Policy Implementation

To deliver services and programmes successfully, risks and implementation issues must be considered during policy design. Effective implementation requires a structured approach to thinking about how the policy will be delivered.

A policy which is embraced by a Minister, approved by Cabinet, announced publicly, but inadequately delivered, is worse than no policy at all.” Dr Peter Shergold AC

Implementation planning should be done early for all new policies or programmes to ensure the risks and challenges have been well considered. Implementation planning does not stop once the Cabinet has agreed to the proposal. Plans should be updated as the proposal is implemented to make sure it is kept up to date.

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Cabinet requirements

While implementation plans should be developed for all proposals, the level of information included in Cabinet submissions will vary.

Implementation information required by the Cabinet

For proposals with significant implementation risks or challenges, the Cabinet requires a well‑documented implementation plan to help them make an informed decision. In these cases, the full implementation plan should be provided to PM&C during the drafting process, with a summary of the plan being attached to the final Cabinet Submission.

Proposals that don’t have significant implementation risks or challenges do not require a summary of the plan to be attached to the Cabinet Submission. However, in these cases, the submission will still require information on:

• how and when the proposal will be implemented, including key milestones
• who will be responsible for delivering it
• who will be the key decision maker if it goes off track
• details of key risks and mitigation strategies.

When to provide an implementation plan with a Submission to the Cabinet

As a guide, the Cabinet is likely to require an implementation plan for higher risk proposals, which could be assessed as when the proposal meets one or more of the following:

• addresses a top priority of the Government
• has significant budget implications
• makes major or complex changes to existing programmes or policies
• involves significant cross-agency or cross-jurisdictional issues
• is particularly sensitive, e.g. has a large number of conflicting stakeholders, is particularly risky or impacts on a significant number of people or vulnerable cohort
• requires urgent implementation
• involves new or complex delivery systems
• has been developed over a very short period.

The Cabinet requires an implementation plan for any new policy proposals with a Risk Potential Assessment Tool pre-mitigation rating of medium or higher.

Information to be provided to the Cabinet for higher risk proposals

The Cabinet requires a summary of the implementation plan to be attached to the final Cabinet Submission. The summary should be no longer than five pages and should:

• normally take the form of a separate attachment to the submission or new policy proposal
• be clear and easy to read
• only include information on the principles that are critical to the successful delivery of the particular proposal.

The full implementation plan should be provided to PM&C during the drafting process.

Information to be provided to the Cabinet for lower risk proposals

At a minimum, submissions that don’t have significant implementation risks or challenges should identify:

• how and when the proposal will be implemented, including key milestones
• who will be responsible for delivering it
• who will be the decision maker if it goes off track
• details of key risks and mitigation strategies.

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Implementation principles

Considering the risks and implementation issues when the policy is being developed is likely to result in improved outcomes. The seven principles below provide a structured approach to thinking about how the policy or programme will be delivered. These principles draw on lessons learned by frontline APS staff involved in implementation and delivery.

We recommend that you consider and document the questions under each of these principles for all proposals, including those where the Cabinet don’t require a full implementation plan:

1. Planning
2. Governance
3. Engaging stakeholders
4. Risks
5. Monitoring, review and evaluation
6. Resource management
7. Management strategy.

The seven principles are explained below. 

1. Planning

• What does success look like?
• Are the scope, objective and end goal of the policy or programme clear?
• Is there a clear path to the end goal?
  • Are the timeframes clear and achievable or overly ambitious?
  • What are the steps and milestones required to achieve the end goal?
  • What are the key dependencies (e.g. passage of legislation, other related programmes, or another jurisdiction agreeing to something)?

See: Toolkit on implementation planning - PDF 495 KB | RTF 318 KB

2. Governance

• Is it clear who is responsible for implementing different parts of the initiative?
  • For example, the Minister may be responsible for seeking agreement from the Cabinet and the Senior Responsible Officer may be responsible for the day to day management of the initiative.
• Will the initiative be overseen by a committee? If so, what decisions will the committee need to make?
• Is there a clear process for escalating issues to the decision maker?

See: Toolkit on Governance - PDF 599 KB | RTF 5.75 MB

3. Engaging stakeholders

• Have the stakeholders and their concerns been identified?
• Is there a plan to manage competing stakeholder interests?
• How will the stakeholders be involved during the implementation planning process?

See also: Toolkit on engaging stakeholders - 610 KB PDF | RTF 5.2 MB

4. Risk

• Has a thorough risk assessment been done?
• Are there strategies to minimise the likelihood of these risks occurring?
• Who is responsible for managing these risks?
• What processes are in place for managing any risks that are realised during delivery?
• How will the risks be reviewed as the initiative progresses?

See: Toolkit on managing risk - 507 KB PDF | RTF 289 KB

5. Monitoring, review and evaluation

• Is there a benchmark against which to measure the progress of the initiative?
• How will the initiative be monitored and evaluated to ensure it is meeting objectives?
• What action will be taken if the original goals are not being reached?

See: Toolkit on monitoring, review and evaluation - PDF 515 KB | RTF 326 KB

6. Resource management

• How will funding be allocated across the initiative?
• Are there non-financial resources (such as staff, facilities and other infrastructure) that are needed to successfully deliver the project?
• Where multiple agencies are required to provide resources to implement the initiative, has this been agreed with all parties?

See: Toolkit on resource management - PDF 616 KB | RTF 886 KB

7. Management strategy

• What project management expertise is needed?
• Does your agency currently have the project management capacity to deliver the initiative, or is additional assistance necessary?
• Can any support be provided by other agencies?

See: Toolkit on management strategy - PDF 595 KB PDF | RTF 1.4 MB

For help with drafting implementation plans, read the Guide to Implementation Planning DOCX 867KB | PDF 895 KB

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Questions and answers

Is there an implementation plan template?

No, there is not a mandated template for implementation plans, as the information will vary from proposal to proposal.

Does Cabinet always need to see details of how the proposal will be implemented?

Yes, the Cabinet always needs some details on how the proposal will be implemented. The higher the risks or greater the implementation challenges, the more information the Cabinet requires.

For proposals with significant implementation risks or challenges or that have an Risk Potential Assessment Tool (RPAT) rating of medium or higher, the Cabinet requires a detailed summary of the implementation plan.

For proposals that have fewer risks or are not as complex, the following information should be included in the implementation statement in the submission:

• how and when the proposal will be implemented, including key milestones
• who will be responsible for delivering it
• who will be the decision maker if it goes off track
• details of key risks and mitigation strategies.

When does a proposal have significant implementation risks or challenges?

As a guide, proposals are likely to have significant implementation risks or challenges when they meet one or more of the following:

• addresses a top priority of the Government
• has significant budget implications
• makes major or complex changes
• involves significant cross-agency or cross-jurisdictional issues
• is particularly sensitive; e.g. has a large number of conflicting stakeholders, is particularly risky or impacts a significant number of people or a vulnerable cohort
• requires urgent implementation
• involves new or complex delivery systems.

If a proposal fits into one of these categories, the requirements should be discussed with PM&C.

What is a Risk Potential Assessment Tool?

The Risk Potential Assessment Tool (RPAT) is a tool developed by the Department of Finance. The RPAT assists agencies to determine and communicate the potential risk of a new policy proposal to Ministers when seeking the Cabinet’s agreement. The risk rating of a proposal also informs the requirements for additional assurance processes.

More information on the Risk Potential Assessment Tool is available on the Department of Finance website or by contacting the Assurance Reviews Branch in the Department of Finance at assurancereviews@finance.gov.au.

Who decides if Cabinet needs to see the implementation plan?

This will be a joint decision between the agency responsible for drafting the submission and PM&C.

What advice will PM&C provide?

PM&C can provide advice on:

• the Cabinet Submission process
• the level of detail in the submission
• which of the principles of implementation the Cabinet requires information on.

PM&C will also provide detailed feedback on the information in the full information plan.

It is important to engage with PM&C early to provide enough time to ensure the details in the implementation plan are covered.

What happens if the Cabinet submission has insufficient information on implementation?

If PM&C thinks there is insufficient information in the exposure draft stage, we will provide you with advice on what additional information would strengthen the submission.

If a submission has insufficient implementation information at the coordination draft stage:

• PM&C may make a coordination comment noting the lack of information and advise the Prime Minister accordingly
• PM&C may recommend to the Cabinet Secretary that the submission not be considered by the Cabinet. If this occurs, the Cabinet Secretary must give written authority to allow the submission to proceed to Cabinet
• The Cabinet may require an implementation plan to be developed in consultation with PM&C following the Cabinet decision.

It is recommended to contact PM&C early in the process to ensure the submission adequately addresses the implementation arrangements.

Once the Cabinet has made a decision on the basis of an implementation plan, can the implementation plan be changed?

Yes. It is expected that an implementation plan will evolve as the project progresses and more detailed planning takes place.

The implementation plan that is submitted with the Cabinet submission is a living document and it is not intended to stop agencies from adapting during implementation. However, any significant changes to the policy or delivery approach require approval from the Prime Minister or the Cabinet.

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Government programmes community of practice forum

The Department of Infrastructure and Regional Development runs a Government Programmes Community of Practice Forum (GPCoPF) targeted at APS officers engaged in programme delivery activities, particularly the EL1 to SES Band 1 levels.

The GPCoPF is an informal knowledge sharing round-table which promotes better practice approaches to delivering Australian Government funded programmes and shares tool and lessons learned amongst peers across the APS. Membership is open to anyone in the APS who is involved in programme delivery.

Email: copforum@infrastructure.gov.au.