The Public Spending Code:
C. Implementation and Post-Implementation
The implementation stage of a project begins once final approval for the award of a contract has been secured. Capital Grant Schemes or Current Expenditure programmes enter this stage once final approval is secured. The critical tasks at this stage are management and monitoring to ensure that what is planned is executed satisfactorily, within budget, to standard and on time.
Implementation is the responsibility of the Sponsoring Agency while the Sanctioning Authority must be satisfied that the Sponsoring Agency delivers what has been approved. Where the Government is the sanctioning authority, the responsibility for ensuring delivery – for the management and monitoring functions in the implementation stage will rest with the relevant line Department (the Department which presented the proposal to Government).
The Sanctioning Authority should satisfy itself that the Sponsoring Agency has systems in place and system checks in place to ensure that the project is delivered as per the contract, approved project specification and within the approved budget and in compliance with these guidelines.
Actions or responsibilities at the Implementation Stage can vary depending on whether you are responsible for:
- a large capital project i.e. > €20m
- a capital project of a smaller scale
- a programme of capital expenditure
- a capital grant scheme
- an area of current expenditure
a) assigned responsibility for delivery
b) an appropriate structure to monitor and manage the implementation phase
c) regular reporting
d) a means of measuring if the project, programme, capital grant scheme or current expenditure intervention is delivering on its expectations
This document sets out a combination of specific requirements and some high-level pointers for the Implementation Phase. It does not aim to be prescriptive about every situation as the nature of what is being implemented; the scale of expenditure and the period of implementation all have a bearing on what is appropriate. Sponsoring Agencies responsible for implementation together with the Sanctioning Authority must decide on the best approach for each individual situation taking account of the guidance in this document.
Note: The monitoring, management, evaluation or review of discrete areas of expenditure should incorporate the relevant administrative expenditure associated.
(a) Assigned Responsibility for Delivery
For capital projects a Project Manager should be appointed within the sponsoring Department or Agency at the planning/procurement stage of the project. The person appointed to the role should be a senior official including an official at MAC level or equivalent where appropriate. The project manager should be assigned personal responsibility for monitoring progress on the project against the contract requirements and for reporting progress and issues arising to the Project Board.
Similarly responsibility for capital programmes, capital grant schemes and current expenditure programmes should be assigned within Departments and Agencies.
(b) Appropriate Structure for monitoring and management
All expenditure, whether capital or current, has to be actively managed. This will involve monitoring against plans and expectations, monitoring and assessing changes in the broader environment that may impact on the underlying need and making decisions on adjustments or even termination.
Capital projects will have a Project Board with appropriate expertise and authority. It will include the Project Manager and a representative of the sanctioning authority.
Capital Programmes, capital grant schemes and current expenditure programmes also need formal structured arrangements to ensure that there is systematic co-ordinated monitoring and management of programmes. Responsibility for putting these structures in place may primarily rest with the sanctioning authority or the sponsoring agency depending on the nature and scale of the expenditure. These structures may include a programme co-coordinator to coordinate implementation of the programme and a monitoring committee to monitor and review progress. Where the programme is a cross-cutting programme the monitoring committee will be representative of relevant Government Departments, implementing public bodies and sectoral interests.
(c) Regular Reporting
Monitoring of all types of expenditure is required to ensure that milestones are being met and expenditure is within budget. Regular reports should be submitted to the Project Board or other structure as discussed above. If adverse developments occur such as potential cost overruns or delays the progress report should include recommendations to address the situation, including where warranted the option of project/scheme termination.
For projects costing over €20m a separate progress report for each project must be submitted to the Department’s MAC for Departmental projects and to Management and/or the Board for Agency projects and then to the relevant Minister on a quarterly basis. These reports may be subject to audit by the Department of Public Expenditure & Reform.
(d) A means of measuring if on target with expectations
For capital projects, milestones in the contract and in the project plan can be used by the Project Manager and Project Board to ensure that the project is on schedule and within budget. Other performance indicators may have to be developed for changes in the external environment that could influence the project.
For non-project expenditure performance indicators should be developed at the outset as well as a means of gathering the data to support performance indicator measurement. These performance indicators will then be used as part of the monitoring and management of the Implementation Stage for capital programmes, capital grant schemes and current expenditure programmes. There may be schemes or programmes underway that do not have suitable performance indicators. If this is so then suitable performance indicators should be developed as soon as possible.
Adverse Developments or Changes in Circumstances
Regular management reports should be prepared by the Sponsoring Agency covering all significant developments relating to the project and its costs. If adverse developments occur, including unforeseen cost increases, which call into question the desirability or viability of the project, the Sponsoring Agency should submit a report at the earliest possible moment to the Sanctioning Authority, detailing the necessary measures proposed to rectify the situation.
Where, despite these measures, increased costs above those already approved are likely to arise, the approval of the Sanctioning Authority for the extra expenditure should be obtained before any commitment is made to accept cost increases. Any application for such approval should outline the reasons for the excess, along with a detailed explanation of why it was not possible to take appropriate measures to offset the increased cost. The viability of the project, given the changed circumstances, should also be reported on.
If a project is going badly wrong, there should be a willingness to terminate it before completion. Action of this kind can be justified if the cost of the project escalates above earlier estimates or if the benefits expected from it are not likely to be realised. An attitude that, once work on a project commences, it must be completed regardless of changed circumstances, is to be avoided. Before making a final decision to terminate a project that is not going according to plan, the costs of termination (for example, payments that might have to be paid by way of compensation to contractors etc.) should be ascertained and made known to the appropriate authorities.
The main requirement post-implementation is one of review. This is discussed in Document C-03 Periodic Evaluation/Post Project Review.
Figure 5 reviews the Implementation Stage.