH advice to the Minister only indicated the relevant policy approval (generally the 10-year Plan) for the opportunity and did not indicate the strategic platforms in the MRFF Strategy and relevant MRFF Priorities.
Nineteen of the 33 submissions received by the ANAO in relation to this audit considered that it is unclear how grant opportunities are selected, and seven submissions said that this gave rise to perceptions of bias.
I would add that it also gives rise to the perception of Ministerial interference: the $3 million provided last year for research into hydroxychloroquine is a case in point.
Other issues of concern
Several other issues are outlined in the ANAO audit as needing attention, as briefly summarised below.
Targeted grant opportunities: As at 30 June 2021, only 64 percent of all grant opportunities (as distinct from grants) since the inception of the MRFF program have been competitive. The remaining have been targeted.
Grants are targeted when it is the assessment of DoH (Note: not clear where or who in DoH) that, “the organisation(s) to be approached for the grant opportunity are the only one(s) with the necessary skills and expertise to undertake the work or when research funding is required to support an urgent public need, such as COVID-19.”
DoH told ANAO it is aware, and has advised the Minister, that targeted grant opportunities may give rise to criticism by the research sector about a lack of contestability, and that the process lacks transparency and favours some organisations.
Timelines for grant submissions: Inadequate timeframes are allowed for the submission of grant applications, especially when these come at the end of the year.
Performance measures: The ANAO found that DoH does not have adequate performance measures for the MRFF and has not effectively measured and reported on the outcomes of MRFF funding.
A monitoring, evaluation and learning strategy was made public in November 2020, but there are no reports under this as yet.
ANAO considers that the impact measures and measures of success for this strategy are high-level and the strategy does not detail what data will be collected to measure performance against these.
The succinct point is made that the development of the monitoring, evaluation and learning strategy and a plan to implement the strategy should have been done at the commencement of the program, and not five years after it started.
Conflicts of interest: Conflicts of interest registers for MRFF advisory groups have not been consistently updated, nor have they been made public to ensure transparency.
Risk management: The audit found that the PAG does not systematically identify, assess and manage risks at the initiative or theme level and called for improvements in the identification of risks and documentation of their management.
Communications strategy: The ANAO notes that AMRAB agreed to a communications strategy and budget in February 2019 and that in March 2020, DoH adopted a communications plan. It’s not clear that either of these has been meaningfully implemented.
The MRFF website – which is not particularly attractive or user-friendly – includes 20 “snapshots” (fact sheets) relating to initiatives funded by the MRFF. These have not been updated since November 2020.
Meanwhile, at the NHMRC…
The NHMRC has just released its four-year corporate plan. Its 27 pages of detail for the next four years are in stark contrast to the three-page document that is the ten-year plan for the MRFF, and both entities manage similar levels of funding.
The information provided around risk management and performance measures are presumably what the ANAO was expecting from the MRFF audit.
Many of the NHMRC priorities overlap with those of the MRFF. These include dementia research, mental health, Aboriginal and Torres Strait Islander health, emerging health threats such as anti-microbial resistance, preventing and managing chronic conditions and emerging technologies in health.
Additionally, the NHMRC is involved in research translation, specifically through the Partnership Centres that help implement findings into policy and practice.
The role of the MRFF is barely mentioned in this document. The impact of the research it funds is seen as a factor affecting the NHMRC’s activities and performance and there is mention of the role the NHMRC has in peer review and grants management for the MRFF.
The AMRAB could not have been involved in the development of this document, although it is likely the DoH PAG was involved.
See previous articles in the #MRFFtransparency series.
See Croakey’s archive of stories about research.
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