A brief description of some quantitative and qualitative methods to assess impacts of adminsitrative simplification efforts, such as the Standard Cost Model and perception surveys
The Path to Product Excellence: Avoiding Common Pitfalls and Enhancing Commun...
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
AS only as one of the solutions. Global problem – complex solutions
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
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.
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.
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