Clarify your Role
Most parts of the Public Spending Code but in particular Public Spending Code B.03 – Approvals Required and Scale of Appraisal make references to the Sponsoring Agency and the Sanctioning Authority. This document outlines the different roles that organisations play in the life-cycle of a project.
The Sponsoring Agency has the overall responsibility for the proper appraisal, planning and management of projects/schemes (incl. current expenditure). Sponsoring Agencies are also responsible for post-project review. (The Sponsoring Agency may be a Government Department, local authority, health agency, University or other State body.)
The Sponsoring Agency must obtain the necessary approvals from the Sanctioning Authority and ensure that the project/scheme proceeds along the lines approved by the Sanctioning Authority. All capital projects being sponsored by a State company must be specifically approved by the Board of the company or, by management in accordance with any delegated authority from the Board, before its submission to the Sanctioning Authority. If a subsidiary company or agency is set up specially to undertake a project, it is important that the responsibilities of the parent body are not diluted.
Where the Office of Public Works (OPW) is undertaking a project in response to a request from a Government Department/Office it is the responsibility of the relevant Government Department/Office to complete the project appraisal and to secure the approval of the Sanctioning Authority before involving the OPW in the planning and implementation stages. In the case of a PPP project, the Sponsoring Agency is the public body or agency sponsoring the project, subject to subsequent assignment of responsibilities under PPP contractual arrangements.
The Sanctioning Authority is responsible for granting the approvals required as projects/schemes, funded with public assistance, proceed through the project/expenditure life cycle. The approvals required include the approval in principle following detailed appraisal and pre-tender approval. If there is not procurement there should still be an approval checkpoint at the equivalent stage i.e. when the quantity of internal resources required is known.
The Sanctioning Authority may also set conditions under which a project may proceed. It is also responsible for paying the public assistance to the Sponsoring Agency and for ensuring the project’s delivery as approved. While implementation is the responsibility of the Sponsoring Agency the Sanctioning Authority must be satisfied that that the Sponsoring Agency delivers the project/scheme as approved.
The Sanctioning Authority is normally the Government Minister or Department or public body with sectoral responsibility for implementing Government policy and for providing public financial assistance in that sector. In the case of major projects the sanctioning authority may be the Government. As a rule the Government will be the Sanctioning Authority for very large projects, costing more than €100m, but the Government could also be the Sanctioning Authority for projects below this value. Where the Government is the Sanctioning Authority, the day to day oversight functions of a Sanctioning Authority revert to the line Department. The Government is involved at the major decision points. The Sanctioning Authority should take the necessary steps to ensure that it has the requisite expertise to assess project appraisal proposals from Sponsoring Agencies.
Each Sanctioning Authority is responsible for drawing up its own procedures applicable to its area of control. These procedures should comply with the principles set out in the Public Spending Code. Each Sanctioning Authority should also ensure that bodies under its aegis follow the procedures laid down by it. If there is an intermediary body (e.g. the Higher Education Authority) between the Sanctioning Authority and the Sponsoring Agency it is the responsibility of the Sanctioning Authority to define clearly the roles and responsibilities of any such intermediary bodies in regard to programme/project appraisal and management consistent with these guidelines.
In some instances the Sponsoring Agency and the Sanctioning authority, in relation to individual projects, may be the same body e.g. the National Roads Authority, non-Exchequer funded commercial State Companies. All such projects will, however, be part of a multi-annual programme or business plan which will have been appraised by a parent Department and/or Board of the company. Individual projects will still have to be appraised and approved in accordance with these guidelines with internal approval processes substituting for an external sanctioning authority.
The source of finance for a project is a good guide to the role played. The provider of the finance is usually the sanctioning authority and the organisation making the payments or incurring the expense is usually the sponsoring agency. If the finance has been received with delegated sanction that allows the funded organisation to make decisions up to a certain limit under certain conditions then the sanctioning authority and sponsoring agency may be the one body. Any organisation whether a sponsoring agency or sanctioning authority has to ensure that the necessary arrangements have been made for the financing of a project before any commitment is entered into.
Proposals made by bodies other than those responsible for their implementation. Proposals may be initiated by bodies other than those which will be responsible for them. Submissions and research documentation coming from such sources may provide some of the information required for a preliminary appraisal. However, the Sponsoring Agency must satisfy itself that such information is accurate and objective.