The Government Advertising Act 2011 (the Act) sets out requirements that must be followed by a government agency when it carries out a government advertising campaign. The requirements prohibit political advertising and require a peer review and cost–benefit analysis (CBA) to be completed before the campaign commences. The accompanying Government Advertising Regulation 2018 (the Regulation) and the 2012 NSW Government Advertising Guidelines (the Guidelines) provide additional requirements.

Section 14 of the Act requires the Auditor-General to conduct a performance audit of the activities of one or more government agencies in relation to government advertising campaigns in each financial year. The performance audit must assess whether a government agency (or agencies) has carried out activities in relation to government advertising campaigns in an effective, economical and efficient manner and in compliance with the Act, the Regulation, other laws and the Guidelines.

This audit examined whether activities relating to Cancer Institute NSW’s (the Cancer Institute) anti-tobacco and vaping control campaigns were carried out effectively, economically and efficiently, and in compliance with the Act, the Regulation, other laws and the Guidelines.

The anti-tobacco campaign and sub-campaigns included in the scope of the audit were the 2023–24 ‘Beat the Cravings’, ’16 Cancers’, ‘New Year, New You’ and a tactical sub-campaign focused on pregnant women. The campaign and sub-campaigns targeted NSW smokers over the age of 18 to highlight the cancer risk of smoking and aimed to make them feel that quitting is achievable and use the available support services to quit smoking. The Cancer Institute spent $4.1 million in 2023–24 to deliver the campaign.

The audit also examined the 2023–24 phase of the vaping control campaign referred to as ‘Every Vape is a Hit to Your Health’. This campaign was targeted at young people aged 14–24 with the objective of quitting vaping and to prevent non-users taking up vaping in the future. The Cancer Institute spent $2.9 million in 2023–24 to deliver this campaign.

The Cancer Institute’s anti-tobacco and vaping control campaigns complied with the requirements of the Government Advertising Act 2011, the Government Advertising Regulation 2018 and largely complied with the Government Advertising Guidelines, including the requirement that the campaign not contain political advertising.

Both campaigns targeted their audiences appropriately, and the evaluation indicates that the vaping control campaign was effective in reducing the uptake of vaping among young people in NSW. The anti-tobacco campaign did not meet two of its key outcome targets, but these were set prior to a reduction in the campaign’s budget and so it is not clear whether the campaign was undertaken effectively.

Both campaigns were undertaken economically. The Cancer Institute directly negotiated with a provider to develop the creative materials for its vaping control campaign without a competitive procurement process, which increased the risk that value for money would not be achieved. However, the Cancer Institute took steps to ensure that value for money was still achieved. The CBAs demonstrated that the campaigns represented value for money.

The Act required the Cancer Institute to submit both campaigns for peer review, to undertake a CBA, and for the head of the agency to issue a compliance certificate for the campaign. All of these requirements were met.

Government advertising is advertising funded by or on behalf of a government agency and disseminated under a commercial advertising distribution agreement through a variety of media, such as radio, television, the internet, newspapers, billboards or cinemas.

Government advertising campaigns in NSW may be used for the following objectives:

• encouraging changed behaviours or attitudes that will lead to improved public health and safety or quality or life
• maximising public and commercial compliance with laws and regulations
• encouraging use of government products and services
• encouraging public involvement in government decision-making
• raising awareness of a planned or impending initiative and reporting on performance in relation to NSW Government undertakings
• assisting in the preservation of order in the event of a crisis or emergency and
• recruiting staff, disseminating important statutory information and promoting business opportunities with the NSW Government.

Under section 14 of the Act, the Auditor-General must conduct a performance audit of the activities of one or more Government agencies in relation to Government advertising campaigns of the agency in each financial year. This audit must consider the economy, efficiency, and effectiveness of the chosen advertising campaign(s), as well as whether it is in compliance with the Act, the regulations, other laws, and the Government advertising guidelines.

The NSW Government spent $80.1 million on media expenditure for advertising in 2023–24. The overall media expenditure across previous financial years is provided in Exhibit 1. Other costs for advertising, such as production, are not included.

There is a regulatory framework that includes both policy guidance and legislation governing NSW Government advertising. Table 1 contains an overview of this regulatory framework.

Source: Audit Office of NSW analysis of government advertising legislation and supporting documentation.

The Department of Customer Service (DCS) is responsible for administering the Act. Compliance with the regulatory framework is certified by the head of the agency conducting the advertising campaign.

Section 6 of the Act prohibits political advertising as part of a government advertising campaign. According to this section, government advertising campaigns must not:

• be designed to influence (directly or indirectly) support for a political party
• contain the name, voice or image of a minister, a member of Parliament or a candidate nominated for election to Parliament
• contain the name, logo, slogan or any other reference to a political party.

In addition, the Guidelines require government advertising campaigns to be politically neutral and clearly distinguishable from party political messages.

_¹ The Government Advertising Regulation 2018 was replaced by the Government Advertising Regulation 2024, however the 2018 regulation was in place at the time of the campaigns subject to this audit.

The Act states that a government advertising campaign must not commence unless the head of the agency has signed a compliance certificate for the campaign. This compliance certificate states that the head of the agency believes the government advertising campaign:

• complies with the Act, the Regulation and the Guidelines
• contains accurate information
• is necessary to achieve a public purpose and is supported by analysis and research
• is an efficient and cost-effective means of achieving its public purpose.

The Act defines further requirements for campaigns which are likely to exceed a total cost of $250,000 or $1 million.

Table 2 summarises the key legislative and policy requirements that agencies must meet before commencing an advertising campaign.

Source: Government Advertising Act 2011 and Government Advertising Regulation 2018.

Government advertising campaigns likely to cost over $250,000 are subject to peer review before the campaign commences. Peer review involves DCS staff assessing the proposed advertising campaign against criteria outlined in the Guidelines. There are two stages of peer review:

• Budget approval – government agencies submit an advertising budget proposal to the DCS Campaign Effectiveness Team. The DCS Campaign Effectiveness Team reviews the budget proposal and makes recommendations to the Expenditure Review Committee (ERC) of Cabinet. The ERC is responsible for approving campaign budgets.
• Campaign review – the DCS Campaign Effectiveness Team assesses the need for the proposed advertising campaign, the creative and media strategy (including objectives and target audiences) and how the agency will manage the campaign. Specifically, the campaign review considers:
  • alignment with government priorities and commitments and the life of NSW customers, including the effectiveness of approaches among regional, Aboriginal and Culturally and Linguistically Diverse (CALD) customers
  • creative strategy and its effectiveness
  • media strategy
  • how the advertising integrates with other communication approaches
  • clarity and appropriateness of campaign objectives and proposed campaign evaluation approaches
  • likely effectiveness of the campaign based on previous campaign performances (if it is a repeat) and campaign research.

Peer reviews are an important step in a campaign as they provide independent assurance for the agency regarding the campaign's compliance with some legislative and policy obligations.

The Act also requires an agency proposing to run a government advertising campaign that is likely to cost over $1 million to complete a CBA before the campaign commences. A CBA aims to evaluate the net economic cost or benefit of the campaign and assess the options for achieving the same objectives, including the option of not advertising.

The Cancer Institute is established under the Cancer Institute (NSW) Act 2003 and is one of the pillar agencies of NSW Health. The Secretary of NSW Health is responsible under the Act for signing the advertising compliance certificates for NSW Health agencies. One of the objectives of the Cancer Institute is to reduce the incidence of cancer in the community. To fulfil this objective, the Cancer Institute regularly conducts advertising campaigns to achieve behavioural change that reduce exposure to significant carcinogens, including the smoking of tobacco and vaping. The Cancer Institute spent $7.5 million on media advertising in 2023–24, which was one of the highest agency expenditures across the NSW Government as a percentage of all money spent on government advertising.

The whole-of-government approach to reducing cancer, including tobacco-related cancer and the reduction of e-cigarette use, is coordinated through a series of plans. These plans consider different interventions across levels of government, government agencies and key partners. Relevant plans include the National Tobacco Strategy 2023–2030 (the National Tobacco Strategy), the NSW Tobacco Strategy 2012–2021 (the NSW Tobacco Strategy) and the NSW Cancer Plan.

The National Tobacco Strategy is a Commonwealth plan to reduce the prevalence of tobacco use and its impacts across Australia. The plan identifies priority areas and actions with responsibilities delineated between federal and state governments in addition to non-government organisations (NGOs). The National Tobacco Strategy focuses on further regulatory, commercial and workplace reform and also highlights a priority area to strengthen regulation on e-cigarettes.

The NSW Tobacco Strategy establishes the background for tobacco control in NSW, sets out the partnership approach and describes actions for government and key partners such as the healthcare system, social services, NGOs, Aboriginal organisations, industry groups and professional associations. The NSW Tobacco Strategy specifically designated the Cancer Institute as the lead agency responsible for the design, delivery and evaluation of anti-tobacco public education campaigns in NSW.

The NSW Cancer Plan outlines the vision for the Cancer Institute to ‘end cancers as we know them’. It proposes to do this by focusing on four priority areas: prevention; screening and early detection; optimal treatment, care and support; and cancer research. The prevention priority area includes a specific action to help people not take up smoking or vaping and to quit smoking and vaping. One of the primary methods of preventing take-up or encouraging quitting is through government advertising, as also outlined in the NSW Tobacco Strategy.

_¹ The Government Advertising Regulation 2018 was replaced by the Government Advertising Regulation 2024, however the 2018 regulation was in place at the time of the campaigns subject to this audit.

The anti-tobacco campaign was not designed to influence support for a political party and was for an allowable purpose under the Government Advertising Guidelines

Section 6 of the Act prohibits political advertising as part of a government advertising campaign. A government advertising campaign must not:

• be designed to influence (directly or indirectly) support for a political party
• contain the name, or give prominence to the voice or any image, of a Minister, member of Parliament or candidate nominated for election to Parliament
• contain the name, logo, slogan or any other reference to a political party.

The audit team reviewed campaign materials developed by the Cancer Institute for the tobacco control campaign. The audit found no breaches of section 6 of the Act.

Section 4 of the Act states that government advertising campaigns are for ‘the dissemination to members of the public of information about a government program, policy or initiative, or about any public health or safety or other matter’. To support this, the Guidelines list the objectives that a government advertising campaign may be used to achieved. One of these is to encourage changed behaviours or attitudes that will lead to improved public health. The anti-tobacco campaign was a public health campaign that aimed to encourage people to stop smoking and to feel that this was achievable. Thus, the anti-tobacco campaign was for an allowable purpose under the Guidelines.

The anti-tobacco campaign complied with the mandatory requirements of the Act

Agencies must comply with a range of requirements set out in the Act regarding CBA and peer review, and the issuing of a compliance certificate. The Cancer Institute complied with these requirements in undertaking the anti-tobacco campaign.

Any campaign valued at over $250,000 is required to go through the DCS peer review process before the campaign commences. The Cancer Institute completed phase one of the peer review process in March 2023 and received in-principle budget support. The Cancer Institute completed the second stage of peer review in August 2023, which was prior to the campaign launch.

An agency undertaking a campaign valued at over $1 million is required to complete a CBA before the campaign commences. The Cancer Institute completed a CBA for the anti-tobacco campaign in May 2023. This CBA was revised in February 2024 to account for a reduction in the campaign budget. The results of these CBAs are discussed below.

Before the campaign commences, the head of the agency is required to issue an advertising compliance certificate which states that, in the opinion of the head of the agency, the proposed campaign:

• complies with the Act, the Regulation and the Guidelines
• contains accurate information
• is necessary to achieve a public purpose and is supported by analysis and research
• is an efficient and cost-effective means of achieving that public purpose.

The head of the Cancer Institute is the Chief Executive Officer (CEO). However, for the purposes of the Act, the Secretary of NSW Health is considered the head of the agency and was therefore required to sign the compliance certificate. The CEO endorsed a brief to the Secretary which advised that they were satisfied that the campaign complied with the above information. The Secretary signed the compliance certificate in line with the requirements of the Act in October 2023. The brief that was sent to the Secretary contained supporting information for the above requirements to demonstrate that the compliance certificate could be signed.

The Cancer Institute ensured that the campaign presented all facts accurately, objectively and in a fair and accessible manner

Section 2 of the Guidelines states that all government advertising campaigns must adhere to the principles of:

• accuracy in the presentation of all facts, statistics, comparisons and other arguments; all facts and claims of fact included in government advertising campaigns must be able to be substantiated
• objective presentation in a fair and accessible manner.

The anti-tobacco campaign materials complied with these principles. The ‘16 Cancers’ campaign contained multiple claims about the dangers of smoking. The statements in the advertising could be substantiated. The ‘Beat the Cravings’ campaign was focused on directing people who smoke and want to quit towards support services, and provided details of these services.

² In this report, the term Aboriginal people is used to describe Aboriginal and Torres Strait Islander peoples. The Audit Office of NSW acknowledges the diversity of traditional Nations and Aboriginal language groups across the state of New South Wales.

The Cancer Institute conducted research to justify the anti-tobacco campaign need and approach

Section 8(2) of the Act and section 5.2 of the Guidelines require agencies to demonstrate that they have justified the need for the campaign through sound data, analysis and research.

The Cancer Institute justified the need and approach for the anti-tobacco campaign by summarising recent research on the relationship between smoking and the burden of tobacco-related disease in campaign documentation. Peer-reviewed journals and research were cited in support of social marketing as an effective population strategy in the reduction of tobacco consumption. The Cancer Institute also conducted focus groups and other research to inform their approach to anti-tobacco campaigns. This included extensive testing and evaluation with CALD audiences.

The 2023–24 tobacco campaign’s CBA also justifies need by comprehensively explaining both the impacts of tobacco on the target audiences and the broader consequences for health services, productivity and the economy. The CBA also outlines the benefits of smoking cessation and provides modelling of expected life-years gained by quitting. This modelling was used to estimate the number of people who would make attempts to quit smoking and thus determine the expected return on investment, discussed further below.

The Cancer Institute developed the campaign as part of a whole-of-government anti-tobacco strategy that also considered and included non-advertising interventions

Section 5.2 of the Guidelines requires agencies to demonstrate the link between a campaign and relevant government priorities and objectives. Section 5.3 of the Guidelines requires that agencies demonstrate that mainstream advertising is the most appropriate medium when considered against available cost-effective, non-advertising alternatives.

A range of plans guides anti-tobacco activities in NSW, including the NSW Cancer Plan, the NSW Tobacco Strategy and the National Tobacco Strategy. Under the NSW Tobacco Strategy, the Cancer Institute is responsible for the public education aspects of the plan, which are linked to actions for the delivery of mass media campaigns. These advertising campaigns are communicated in the plan as one aspect of a package of complementary strategies to be delivered by the NSW Government.

The peer review for the anti-tobacco campaign did not consider alternatives to paid advertising as required by the Guidelines. The peer review provided a persuasive case that mainstream advertising was an appropriate medium. However, it did not explain why it was the most appropriate medium compared to other methods and options. While this represents a non-compliance with the Guidelines, it can be explained by the above integrated approach to cancer prevention and anti-tobacco initiatives in NSW where alternatives are considered in the broader planning framework and not within campaign planning. However, the Cancer Institute could have more clearly addressed this in its peer review documentation.

The anti-tobacco campaign’s CBA demonstrated that the campaign would likely represent value for money

Section 7(1) of the Act requires that a government advertising campaign’s CBA must be carried out before the campaign commences if it is likely to cost more than $1,000,000. One of the roles of a CBA in government advertising campaigns is to inform the head of an agency about whether a proposed government advertising campaign is an efficient and cost-effective means of achieving a public purpose. As required by the Act, the Cancer Institute undertook a CBA for the anti-tobacco campaign during campaign development. The CBA was comprehensive and demonstrated that the campaign was expected to have a benefit-to-cost ratio (BCR) of 33.2. This represents a strong return on investment for the advertising campaign.

The CBA also included a net present value (NPV) estimate for the campaign. The NPV estimates the total value of the campaign over its lifetime, discounted using a standard rate to account for inflation and uncertainty in the future. With a discount rate of five per cent, the NPV for the campaign was estimated by the CBA to be $291.6 million (central estimate) for the initial budget and $204.6 million (central estimate) for the reduced budget.

This initial CBA was done under the assumption that the campaign would either retain its previous year’s budget of $8.45 million or would have a reduced budget of $6.35 million. The same BCR was expected under either scenario. However, when the campaign had its budget further reduced to $4.21 million, the BCR was re-evaluated and reduced to 24.4. This still allowed the Cancer Institute to clearly demonstrate that the campaign represented value for money, even if it was at a lower rate than the other two budget scenarios.

Section 6.1 of the Guidelines requires that any government advertising campaign’s CBA must: assess the options that are available to achieve the campaign’s objective; identify and assess the costs and benefits of all reasonable options; and consider the best option to achieve the objective. Section 6.5 of the Guidelines states that the CBA must also outline options other than advertising that could be used.

The CBA did not explicitly consider non-advertising alternatives and compare these costs. However, under the NSW Tobacco Strategy, the Cancer Institute is responsible for delivering public education in the form of government advertising. The advertising campaigns communicated in the plan are one aspect of a package of complementary strategies that cover a range of different types of interventions and responsible entities. Given that the campaign was expected to be delivered as government advertising, and because the advertising campaign takes place within a broader context of other government programs, further consideration of alternatives would have provided limited additional understanding.

The Cancer Institute established objectives and targets for its anti-tobacco campaign that are in line with government priorities but did not revise these following a significant reduction in budget

Section 5.2 of the Guidelines requires that there is a strong link between the campaign and NSW Government priorities and objectives, and that the objectives of the campaign are clearly set out and realistic.

The Cancer Institute’s overall objective for the anti-tobacco campaign was to influence people aged 18 or over in NSW who currently smoke to feel that quitting is achievable and to use the available smoking cessation support services to successfully quit smoking. In addition, the anti-tobacco sub-campaigns used behavioural objectives (to describe the desired behaviour change for a target audience) and campaign objectives (to identify the overall desired outcomes). These are listed in Table 3.

Source: Cancer Institute NSW.

These sub-objectives and the overall objectives were informed by a range of government strategies and objectives. They include:

• the NSW Health Plan’s objective to reduce the use of tobacco products
• the NSW Cancer Plan’s goal to reduce the incidence of cancer with a priority action to target prevention efforts to the areas of greatest need, which includes smoking and other risks
• the National Tobacco Strategy’s goal to improve the health of Australians by reducing the prevalence of tobacco use and its associated costs.

In addition to the overall objectives, the Cancer Institute developed performance indicators and measurable targets that provided further advice on how it would go about achieving these outcomes. A selection of the key targets for the campaign can be seen in Table 4.

Source: Cancer Institute NSW.

During the planning stages of the campaign, the Cancer Institute considered these targets to be achievable. However, the post-campaign effectiveness report stated that some of the targets were too ambitious. The Cancer Institute attributed this partially to the fact that the campaign was only in the market for a short time, unlike previous years where it ran for most of the calendar year. The Cancer Institute also attributed this to its practice of increasing targets each year, despite the fact that this campaign was not directly comparable to previous ones because it was in market for a shorter period of time.

Throughout the initial planning stages the Cancer Institute expected a total campaign budget of $8.5 million, which included $7.5 million in media costs. The campaign targets were set with the expectation that this budget would be available. A whole-of-government advertising budget reduction required the Cancer Institute to reduce the budget to $4.2 million, including $3.3 million for media. This represented a significant reduction in the available budget.

The NSW Communications Evaluation Framework requires agencies to set targets that are realistic, which in this case would have required a change in targets when the budget was reduced. Realistic targets are important to ensure that the effectiveness of a campaign can be accurately evaluated. Some digital targets were reviewed in response to the reduction in budget. However, the Cancer Institute did not revisit the campaign’s other targets in light of the reduced budget. The metrics do not show that the Cancer Institute delivered what it set out to achieve with its original targets and budget.

The Cancer Institute used lessons learned from previous campaigns and tracking surveys to improve the effectiveness of the anti-tobacco campaign

Section 5.3 of the Guidelines requires agencies to demonstrate that they have considered the effectiveness of the tactical approach as well as creative and media strategies for the campaign. Agencies can also benefit from examining their experience with past campaigns to improve effectiveness.

Previous campaign effectiveness reports such as the 2021–22 and 2022–23 ‘Tobacco Control Campaign Effectiveness’ reports were used to inform the strategy of the 2023–24 campaigns. Where the full report was not yet available, interim results were used. Other examples of information that was used to shape campaign strategies and messaging include:

• specific testing and evaluations of key audiences
• post-campaign reports
• tracking survey data
• updates on campaign topics by the creative agency
• website data and Google analytics
• analysis of reporting by media agencies.

Observations and recommendations from the above sources were presented at kick-off briefings and presentations and then integrated into campaign planning. Evaluations of previous campaigns allowed the Cancer Institute to learn lessons from earlier iterations of the same campaigns and live analysis of its campaign allowed it to make changes as the campaigns were running. The Cancer Institute monitored the campaign’s effectiveness while it was live through digital tracking and mid-campaign reporting.

The anti-tobacco campaign achieved positive results but did not meet all of its outcome targets

Section 5.4 of the Guidelines requires that government advertising campaigns must demonstrate that campaign objectives are measurable and there is a sound approach to evaluation. Objectives should also be specific and achievable.

The Cancer Institute submitted the campaign effectiveness report for the 2023–24 anti-tobacco campaign to DCS in October 2024. The effectiveness report meets the requirements of the Guidelines. Table 5 presents the results of the campaign against key target outcomes. The campaign achieved positive results including:

• an estimated 108,606 people made a quit attempt and/or sought help to quit as a result of seeing the campaign. This represented a cost of $38.77 for each person who made a quit attempt
• nine per cent of people reported making a quit attempt as a result of seeing the campaign against the target of 13%. Twenty-five per cent of smokers reported their intention to quit within the next 30 days as a result of seeing the campaign, which met the target
• the meeting of all but one digital conversion targets (where an audience views the creative and then engages with smoking cessation support services).

While the campaign achieved positive outcomes, it did not meet the targets relating to quit attempts and behaviour change. The Cancer Institute attributes this to the suitability of the targets, rather than to the effectiveness of the strategy. It reports that the shortfalls against these two targets were due to reductions in budget, a practice of increasing targets every year and the short time the campaign was live in the market.

Source: Cancer Institute NSW.

The campaign effectiveness report and the measurement of outcomes was informed by the Cancer Institute Tobacco Tracking Survey, a cross-sectional continuous survey designed to evaluate the effectiveness of anti-tobacco social marketing campaigns. In addition, the Cancer Institute undertook comprehensive post-campaign analysis of creative material and delivery, including insights and observations on view statistics, language, channels, reception and preferred messaging. The report also contains detailed analysis in relation to CALD audiences, Aboriginal reception and pregnant women.

The Cancer Institute selected media channels appropriate for its target audiences, and ensured appropriate and inclusive messaging

Section 5.2 of the Guidelines requires that the campaign strategy must consider whether the tactical approach and creative and media strategies are likely to be effective for the campaign issue and target audience, including whether the target audience is well defined and understood, and CALD and Aboriginal communities and their communication needs have been considered as part of the target audience.

The Cancer Institute has adopted industry and academic frameworks to guide anti-tobacco campaigns and provide a methodical and structured approach to audience selection. Inputs such as smoking cessation motivation, intentions to quit, prompts to action and maintenance of behaviour were assessed to determine target audiences. In addition, the Cancer Institute’s reference to a ‘Tobacco Control Customer Eco-System’ shows how parts of the system work together to drive customer-focused outcomes. This demonstrates a structured approach to audience selection.

The Cancer Institute selected its audiences on a range of factors, including using data sourced from the NSW Population Health Survey. In 2019, research was undertaken to identify audiences which offered the greatest opportunity for impact and changes in behaviour. Further testing was undertaken in 2020 to assess the effectiveness of the creative concepts for that year’s campaign. The Cancer Institute used this information to inform its audience selection.

The Cancer Institute identified and considered the special messaging requirements of key audiences, including Aboriginal communities, CALD communities, people who live in regional and rural areas, and women who smoke during pregnancy (there was specific messaging for Aboriginal women who smoke during pregnancy). This approach was largely informed by commissioned testing and evaluation undertaken by consultants with specialist knowledge of these communities.

Premier’s Memorandum M2022-12 ‘Advertising in regional media’ states that agencies should ensure that they incorporate appropriate images, messages and calls to action that will be relevant and resonate with communities in the target regional areas. The Cancer Institute considered the differing needs of metropolitan, and rural and regional communities. Qualitative research undertaken by the Cancer Institute in 2019 and 2021 informed changes in messaging for rural and regional communities and these changes were carried through to the 2023–24 campaign.

Section 4(9) of the Disability Inclusion Act 2014 sets out that people with a disability have the right to access information in a way that is appropriate for their disability. The Cancer Institute considered the needs of people living with a disability. For example, the Cancer Institute included closed captioning for its video advertisement, in line with the preferences for deaf and hard-of-hearing people.

The Cancer Institute has effectively managed anti-tobacco campaign funding within budget

Section 5.4 of the Guidelines requires that campaigns demonstrate a sound approach to budget management, including whether the size of the campaign budget is appropriate to achieve the campaign’s objectives, and that campaign production costs are reasonable.

The Cancer Institute initially planned for total campaign expenditure of $8.5 million, which included $7.5 million in media costs. The Cancer Institute subsequently revised the budget to $4.2 million, including $3.3 million for media, due to a whole-of-government requirement to reduce expenditure on government advertising. As can be seen in Table 6, the Cancer Institute delivered its campaign within the established budget. While there was a small overspend on creative, talent and production, this was recouped by a lower expenditure on media placement.

Source: Cancer Institute NSW.

Premier’s Memorandum M2022-12 ‘Advertising in regional media’ requires that at least 26% of the campaign’s media expenditure is spent on channels targeting regional audiences outside Greater Sydney, Wollongong and Newcastle. Actual expenditure reporting shows that 34% of expenditure was on regional audiences, exceeding the requirement of 26% for regional communities.

At the time, the NSW Government Multicultural and Aboriginal Advertising Policy required that at least 7.5% of the campaign’s media expenditure was spent on direct communications to multicultural and Aboriginal audiences. Aboriginal and CALD expenditure together comprised 11.7% of media expenditure (7.9% Aboriginal and 3.8% CALD), which exceeds the requirement of 7.5%. However, it also represents a shortfall against planned spend which allocated 14.2% of media expenditure to direct communications with Aboriginal and CALD audiences. The Cancer Institute advised that the whole-of-government reductions in advertising budget required them to prioritise the effectiveness of the campaign over increasing their CALD expenditure which was already exceeding required benchmarks.³

The Cancer Institute ensured value for money through appropriate procurement

Section 5.4 of the Guidelines requires that campaigns demonstrate a sound approach to procurement.

The Cancer Institute procured suppliers through a request for quote (RFQ) process through the NSW Advertising and Digital Communications Services Prequalification Scheme. It undertook a comprehensive RFQ in 2018–19 to engage creative contractors for the subsequent two years, with three potential extension options of 12 months each. This process included developing and utilising selection criteria, weighted decision-making and a focus on best value for money. These were appropriately applied and documented.

Healthshare NSW is an entity established to support delivery within the NSW Health System, including procurement functions. HealthShare NSW supervised and provided advice for the anti-tobacco campaign procurement.

The Cancer Institute undertook a similarly comprehensive RFQ process in 2023–24 to refresh its suppliers. The same supplier was successful in this bid and was appointed for two years with an option to extend by three years.

³ The Cancer Institute notes that a minimum of four exposures to tobacco control advertising per month is required for behaviour change so campaign expenditure in delivery could not be dropped below that without compromising campaign effectiveness.

The vaping control campaign was not designed to influence support for a political party and was for an allowable purpose under the Guidelines

The audit team reviewed campaign materials developed by the Cancer Institute for the vaping control campaign. The audit found no breaches of section 6 of the Act.

The vaping control campaign was a public health campaign that aimed to reduce the proportion of 14–24-year-olds in NSW taking up or using e-cigarettes. As such, the vaping control campaign was for an allowable purpose under the Guidelines.

The vaping control campaign complied with the mandatory requirements of the Act

Agencies must comply with a range of requirements set out in the Act regarding CBA and peer review, and the issuing of a compliance certificate. The Cancer Institute complied with these requirements in undertaking the vaping control campaign.

Any campaign valued at over $250,000 is required to go through the DCS peer review process before the campaign commences. The Cancer Institute completed the peer review process in October 2023. As required by the Act, this was prior to the campaign’s launch.

An agency undertaking a campaign valued at over $1 million is required to complete a CBA before the campaign commences. The Cancer Institute completed a CBA for the vaping control campaign in April 2023. The result of this CBA is discussed below.

Before the campaign commences, the head of the agency must issue an advertising compliance certificate. This certificate states that, in the opinion of the head of the agency, the proposed campaign:

• complies with the Act, the Regulation and the Guidelines
• contains accurate information
• is necessary to achieve a public purpose and is supported by analysis and research
• is an efficient and cost-effective means of achieving that public purpose.

The head of the Cancer Institute is the CEO. However, for the purposes of the Act, the Secretary of NSW Health is considered the head of the agency and as such was required to sign the compliance certificate. The CEO endorsed a brief to the Secretary which advised that they were satisfied that the campaign complied with the above information. The Secretary signed the compliance certificate in line with the requirements of the Act in November 2023. The brief that was sent to the Secretary contained supporting information for the above requirements to demonstrate that the compliance certificate could be signed.

The Cancer Institute ensured that the campaign presented all facts accurately, objectively and in a fair and accessible manner

The vaping control campaign complied with the principles of accurate and objective presentation of facts and the objective in its campaign materials, as required by section 2 of the Guidelines. The Cancer Institute provided research to substantiate its claims regarding the effects of vaping in its peer review proposal.

The Cancer Institute consulted with the Chief Health Officer’s E-cigarette Expert Panel, which reviewed the campaign storyboards for accuracy. During the campaign material production, the Expert Panel recommended the removal of a specific scene because it made claims that were not in line with available scientific research. This scene was removed.

The Cancer Institute has conducted research to justify the vaping control campaign need and approach

The Cancer Institute justified the need for the 2023–24 vaping control campaign by outlining the negative health impacts of vaping and its role as a gateway to tobacco smoking. The Cancer Institute conducted focus groups and other research to inform the approach to the vaping control campaigns. The Cancer Institute also established a Vaping Communications Advisory Panel with a Terms of Reference to provide advice and guidance throughout campaign development. The panel included experts on behaviour change, e-cigarette research and Aboriginal public health. The panel met regularly and recorded detailed agendas and discussions about the campaign’s approach.

The Cancer Institute’s justification for the campaign utilised data from Health Stats NSW and other external sources. The rationale for the campaign included:

• there was an increase in the percentage of 16–24-year-olds in NSW who had ever used an e-cigarette from 15.6% in 2014–15 to 32.7% in 2020–21
• e-cigarettes can be a gateway to cigarette smoking
• e-cigarettes contain ingredients that can cause long-term harms to health, including ingredients that contain cancer-causing agents that can cause adverse health effects and cardio-vascular/lung disorders
• there are short-term harms to health from e-cigarette use, such as an elevated heart rate and high blood pressure.

In the absence of current and available data, the Cancer Institute undertook primary research to explore the use of e-cigarettes among young people in NSW. This research was undertaken in conjunction with the University of Sydney and informed the campaign’s need and approach. It included two online surveys:

• a survey of 1,000 young people aged 18–24 in 2022–23, supported by additional focus groups
• a survey of 962 parents, 2,011 educators and 721 young people aged 14–17, supported by additional focus groups.

The Cancer Institute commissioned a subject matter expert to undertake a literature review and horizon scan of the opportunity for a vaping control campaign. The resulting research recommended a role for an evidence-based social marketing campaign to reduce the uptake of e-cigarettes in NSW.

The CBA demonstrated that the campaign would likely represent value for money

As required by the Act, the Cancer Institute undertook a CBA for the vaping control campaign during campaign development. This CBA modelled a campaign BCR of 8.2, indicating that the campaign would likely represent good value for money.

The CBA also included a NPV estimate for the campaign. The NPV estimates the total value of the campaign over its lifetime, discounted using a standard rate to account for inflation and uncertainty in the future. Using a five per cent discount rate, the CBA calculated the NPV of the campaign to be $35.3 million.

The Cancer Institute advised that data and research on vaping and its effects was still limited at the time, and this posed challenges to establishing quantifiable benefits for the CBA. The Cancer Institute relied on research that showed a connection between people who vaped and an uptake in smoking, and used this link to calculate the benefits in the CBA. The benefits stated in the CBA only related to this connection between vaping and smoking. Given the research and evidence, this was an appropriate method for establishing a quantifiable benefit for an emerging risk in the absence of other research and data. However, it also meant that the benefits were all formulated in terms of cigarette smoking cessation and did not consider the unique risk profile of e-cigarettes.

The NSW Government Guide to Cost-Benefit Analysis states that where quantification may not be practical for benefits, impacts can be accounted for qualitatively and should be recorded in the CBA. In addition to the role of vaping in transitioning to tobacco cigarettes, the CBA describes the evidence of emerging harms of e-cigarettes, including links to lung disease, cardio-vascular disease, developmental damage, lung injury, poisoning and class-action litigation. However, while the harms are listed and broadly described, they are not discussed as benefits in terms of their likely significance to the target audiences or how the campaign might impact these risks. Thus, the benefits of the campaign may be understated.

The CBA did not outline or compare costs with options other than advertising as required by Section 6.4 of the Guidelines. The vaping control campaign was delivered by the Cancer Institute as a complementary measure to a range of regulatory and other interventions listed in the CBA. Under the NSW Tobacco Strategy, the Cancer Institute is responsible for delivering public education about tobacco use in the form of government advertising and it has extended this approach with the vaping control campaign. Given that the campaign was expected to be delivered as government advertising, and because the advertising campaign takes place within a broader context of other government programs, consideration of alternatives would have provided limited further understanding.

For its vaping campaign, the Cancer Institute established objectives and targets that were in line with government priorities

The Cancer Institute established an overall objective for the vaping control campaign to get young people aged 14–24 years to remain vape-free or quit vaping. This was in line with the planned approach to focus on changing the behaviour of young people.

Objectives for the vaping control campaign were linked to a range of government strategies and objectives. Several of the government strategies relate to reducing the use of tobacco products. The Cancer Institute saw these as relevant objectives because it had evidence that e-cigarette usage was tied to an increased likelihood of taking up the use of tobacco products. The whole-of-government objectives include:

• the NSW Health Plan’s objective to reduce the use of tobacco products
• the NSW Cancer Plan’s goal to reduce the incidence of cancer with a priority action to target prevention efforts to the areas of greatest need, including helping people to not take up vaping
• the National Tobacco Strategy 2023–2030’s goal to improve the health of Australians by reducing the prevalence of tobacco use and its associated costs
• the Commonwealth Government’s position paper on ‘Policy and regulatory approach to electronic cigarettes (e-cigarettes) in Australia’.

The objectives for the vaping control campaign were underpinned by a logic model that identified the background influences, influences on intention to reject/quit, and developmental attributes specific to youth and adolescents. Performance indicators and measurable targets were developed against these objectives. Examples of these can be seen in Table 7.

Source: Cancer Institute NSW.

The Cancer Institute improved its vaping control campaign using lessons learned from previous vaping control campaigns and audience research

The Cancer Institute improved the 2023–24 vaping control campaign by referring to lessons from the campaigns run in 2021–22 (phase one – managed by the Ministry of Health) and 2022–23 (phase two – managed by the Cancer Institute).

The following information sources allowed the Cancer Institute to learn from previous versions of the campaign and to help shape its campaign strategies and messaging:

• evaluations of phase one and phase two and post-campaign reports. In particular, the 2022–23 post-campaign report contained recommendations for improvements
• a mid-campaign evaluation of the 2023–24 campaign
• tracking surveys showing live results
• website data and Google analytics allowing for live outputs to be seen and changes to be made.

The lessons-learned approach was also applied to improve the available campaign data and research to help inform the way the campaign was run. For example, an evaluation of the 2022–23 vaping control campaign highlighted a lack of available data on the use of e-cigarettes by Aboriginal young people and suggested the engagement of an Aboriginal-owned and -led organisation to undertake formative research. The Cancer Institute commissioned this research, which informed the 2023–24 campaign and the approach to the campaign evaluation.

The Cancer Institute’s post-campaign evaluation and effectiveness report demonstrates that the vaping control campaign exceeded its target outcomes

The Cancer Institute submitted its campaign effectiveness report for the 2023–24 vaping control campaign to DCS. The report met the requirements of the guidelines. The vaping control campaign performed strongly against performance indicators and met all outcome objective targets within the margin of error, as shown in Table 8, including significantly exceeding several of the key outcomes. The results demonstrate that:

• recognition was above target for all demographics, with 64% of people recognising the campaign after being prompted to recall it, exceeding the target of 45%. The Cancer Institute estimates that this contributed to an additional 24,000 14–24-year-olds in NSW attempting to quit
• 87% of people who remembered the campaign agreed that vaping is not safe compared to 78% of those who didn’t remember the campaign
• 92% of non-vapers who remembered the campaign indicated their intention to continue not to vape
• 57% of vapers who saw the campaign made at least one attempt to quit.

Source: Cancer Institute NSW.

The Cancer Institute highlighted other factors that may have impacted performance against the outcome targets. Regulatory reform and the introduction of vape restrictions may have affected the likelihood of people making quit attempts, as well as producing concurrent messaging to the target audiences. Other vaping control campaigns were delivered by the Commonwealth Government around the same time and may have enhanced the target audiences’ capacity to receive messaging. Thus, the full results against the outcome measures may not be attributable solely to the Cancer Institute’s campaign.

In addition to these results, the Cancer Institute also measured a variety of diagnostic objectives that would allow it to determine the way the campaign was received by the audience.

The Cancer Institute selected media channels that were appropriate for its target audiences and ensured appropriate and inclusive messaging

The Cancer Institute adopted industry and academic frameworks to guide its vaping control campaigns and provide a methodical and structured approach to audience selection. Impacts such as barriers to change, thoughts and feelings, and key messages were considered against particular media channels. In addition, the Cancer Institute refers to a ‘Vaping Control Customer Eco-System’, which shows how parts of the vaping control system work together to drive customer-focused outcomes.

Exploratory audience research was used to aid the selection of relevant audiences through 12 online focus groups. The vaping control campaign was targeted at young people aged 14–24 in NSW, including Aboriginal young people and audiences who speak Mandarin, Cantonese, Arabic, Vietnamese and Hindi at home. The Cancer Institute identified the particular messaging requirements of these audiences and considered these needs throughout the creation of the campaign’s creative. The messaging approach to these communities was underpinned by testing and evaluation.

The Vaping Communications Advisory Panel provided advice on campaign concepts, audiences and messaging, evaluation tools and potential messaging risks. The minutes of the Panel show extensive discussion and tailoring to ensure responsible, evidence-based messaging that was appropriate for the audience and purpose.

Creative pre-testing included potential audience testing according to age and campaign status, concept testing to establish message take-aways and likely behaviour impacts, and online quantitative surveys to test final suitability, fine-tuning and risks. Pre-testing specific to Aboriginal people was conducted across a sample of young people from across NSW. Interviews were carried out by professionally engaged community interviewers. This pre-testing found that the prevalence of vaping among Aboriginal youth was much higher than it was among the general population and far greater than previous research indicated.

The online, near-finalised material for the anti-vaping campaign was tested through an online survey of young people aged 14–24 years, including young people in regional NSW, Aboriginal young people and young people from CALD communities. Findings from pre-testing were analysed in the report and improvements were recommended to overcome ineffective or inappropriate messaging.

The Cancer Institute effectively managed the vaping control campaign funding within budget

The Cancer Institute’s final expenditure on the vaping control campaign was $2,941,707. As can be seen in Table 9, the Cancer Institute delivered its campaign within the established budget. A small underspend was reported due to changes to timelines for research activities.

Source: Cancer Institute NSW.

Forecasts outlined expenditure by month to allow tracking through the campaign and reconciliation with the allocated budget. The traditional media plan included breakdowns and forecasts by geographical audience, media type and CALD audiences. The digital plan included forecasts by digital media type and information about creative messaging and placement for each item.

Premier’s Memorandum M2022-12 ‘Advertising in regional media’ requires that at least 26% of the campaign’s media expenditure is spent on channels targeting regional audiences outside Greater Sydney, Wollongong and Newcastle. For this campaign, 38% of expenditure was on regional audiences.

At the time, the NSW Government Multicultural and Aboriginal Advertising Policy required that at least 7.5% of the campaign’s media expenditure was allocated to direct communications to multicultural and Aboriginal audiences. Aboriginal and CALD expenditure together comprised 14.4% of media expenditure (8.6% Aboriginal and 5.8% CALD), which exceeds the minimum requirement.

The Cancer Institute directly negotiated with a creative materials supplier in 2022

The Cancer Institute used direct negotiations for the vaping control campaign creative materials contract in March 2022. A direct negotiation is an exclusive dealing between an agency and a potential supplier. The contract was awarded in March 2022 and ran until June 2023 with two one-year optional extensions. The vendor, who was selected through direct negotiation, supplied materials for the 2023–24 campaign after the Cancer Institute exercised one of the optional extensions.

The Cancer Institute advised that in December 2021 the then Minister for Health requested that the Cancer Institute expedite the vaping control campaign. The Cancer Institute did not create a record of the request from the Minister. To meet this request, the Cancer Institute brought the deadline for supplier engagement forward to March 2022. At the time, the Cancer Institute evaluated that this could only be achieved by negotiating directly with a supplier.

The NSW Independent Commission Against Corruption (ICAC) has released relevant guidelines for how to handle direct negotiations. The NSW Government Direct Dealing Guidelines require agencies to comply with the ICAC guidelines, and also advise that agencies must document their justification for direct dealing. The ICAC guidelines advise that direct negotiations should be avoided unless they clearly fall within the Government’s legislative and policy framework and there is a plan to manage risk. Where a decision is made to negotiate directly with a supplier, the ICAC outlines the steps that can be taken to mitigate the risks to fair competition, public perception and other consequences. Examples include documenting the process thoroughly, seeking expressions of interest to show transparency, documenting alternative approaches and being evidence-based.

The decision to commence direct negotiations was signed off by the CEO of the Cancer Institute and the NSW Health Chief Procurement Officer. Given the higher risk posed by a direct negotiation, it was appropriate that this decision was signed off at a senior level. The brief setting out the decision to directly negotiate sets out a number of reasons for this being necessary:

• the only way to ensure that supplier engagement could be completed by March 2022 was through direct negotiation
• the chosen creative agency had experience working on vaping campaigns and no other available suppliers had that relevant experience
• a procurement process would not improve value for money as alternative suppliers would be less experienced and would need to be upskilled.

In its guidance regarding direct negotiations, the ICAC provides a range of situations where direct negotiations may be appropriate, such as where a single supplier has a monopoly, where intellectual property rights play a role in the decision and where there is a public health emergency. The rationales set out by the Cancer Institute did not meet any of the situations identified by the ICAC. The ICAC does not list a reduced procurement timeframe as one of the rationales.

The decision to directly negotiate with a supplier meant that the Cancer Institute increased the risk of not achieving value for money in its procurement for the vaping control campaign, as not seeking other cost-effective quotes for the work meant that alternative suppliers could not be considered. Given this, the Cancer Institute had to ensure that appropriate due diligence was done on the supplier to ensure that value for money was achieved.

The Cancer Institute ensured appropriate levels of due diligence over engagement with the supplier and took steps to ensure the procurement represented value for money

Due diligence in procurement consists of the checks performed to understand if a supplier is genuine, capable, reliable, financially viable, compliant and of good reputation. The NSW Procurement Board provides whole-of-government procurement arrangements to offer buyers access to suppliers who meet relevant experience and qualifications standards. This includes an Advertising and Digital Services Prequalification Scheme.

In order to ensure that it undertook appropriate due diligence, the Cancer Institute convened a panel to evaluate the documentation provided by the supplier and to manage the procurement. This process was well documented and considered relevant aspects such as value for money. In addition, in 2019, the Cancer Institute had awarded the same supplier a contract through a competitive process for the anti-tobacco campaign. It was able to use the due diligence from this earlier procurement to compare the prices the supplier quoted with its previous quotes, and therefore it could benchmark value for money against the supplier’s previous work that was offered under a competitive tender.

The Cancer Institute selected its supplier from the Advertising and Digital Services Prequalification Scheme, meaning that the supplier had undergone pre-assessment as part of joining the scheme. This reduced the need for the Cancer Institute to repeat some basic due diligence checks, which included assessment criteria relating to performance capacity, demonstrated experience, and financial viability and stability.

The Cancer Institute also applied the NSW Procurement Portal risk assessment tool to the project which recommended that the Cancer Institute prepare various briefing, evaluation and procurement planning documents. The Cancer Institute completed the recommended documentation and also ensured that it used the standard forms of agreement and other resources set by the prequalification scheme terms and conditions. These steps allowed the Cancer Institute to demonstrate that it undertook an appropriate level of due diligence regarding the chosen supplier.