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EVALUATING IMPACTS OF
                    REGULATORY REFORMS –
                    QUANTITATIVE AND QUALITATIVE
                    METHODS


4 February 2013, Bogotá


Daniel Trnka
Regulatory Policy Division,
Directorate for Public Governance
and Territorial Development
OECD
How to evaluate impacts?

• Outputs vs. outcomes
• Improving social welfare through
  better/smarter regulation
  vs.
• Saving costs for citizens/businesses/public
  sector and changing perception
• Ideal case – full RIA
• Other options – calculating reduction of
  regulatory/administrative costs (SCM),
  perception surveys
What is the Standard Cost Model?

• Invented by the Dutch Ministry of Economic Affairs in the mid
  90s
• Used by all EU countries + Australia, Mexico, Kazakhstan…
• A tool to measure administrative costs and express them in
  monetary terms
• Advantages:
   –   SCM makes costs ‘visible’
   –   Easy to measure, monitor & communicate
   –   Uniformity, transparency, reliability and comparability
   –   Commitment & awareness of policymakers
   –   Enables to set a target distribute it across administration
• Disadvantages:
   – May be too costly
   – Focus only on one part of costs, not benefits
Different costs of regulations

The costs of regulation to businesses



Direct financial           Compliance               Long-term
costs                      costs                    structural costs



Indirect financial costs                Administrative costs
(substantive compliance
costs)
What are administrative costs?

• Administrative costs/burdens (AB) are the costs
  imposed on businesses, when complying with
  information obligations stemming from
  government regulation
• Costs of paperwork – e.g. filling in forms,
  submitting them to the administrative
  authorities
• But also – gathering, processing and updating
  data, inspections
The methodology for AC measurement

The Standard Cost Model




Possible to differentiate between particular regulations,
ministries, sectors of regulation
Methodological questions

• Full or partial baseline measurement,
  prioritisation – Beyond Pareto principle - 10% of the IO’s
  accounts for 90% of AC
• Business As Usual (BAU) costs
• Costs of informing third parties (customers,
  trade unions…)
• Costs of material, equipment
• Statistical relevance
Statistical relevance

• SCM based on assumptions, not on precise
  numbers
• 3 to 5 measurements per IO (and
  consultations of stakeholders) - a
  sophisticated rule of thumb
• If results converge, 3 to 5 is enough, if not,
   need a bigger sample
Main challenges
•   Interagency co-ordination
•   Sustained momentum
•   Cutting dead wood
•   Last mile issue
•   Communication – with stakeholders, of results,
    managing expectations
•   Possible discrepancy between the most burdensome and
    the most irritating regulations
•   Evaluation
•   Potential squeezing-out effect
•   Integration with other policies
•   Integration into ex ante impact assessment
Reducing administrative burdens - does
    anyone perceive higher comfort?
• The shortest answer is: “No.”
• A gap between “perceptions and reality”
• But “What is reality?”
• “If a majority of persons perceive the same way
  consistently over time – maybe that’s the reality”
• Some possible reasons:
    – Absolute numbers vs. individual effects
    – Delays in impact
    – Cutting dead wood
    – Too much focusing on numbers, less on perception,
      irritation
    – Lack of communication
Assessing perception

• Another way to evaluate effects of
  simplification efforts
• “happiness” is not our main goal but…
• Getting feedback from users
• Shaping and evaluating regulatory reform
  programmes
• Perceptions influence compliance with
  regulations and investment decisions
• Getting a well-deserved praise
Drivers of perception

•   Irritation costs,
•   Service quality,
•   Different categories of costs,
•   Unawareness of goals benefits
•   Frequency of reform, uncertainty
•   Negativity bias,
•   Expectations,
•   Trust in government, political opinions
•   Communication, involvement
Danish burden hunter technique

•   Cutting the red tape that business experience as most irritating
•   Allowing business to set the agenda and be heard
•   User centered methods for collecting data and developing solutions
•   Increase knowledge about why specific regulation is experienced as a burden to
    business – user behavior and efficient regulation


Objectives
•   Identify 10-15 specific initiatives which addresses burdens experienced by
    business
•   Develop a method that focuses on burdens experienced by business
For more information see:

• OECD Cutting Red Tape series:
   –   National Strategies for Administrative Simplification
   –   Businesses' Views on Red Tape
   –   Comparing Administrative Burdens across Countries
   –   Progress in Public Management in the Middle East and North Africa
   –   Why Is Administrative Simplification So Complicated?
   –   Country reviews: the Netherlands, Portugal. Poland, Viet Nam
• Overcoming Barriers to Administrative Simplification
  Strategies: Guidance for Policy Makers

• SCM Network:
http://www.administrative-burdens.com/

• OECD project on Assessing performance of regulations
  through perception surveys
www.oecd.org/regreform/perceptions
THANK YOU!

 daniel.trnka@oecd.org
www.oecd.org/regreform

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Evaluating Impacts of Regulatory Reforms

  • 1. EVALUATING IMPACTS OF REGULATORY REFORMS – QUANTITATIVE AND QUALITATIVE METHODS 4 February 2013, Bogotá Daniel Trnka Regulatory Policy Division, Directorate for Public Governance and Territorial Development OECD
  • 2. How to evaluate impacts? • Outputs vs. outcomes • Improving social welfare through better/smarter regulation vs. • Saving costs for citizens/businesses/public sector and changing perception • Ideal case – full RIA • Other options – calculating reduction of regulatory/administrative costs (SCM), perception surveys
  • 3. What is the Standard Cost Model? • Invented by the Dutch Ministry of Economic Affairs in the mid 90s • Used by all EU countries + Australia, Mexico, Kazakhstan… • A tool to measure administrative costs and express them in monetary terms • Advantages: – SCM makes costs ‘visible’ – Easy to measure, monitor & communicate – Uniformity, transparency, reliability and comparability – Commitment & awareness of policymakers – Enables to set a target distribute it across administration • Disadvantages: – May be too costly – Focus only on one part of costs, not benefits
  • 4. Different costs of regulations The costs of regulation to businesses Direct financial Compliance Long-term costs costs structural costs Indirect financial costs Administrative costs (substantive compliance costs)
  • 5. What are administrative costs? • Administrative costs/burdens (AB) are the costs imposed on businesses, when complying with information obligations stemming from government regulation • Costs of paperwork – e.g. filling in forms, submitting them to the administrative authorities • But also – gathering, processing and updating data, inspections
  • 6. The methodology for AC measurement The Standard Cost Model Possible to differentiate between particular regulations, ministries, sectors of regulation
  • 7. Methodological questions • Full or partial baseline measurement, prioritisation – Beyond Pareto principle - 10% of the IO’s accounts for 90% of AC • Business As Usual (BAU) costs • Costs of informing third parties (customers, trade unions…) • Costs of material, equipment • Statistical relevance
  • 8. Statistical relevance • SCM based on assumptions, not on precise numbers • 3 to 5 measurements per IO (and consultations of stakeholders) - a sophisticated rule of thumb • If results converge, 3 to 5 is enough, if not, need a bigger sample
  • 9. Main challenges • Interagency co-ordination • Sustained momentum • Cutting dead wood • Last mile issue • Communication – with stakeholders, of results, managing expectations • Possible discrepancy between the most burdensome and the most irritating regulations • Evaluation • Potential squeezing-out effect • Integration with other policies • Integration into ex ante impact assessment
  • 10.
  • 11. Reducing administrative burdens - does anyone perceive higher comfort? • The shortest answer is: “No.” • A gap between “perceptions and reality” • But “What is reality?” • “If a majority of persons perceive the same way consistently over time – maybe that’s the reality” • Some possible reasons: – Absolute numbers vs. individual effects – Delays in impact – Cutting dead wood – Too much focusing on numbers, less on perception, irritation – Lack of communication
  • 12. Assessing perception • Another way to evaluate effects of simplification efforts • “happiness” is not our main goal but… • Getting feedback from users • Shaping and evaluating regulatory reform programmes • Perceptions influence compliance with regulations and investment decisions • Getting a well-deserved praise
  • 13. Drivers of perception • Irritation costs, • Service quality, • Different categories of costs, • Unawareness of goals benefits • Frequency of reform, uncertainty • Negativity bias, • Expectations, • Trust in government, political opinions • Communication, involvement
  • 14. Danish burden hunter technique • Cutting the red tape that business experience as most irritating • Allowing business to set the agenda and be heard • User centered methods for collecting data and developing solutions • Increase knowledge about why specific regulation is experienced as a burden to business – user behavior and efficient regulation Objectives • Identify 10-15 specific initiatives which addresses burdens experienced by business • Develop a method that focuses on burdens experienced by business
  • 15. For more information see: • OECD Cutting Red Tape series: – National Strategies for Administrative Simplification – Businesses' Views on Red Tape – Comparing Administrative Burdens across Countries – Progress in Public Management in the Middle East and North Africa – Why Is Administrative Simplification So Complicated? – Country reviews: the Netherlands, Portugal. Poland, Viet Nam • Overcoming Barriers to Administrative Simplification Strategies: Guidance for Policy Makers • SCM Network: http://www.administrative-burdens.com/ • OECD project on Assessing performance of regulations through perception surveys www.oecd.org/regreform/perceptions

Editor's Notes

  1. AS only as one of the solutions. Global problem – complex solutions
  2. Whole-of-government approach, integration with ex ante, e-gov User-focused approach Quantification, but cautious A watchdog? Centralisation x ownership, Training, guidelines, co-ordination, methodological support
  3. Despite large investments in regulatory reform programmes in many OECD countries, few surveys in the sample indicate that stakeholders feel improvement In several countries, businesses are aware of the governments’ programs and intention to reduce administrative burdens. However businesses are very suspicious whether governments can successfully realize their targets in some countries In a number of countries, tax regulation is frequently viewed as particularly burdensome. Employment, health and safety, environmental regulations and reporting obligations are also identified as burdensome In the Netherlands for example, the government met its goal to reduce administrative burdens on businesses by 25% in 2007. Despite this achievement (OECD, 2007) business is frustrated at what it considers to be slow progress and the failure to tackle issues that really matter from its perspective. The Regulation Barometer – Evaluating the Better Regulation Programme in Sweden The results of the survey indicated that most of the businesses were aware of the government’s reform, indicating that the communication strategy of the government proved successful. However, 75% of respondents thought that the burden of regulation had remained almost the same over the last 12 month and still 58% said that administrative burdens will be more or less the same in the following year – despite the government’s plans.
  4. An individual’s sense of hassle or irritation may have a larger impact on his/her overall perception of regulation than measurable costs of regulation. For example, according to the 2009 Action Programme for Reducing Administrative Burdens in the EU, “the degree to which businesses consider an information obligation to be irritating (irritation factor) is very often uncorrelated to the administrative burdens imposed.” Citizen and business’ perceptions of regulations are shaped by their experience with front-desk staff that is in charge of the implementation of regulation. Factors of service quality include “professionalism, timeliness, staff attitude, and information.” For example, participants in the Canadian CFIB Survey identified customer service issues such as being put on hold by a regulator, rude or poorly-informed agency staff, and getting more than one answer to the same question, as a large part of the ‘regulatory headache’ . Business and citizens are unaware of the full impact in terms of costs and benefits on society of regulations. Benefits are often diffuse, whereas costs affect individual businesses more concretely. By changing institutionalized practices, reform per se may create significant irritation costs, especially on businesses. Reform can make businesses uncertain of compliance requirements; the Danish Burden-Hunter Project cited government uncertainty and unpredictability as drivers of negative perception.
  5. Why not just ask the companies that have to follow the regulation? Let the companies set the agenda – we had some ideas about what they would say from e.g. SCM measurements and talks with business organisations Apart from solving (some of) the problems we would find we also wanted to develop a method that can be used in the future