Getting started on the PBB reform agendain Indonesia – a practical outline of thesteps to be taken in setting up a framewo...
Aims of this session:• Examine some practical examples of how PBB  could be applied here at the implementation  stage. Thi...
5 phases in developing a performancebudgeting framework1. The “Set-up” stage of defining:    – outcomes & programs    – se...
Phase 1 - Six steps in “setting up” aperformance monitoring regimeThere are six basic steps to setting up a performance mo...
Step A. Defining outcomes, programs andactivities – Examples from DG Budgets•   Outcomes & Program structure     – Governm...
Step A. Outcomes, Programs, Activities and Responsibilities– An Example                        Management                 ...
Australian example and some similarities          Fi g u r e: Ou t com e 1 – con t r i b u t i n g ou t p u t s
Distribution of all expenditures to programs               Current Main Programs (8 )and DGs                              ...
Step B. Selecting performance indicatorsRemember performance indicators demonstrate that the governments  requirements are...
Step B. Australian example ofperformance indicators for Budget outputs
In choosing output group indicators and targets,agencies should aim to answer ‘yes’ to all of thefollowing questions:1.   ...
In choosing output group indicators and targets,agencies should aim to answer ‘yes’ to all of thefollowing questions (cont...
Step B. Testing some early Performance Indicatorsdefined for Budget Management & Reform  Outcome/Objective: To manage the ...
Step B. Performance indicators for DG Treasuryactivities – indicators serve different purposes:accountability, analysis an...
Step C. Specifying targets, benchmarks & referencepoints – Examples from Australian CustomsOutput 2: Trade facilitation an...
Step C. Specifying targets, benchmarks &reference points – Testing of other earlierprepared indicators not endorsed by DG ...
Step C. Specifying targets, benchmarks &reference points – testing of indicators continuedActivity 4. Enforcement and inve...
Step F. Reporting• Internal reporting for Agency Management   – Management’s requirements ideally issued     through the C...
More this afternoon - Planning the introduction of“operating cost flexibilities” and revisedaccountability arrangements  •...
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Getting started on the PBB reform agenda in Indonesia – a practical outline of the steps to be taken in setting up a framework

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Presented by Pat McMahon Budget Advisor, Australian Department of Finance and Deregulation

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  • Examine some practical examples of how PBB could be applied here at the implementation stage. This is only the setting up stage. This afternoon, after we have looked at MTEF, we shall start addressing the Plan and the practicalities involved in moving to a mature PBB (3 rd Session).
  • If you take the Australian example there are at least 5 stages in developments of any performance budgeting framework. They should not occur all at once. I want to focus on the first three of these as these are the most critical early steps.
  • Getting the basics right from the beginning is important. You might recall from the Australian experience we did an evaluation of our performance framework some 7 to 8 years after implementing our version of PBB. I want to focus on what can be done to avoid our errors at this crucial set up stage. There are 6 elements to setting up a performance monitoring regime – as listed above. I want to concentrate on some of these in the context of Indonesia
  • The obvious starting point is to define outcomes and programs. Defining Outcomes and programs requires great care and is very important. Getting this wrong will likely mean that the wrong performance indicators are defined, the wrong data is collected and used and the information available is not optimal for decision makers (i.e.managers, ministers, government and parliament). The other obvious point is that in any performance framework it must be clear who is to be held responsible for performance. Without this, there can be limited accountability. For this reason great care is taken to ensure responsibilities for administering programs are clearly defined and very few programs in Australia are therefore shared across agencies. The distribution of all expenses to programs that are used to achieve the outcomes sought by governments (ie their priorities) are particularly important when we measure costs over time in achieving those objectives. It is clear that if not all costs are recorded then performance measures that incorporate costs or unit costs will be very misleading.
  • No doubt this will look familiar to many of you. This is borrowed from slides presented by the World Bank that has aligned organisational structures to Programs and Activities. It has since been used fairly widely by the Ministry of Finance and Bappenas to discuss program structures and how they should align with Echelon 1s in order that there be clarity as to who is responsible for the performance of programs. The program name is shown in red – Budget Management and Reform. The activities that feed into this program are shown in yellow. The organisational structure is shown in the white boxes. All of these feed into the outcome which is shown in italics at the bottom in the purple box. The outcome is meant to be what the Government wants to achieve, and performance indicators should always be developed to measure whether or not the outcome is being achieved. It is a very good start, but there are some comments I want to make. Remember that an Outcome or the objective should be what the Government is trying to achieve . Carefully defining the government’s desired outcomes as the program objective is very important as it will define what performance indicators are necessary. This will become apparent as we go through this presentation. There are two other comments that I want to highlight by reference to the next two slides.
  • I said that in relation to the previous slide that the DG Budgets example was a good start and I will say why now by reference to the similarities with the Australian equivalent. Regard the outcome as the government’s objective – namely “sustainable government finances” – sustainable in the sense that the Budget is setting up medium term fiscal outcomes that are sustainable which leads to confidence in the government’s ability to manage the economy and to growth. 2. Regard the output group as the program – in this example there are two programs feeding into the achievement of the Government’s objective of sustainable government finances (i.e. the Budget and Financial Management) 3. Regard the sub outputs as the activities (Budget advice, financial reporting, financial framework etc). If you do this you can see definite similarities with the previous slide for DG Budgets. While the Australian example does not show the organisational structure you can envisage that the organisational structure will align readily to the output groups and sub outputs. I can assure you that they do – the head of Budget Group is responsible for the Output Group called “Budget” and the head of Financial Management Group is responsible for the Output Group called “Financial Management”. Note also the sub outputs shown are equivalent to what you call activities. They tend to align with organisational structures. This alignment with organisational structures makes it very clear who is responsible for which activity and which output. However there is a further point I want to make in the next slide that organisational structure and program structure should not always be mirror images of each other.
  • This slide is likely to be familiar to you. It is taken from the same source I refered to earlier. It is used as an example to say that the current structure needs to be redefined so that there are no programs which have many DGs. My apologies if people cannot read the detail. IT IS AN EXCELLENT START The point I want to make here is that organisational structures and program structures do not have to be perfectly aligned , and in some cases it would be a mistake to call the activities of a corporate nature (even though delivered by an Echelon 1) a “program”. Take the two examples in the bottom of the right hand column - item 11 “Training and Professional Education” and item 12 “Central Management and Direction”. Many of the activities in these items are corporate support activities for all the other programs listed above these items. It is clear, therefore, that this program structure will mean that not all expenditures will be distributed properly. This could become a significant problem, particularly for assessing program cost and efficiency. This is why “Management and Direction” (ie corporate support activities were recognised as an activity that contributes to the Program output and the outcomes desired by Government but is an activity managed elsewhere in the organisation) So my recommendation is that you maintain whatever organisational structure works efficiently for you BUT remember that supporting areas are inputs to other “programs”. The allocation of all costs to the relevant programs should be made if performance measures are to used. This allocation is not a difficult problem. For example, if 20% of the training and professional education is in respect of staff in DG Budgets, then for performance measurement attribute 20% of the costs to the Budget Management and Reform Program.
  • PERFORMANCE INDICATORS: The aim of using performance indicators is to demonstrate that an agency has addressed the government's requirements in an efficient way, demonstrating overall value for the community. There are two types of indicators used in Australia: Effectiveness indicators Effectiveness indicators reflect how effective the outputs are in achieving the outcome. Efficiency indicators Indicators of quantity, quality and cost reflect the efficiency of the department’s performance in delivering its outputs. Efficiency indicators will play a large role in managers decisions on how to allocate and in Parliament’s assessment of whether the funds have been properly managed to get the best result at least cost. If you can recall the 5 phases of development of a performance framework, these indicators will be limited in usefulness until Phase 3 – introduction of operational flexibilities – actually commences. Lets now look at some examples of indicators and how they relate to outcomes or government objectives
  • The first point to note from this slide is that the performance indicators for outputs relate to the outcome and its description. The objective of the Government from funding the activities of the Australian Department of Finance is to achieve sustainable government finances (i.e a sustainable fiscal environment that leads to confidence and growth in the economy). The description relates how the activities of the Department contribute towards assisting the Government to meet that objective and include: whole of government advice on expenditure and procurement policy; assisting the government prepare the Australian Government Budget; providing whole of government financial reporting The very first performance indicator is about how effective the activities of the Department are in assisting the government to meet its fiscal objective - the minister and the government must be satisfied with the quality, relevance and timeliness of our advice for Australian Government decision making. The other indicators about quantity, quality (including timeliness and accuracy) along with cost reflect the efficiency of the department’s performance. Accuracy is important because if the estimates of the deficit or surplus that the government is aiming for are wildly inaccurate the markets can lose confidence with adverse effects on the economy – such an outcome would be contrary to the aims of the Government. Let us now turn to Performance indicators for Indonesian activities, but before I do I would like to digress and pose a number of questions which could be used to assist you in determining whether you have chosen meaningful and useful outcome statements and performance indicators.
  • The task ahead for Indonesian agencies is to define their outcomes, outputs and performance indicators. From the Australian experience we know that outcome statements and performance indicators can require a great deal of thought and that sometimes we may not do it well. It helps however if we can pose a series of questions the answers to which will tell us whether we have done a good job or otherwise. In this and the next slide are some 7 questions that the designers of performance indicators should ask (this set of questions are taken from the guidance material included in your folders on how to set up a performance framework).
  • Let us now apply some of these questions to the KPI developed for the Ministry of Finance by the World Bank consultants. I should emphasise however these are hypothetical performance indicators that have not been endorsed by the Ministry of Finance.
  • Lets start with some KPIs defined by some consultants for the budget management and reform program but which have not been endorsed by DG Budgets. It is clear from this example that activities have been defined and performance measures for each of the activities have also been defined. This is a good start but can the designer of these performance indicators answer “yes” to all of the questions in the previous two slides? The very first question was “Is it possible to demonstrate the relationship between the indicators and the outcomes the Government wants?” The important point here is that if there is not clarity as to what the Government wants to achieve it is very difficult to define clear and meaningful performance indicators. What is apparent here is that the performance indicators fit loosely with the objective. Either there is a problem with the objective or a problem with the indicators or both.
  • These performance indicators are taken from the same source. Again they can be tested as they have not been endorsed by DG Treasury. Again the relevant question is whether the performance indicators shown here can generate a “yes” to all of the 7 questions shown in the previous slide. The other point I want to make is that d ifferent types of indicators serve different purposes. In selecting performance indicators agencies need to consider three basic principles about what to measure. These are:   What is most important to the agencies and its stakeholders, particularly the Government and Parliament, in terms of performance or ‘success’; What is useful for accountability, analysis and decision-making; and What is cost effective to collect and report at the time it is needed by stakeholders.   So the question is, are these performance indicators shown here useful measures, and are they the most important and if so to whom? Are they useful to program managers, or the Government and the Parliament? Do they indicate performance in terms of success? Are they useful in terms of decision making or program management or accountability? Should there be other measures? Remember, I said these are indicators developed by consultants but have not been officially endorsed by the Ministry of Finance. Perhaps if I were the DG Treasury I might find the per unit costs of disbursements made more useful than simply the number. Is the number of public service institutions managed a useful measure – is it useful for management, accountability or government decision making? Of course those who are in the best position to define performance indicators and to make the judgements against these type of questions are usually the agencies themselves, that is the Director Generals and their staff. But you also need some guidance to know if the indicators you have defined are the best – that is why using the check list in the earlier slides could be useful. I now want to turn to Step C in setting up a performance framework – that is defining targets
  • This slide shows how defining targets in your performance indicators can be useful measures of effectiveness. The examples here are those from the Customs Service in Australia which I would like to compare to KPI proposed for Indonesia in the recent work of consultants referred to earlier. The outcome stated in the Customs PBS is “Effective border management that, with minimal disruption to legitimate trade and travel, prevents illegal movement across the border, raises revenue and provides trade statistics”. From this slide it is clear that performance targets in relation to enforcement of border protection and revenues can be set. Similar targets ought to be possible for Indonesian Customs since the Government here would also want to protect its borders and facilitate the rapid processing of legitimate trade and passenger movements. Let us now look at the KPI defined for the Indonesian Customs Service by the consultants, particularly in terms of whether they specify targets or benchmarks.
  • This slide and the next slide show the activities that the consultants defined for the program “Customs and Excise Management” . The program objective has been defined in process terms rather than the aims of the government ie “to execute state laws and regulations on imports and exports and to collect related taxes”. A comparison with the previous slide might raise several questions. The striking feature of that comparison is that there are no measures in this slide or the next of targets. Moreover there is nothing in relation to targets for the quantity or quality of services provided to the public (i.e. Exporters, importers, passengers etc) in this list of Indonesian Customs performance indicators. So the question is why? Perhaps the measures are reflective of the stated objective, which is probably too narrow. Would the Indonesian government have objectives similar to the Australian Government of facilitating rapid clearances of trade and of people ( admittedly within the laws and regulations) as well as raising revenue?
  • In this slide there are some efficiency measures being proposed (remember when we looked at the DG Treasury KPI’s I said that for management purposes per unit costs of disbursements might be more useful than the number of disbursements). Here are some examples of per unit costs in the Customs area which were defined by the consultant. That is probably enough about outcomes, performance indicators targets etc. I want to acknowledge that this does require careful consideration and that building outcome statements and performance indicators is not easy, particularly if you start from the beginning. But, Indonesia should not re-invent the wheel. While I am not advocating that you adopt the Australian examples shown here, it is clear that a number of countries have defined performance measures for various agencies and that there may be some value in examining what has been done elsewhere when defining your outcomes, outputs and performance indicators. My advice is that after all your efforts to define performance indicators you should ask the question of whether they will be useful to you and your minister.
  • I have skipped Steps D and E which are about data collection and analysis and assessment. These are covered in the guidance provided. But I do want to talk about reporting. Under a Performance Based Budgeting system the reporting requirements for the Parliament and for Government and agency management will change from the current reporting frameworks. How they will change needs to be thoroughly thought through and dialogue with the Parliament and Government needs to occur to determine whether their requirements are being met under a new Performance Based Budgeting regime.   Agency management will need to consider its needs and prescribe their requirements through their instructions to staff. The Government’s requirements under a Performance Based Budgeting regime will need to be issued to agencies, ideally through the Minister for Finance. All the Australian examples I have shown you today come from documents submitted by the Agencies to the Parliament at the time of the Budget through their Portfolio Budget Statements . What I have shown you is only a fraction of the performance information that the parliament receives from the agencies. The Parliament looks at financial and non-financial performance information at the time of the Budget, additional estimates (mid year) and at the end of the year through annual reports. Nowadays Parliament is not really at all interested in the inputs (unless there has been abuse and misappropriation) but is much more interested in the delivery of outcomes and at the lowest cost (value for money). The power of the various reforms in Australia over the last 20 years is that the Parliament has received more and more relevant information on which to judge performance and to hold governments and bureaucrats accountable.
  • We saw in the previous sessions on the Australian experience that “operating cost flexibility” refers to flexibility that program managers were given to change the use of inputs within a “running cost budget” to maximise government services or to minimise costs. A number of the reforms were phased over time in Australia but the key elements were to group together the budgets for various inputs with the aim of giving more flexibility to managers to substitute between inputs. The “quid pro quo” required with increased flexibility was (1) increased accountability and (2) more efficiency, and this efficiency was taken through an annual efficiency dividend repaid to the Government. It also makes sense to phase operating cost flexibility with requirements for increased accountability. There are at least three phasesh Phase 1 - Introduction of concepts and training Define expenditures into running costs and non running cost expenditures Group like expenditures in groups Provide financial management and performance training Phase 2 – Introduce modest flexibilities and stronger reporting and accountability arrangements Introduce modest flexibilities for substitution of inputs within groups Introduce new reporting and accountability requirements Strengthen audit and monitoring arrangements Evaluate the reforms Phase 3 – Introduce greater flexibilities and refine reporting and accountability arrangements Rolling groups together into a smaller number of groups “ Property Operating”, “Repairs and Maintenance”, “Legal” and “Minor new capital” expenditures into “Running Cost Budgets” (early 1990’s); Amending laws: New financial management and audit acts to give greater powers to CEOs of Departments (mid 1990s); Replacing “Running Costs” with “Departmental” (end of 1990’s upon the introduction of accruals budgeting). Operating cost flexibility refers to flexibility that program managers were given to change the use of inputs within a “running cost budget” to maximise government services or to minimise costs. A number of the reforms of the late 1980’s and 1990’s refer to grouping together the budgets for various inputs aimed at giving more flexibility to managers to substitute between inputs. The “quid pro quo” required was accountability for more efficiency, and this efficiency was taken through an annual efficiency dividend repaid to the Government.
  • Getting started on the PBB reform agenda in Indonesia – a practical outline of the steps to be taken in setting up a framework

    1. 1. Getting started on the PBB reform agendain Indonesia – a practical outline of thesteps to be taken in setting up a framework Presented by Pat McMahon Budget Advisor, Australian Department of Finance and Deregulation
    2. 2. Aims of this session:• Examine some practical examples of how PBB could be applied here at the implementation stage. This is only the setting up stage.• This afternoon, after we have looked at MTEF, we shall start addressing the plan, and practicalities, involved in moving to a mature PBB
    3. 3. 5 phases in developing a performancebudgeting framework1. The “Set-up” stage of defining: – outcomes & programs – selection of indicators/specifying targets & benchmarks1. Financial management training2. Introduce operational flexibilities3. Introduce evaluation and monitoring4. Review and refine frameworks
    4. 4. Phase 1 - Six steps in “setting up” aperformance monitoring regimeThere are six basic steps to setting up a performance monitoring regime:A. Defining outcomes and programs for measurementB. Selecting indicatorsC. Specifying targets, benchmarks and reference pointsD. Data collectionE. Analysis & assessmentF. Reporting
    5. 5. Step A. Defining outcomes, programs andactivities – Examples from DG Budgets• Outcomes & Program structure – Government objectives needs to be defined along with the means (programs/outputs) necessary to achieve those objectives.• Be clear who is to be held responsible for performance – Alignment of program responsibility with responsible officers on the organization chart• Distribution of expenditures – All expenses need to be distributed among the various program activities that make up the program
    6. 6. Step A. Outcomes, Programs, Activities and Responsibilities– An Example Management and “Budget Management and Reform” Direction Program 1. Review of line ministry budgetsProgram Activities implement budget 4. Prepare annual monitor non-tax 3. Establish and 2. Develop and system reform summaries policy and collection budget Outcome/Objective:: To manage the state budget process to assure that the government’s goals and priorities are translated into annual budgets
    7. 7. Australian example and some similarities Fi g u r e: Ou t com e 1 – con t r i b u t i n g ou t p u t s
    8. 8. Distribution of all expenditures to programs Current Main Programs (8 )and DGs Proposed Programs (12) and DGs1. Revenue Increase and Fund Safeguarding 1. Budget Management and Reform ( DG Budget) DG Taxes Non-tax Revenue Increase and Fund Safeguarding DG Customs and Excises Budget System Implementation and Improvement DG Assets Management State Expenditure Effectiveness Secretary General 2. Debt Financing and Management (DG Debt)2. State Expenditure Effectiveness DG Budget 3. Fiscal Policy and Macro-economic Analysis (Fiscal Policy Board) DG Treasury Finance and Economic Stabilization DG Central-Local Fiscal Balance 4. Revenue Policy and Management (DG Tax)3. State Financial Accounting DG Treasury 5. Intergovernmental Fiscal Relations (DG Fiscal Balance)4. Financial Institutions Development 6. Customs and Excises Management (DG Customs) Capital Market and Financial Institutions Management Board Secretary General 7. Capital Market and non-Bank Financial Institutions Regulation (Capital Markets Board)5. Financial and Econmic Stabilization 8. Management of State Assets (DG Asset Management) Fiscal Policy Board Capital Market and Financial Institutions Management Board 9. Treasury Affairs (DG Treasury) State Financial Accounting6. Debt Financing and Management State Expenditure Effectiveness DG Debt Management 10. Inspector General7. Budget Systems Implementation and Improvement DG Budget 11. Training and Continuing Profesional Education DG Treasury 12. Central Management and Direction8. State Assets Management Tax Court DG State Assets Management Secretary General Public Accounts and Appraisal Regulation Supporting Programs (5) and DGs Center for IT Finanical System9. State Apparatus Accountability Center for Policy Harmonization10. Manpower Management11. State Apparatus Infrastructure12. State and Government Leadership13. In-Service Education Many DGs involved in each supporting program
    9. 9. Step B. Selecting performance indicatorsRemember performance indicators demonstrate that the governments requirements are met. There are two types of indicators:Effectiveness indicators – Effectiveness indicators reflect how effective the outputs are in achieving the outcome.Efficiency indicators – Indicators of quantity, quality and cost reflect the efficiency of the department’s performance in delivering its outputs.
    10. 10. Step B. Australian example ofperformance indicators for Budget outputs
    11. 11. In choosing output group indicators and targets,agencies should aim to answer ‘yes’ to all of thefollowing questions:1. Is it possible to demonstrate the relationship between the indicators and the outcomes the Government wants?2. Are the indicators easily understood by non-technical stakeholders?3. Are the indicators and targets: a Specific – clear, concise and precise; b Measurable – quantified; c Achievable – practical and reasonable; d Relevant – to stakeholders (including Government, Parliament, customers, beneficiaries); and e Time bound – related to a period of time or time limit?
    12. 12. In choosing output group indicators and targets,agencies should aim to answer ‘yes’ to all of thefollowing questions (continued):4. Do the indicators provide sufficient and balanced representation of actions taken, and goods and services delivered by the program/activity/service?5. Do the indicators adequately capture the intended relationship between Government programs/services and outcomes (or, if not, is there a robust means of monitoring and evaluating the contribution of Government programs/services to the outcome)?6. Will the results of measuring programs/services be available for evaluation and reporting in an appropriate form when needed for a reasonable cost?7. Is there a mechanism for review and revision of program/services measurement to ensure that it remains appropriate and sufficient for agency and Government needs?
    13. 13. Step B. Testing some early Performance Indicatorsdefined for Budget Management & Reform Outcome/Objective: To manage the state budget process to assure that the government’s goals and priorities are translated into annual budgetsActivity 1. Review of line ministry budgets• 1. Parliament adopts line ministry budgets with only minor changesActivity 2. Develop and Implement budget system reforms• 1. PBB implementation (no. of line ministries) / 2. MTEF implementation (no. of line ministries) / 3. PBB and MTEF guidelines issued and training provided to line ministriesActivity 3. Establish & monitor non-tax policy and revenue collection• 1. Actual non-tax revenues as a % of projectionsActivity 4. Prepare annual budget summaries• 1. Quality “I” accounts are produced in a timely manner
    14. 14. Step B. Performance indicators for DG Treasuryactivities – indicators serve different purposes:accountability, analysis and decision-makingActivity 1. Budget execution• 1. Annual number of disbursements made/ 2.Annual number of budget execution documents processedActivity 3. Financial management of public service institutions• 1. Number of public service institutions managedActivity 7. Financial accounting and reporting• 1. Annual number of financial accounting reports issued
    15. 15. Step C. Specifying targets, benchmarks & referencepoints – Examples from Australian CustomsOutput 2: Trade facilitation and revenue collection
    16. 16. Step C. Specifying targets, benchmarks &reference points – Testing of other earlierprepared indicators not endorsed by DG CustomsOutcome/objective: To execute state laws and regulations on imports andexports and to collect taxesActivity 1. Development of customs technical procedures• 1. Number of technical procedures revised and issued/Number of new technical procedures issuedActivity 2. Management and operation of customs facilities• 1. Number of individual facilities maintained and operated/Total square metres of facilities maintained and operated/Square metre cost of maintaining and operatingActivity 3. Excise policy and procedures• 1. Number of new or revised procedures issued
    17. 17. Step C. Specifying targets, benchmarks &reference points – testing of indicators continuedActivity 4. Enforcement and investigations• 1. Number of investigations initiated / 2. Number of investigations completed/ 3. Average cost per completed investigationsActivity5. Conduct of audits• 1. Number of audits initiated/ 2. Number of audits completed/ 3. Average cost per completed audits/ 4. Average number of completed audits per auditorActivity 6. coordination with international agencies• 1. Number of agreements concludedActivity 7. Preparation of customs and excise regulations• 1. Number of new and amended regulations issued
    18. 18. Step F. Reporting• Internal reporting for Agency Management – Management’s requirements ideally issued through the Chief Executive Officer of the Agency• External reporting for Parliament – Government’s requirements ideally issued through Minister for Finance
    19. 19. More this afternoon - Planning the introduction of“operating cost flexibilities” and revisedaccountability arrangements • Defining outcomes, programs and performance indicators is only the start. • Performance will be limited unless there is proper planning of operating cost flexibilities. The preliminaries before any reforms in this area must include: • Training • Defining running costs (where operational flexibilities are introduced) and non running costs (related to expenditures over which the Government has total control and where operational flexibilities cannot be applied) • Grouping costs within running cost to groups where flexibilities could be granted and planning the staging the degree of flexibility granted • Planning the audit, review and evaluation mechanisms to be used

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