1. Collecting information on full-time equivalent staff

UA supports the collection of information on full-time equivalent (FTE) staff instead of headcounts to better reflect the numbers of actual hours worked by staff in Australia’s charities and not-for-profits sector. However, extra guidance or information will need to be provided to ensure consistency in calculating hours worked and conversion to FTE staff in different types of organisations.

Australian universities currently provide information on FTE staff to the Department of Education and Training through the Higher Education Information Management System (HEIMS). The HEIMSHELP website provides guidance to assist universities in calculating FTE for a full year of staff members employed under casual work contracts.

2. Assisting charities to update their responsible persons as part of the AIS

UA supports the use of the 2017 AIS to ensure and improve the accuracy of information on the ACNC Register. UA prefers the option which shows charities a preview of the responsible persons on the ACNC Register before they submit the AIS and allows charities the opportunity to amend any details if required.

3. Confirming compliance with the ACNC’s governance standards

UA supports the proposal to include questions on whether charities are meeting ACNC governance standards as part of their 2017 AIS.

Most Australian universities are established and governed by their own state-based university establishment Acts, for example, the University of Sydney Act 1989. In general, these Acts specify the organisation, responsibilities, functions and management of universities. Therefore, Australian universities are compliant and meet the ACNC governance standards.

4. Allowing charities to upload their Annual Report in the AIS

UA agrees that charities should have the option to upload their annual report in the 2017 AIS.

5. Requesting specific locations where charities are operating

UA does not support the proposal to seek a further breakdown of the areas in which charities operate. Universities that operate through different campuses may find it difficult to answer this question. This requirement would increase their reporting burdens. While there are 39 not-for-profits universities in Australia, they operate across 229 campus locations around Australia. For example, CQUniversity has 13 campuses around Australia, of these 10 campuses are located in different parts of Queensland.

6. Improving the question about a charity’s beneficiaries

UA supports the proposal to amend the question on beneficiaries such that its format is the same as the question on activities.

7. Addition of sales and investment income to the income statement

UA supports the inclusion of sales and investment income in the income statement. However, clear guidance and definition of sales and investment income will need to be provided to ensure consistency across different charities.

8. Removal of the question asking charities if they are up to date with their subtypes, governing documents and responsible persons

UA supports this proposal.