Polverari, Laura (2011) The effectiveness of cohesion policy
implementation : conflicting accountabilities and
accountability/efficiency trade-offs. In: Regional Studies Association
Conference 2011, 2011-03-16 - 2011-03-18. ,
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The effectiveness of Cohesion policy implementation:
conflicting accountabilities
and accountability/ efficiency trade-offs
Laura Pol verari
1DRAFT
Not t o be quot ed or circul at ed wit hout t he aut hor’ s permission
RSA Conf erence
What f ut ure f or Cohesion pol icy?
An academic and pol icy debat e
Bl ed, Sl ovenia, 16-18 March 2011
1.
INTRODUCTION
Account abilit y is a fundament al element of cont emporary public policy and one of t he principles of ‘ good governance’ recognised by t he OECD, t he World Bank and t he European Commission (CEC, 2001; Harlow 2002; OECD, 2005; SIGMA, 1999). The concept of account abilit y has known an unint errupt ed rise in popularit y over t he past decade – bot h in policy-making and academia (Bovens, 2005, 2007 and 2010; Dubnick, 2002; Mulgan, 2003) – and it s significance has been furt her reinforced by t he recent economic downt urn and t he associat ed t ight ening of public finances. As a result , polit icians and policy-makers are increasingly sensit ive t o t he necessit y t o j ust ify t heir act ion on t he use made of scarcer and scarcer public resources, a use t hat needs t o be (or t hat , at least , needs t o be perceived t o be) relevant , j ust ified, efficient and effect ive.
However, t he pursuit of account abilit y is not t he primary aim of any public policy. The primary concern of polit icians and policy-makers is t he achievement of a policy’ s int ended goals, paramet erised on t he resources mobilised. Whilst some lit erat ure suggest s t hat cert ain t ypes of account abilit y can improve policy performance (Currist ine, 2005; Gormley and Balla, 2004), t here is wide consensus t hat t he pursuit of account abilit y and effect iveness can run count er each ot her and t hat ‘ at some point , account abilit y must begin t o yield diminishing ret urn and become count er-product ive’ (Mulgan, 2003, 236). Enact ing account abilit y ent ails cost s and can lead t o perverse effect s in t erms of policy achievement s and effect iveness (Gregory, 2007; Mulgan, 2003; Barberis, 1998).2
1
Senior Research Fellow, European Policies Research Cent re, Universit y of St rat hclyde (Glasgow) and Direct or of IQ-Net .
2
For inst ance, rendering public agent s risk-averse (Gregory, 2007) and inducing goal displacement (Mulgan, 2003).
This paper’ s key concern is t he account abilit y/ effect iveness t rade-off. This is a t opic t hat has surfaced ont o t he policy and academic debat e in t he early 2000s, suggest ing t hat government s and administ rat ions ‘ have become t oo focussed on input s and processes of administ ering public policies and have lost sight of t he out comes t hat t hey int end t o achieve’ (Talbot , 2005, p. 500). The paper addresses t his t heme in t he cont ext of European Cohesion policy, i.e. t he ext ent t o which t he account abilit y mechanisms in place in t his cont ext are indeed inst rument al or det riment al for t he policy’ s abilit y t o achieve it s int ended goals.
This focus is j ust ified by at least t wo main reasons: because Cohesion policy has been ext ensively crit icised for it s lack of effect iveness (or lack of definit ive evidence of t his) as well as for it s overwhelming emphasis on input s and procedures, and because t his policy present s part icular feat ures t hat have rendered formalising account abilit y mechanisms paramount , in order t o avoid ambiguit ies regarding which act or has responsibilit y over which aspect s of t he policy. They are: (i) t he fact t hat Cohesion policy rest s on t he principle of ‘ shared management ’ (art . 274 TFEU and art . 14 of t he General Regulat ion) according t o which t he European Commission and Member St at e aut horit ies j oint ly share t he overall responsibilit y for it ; (ii) t he fact t hat policy implement at ion is charact erised by a mult i-level allocat ion of t asks, wit h a large proport ion of t he resources managed direct ly by meso-level aut horit ies wit hin t he Member St at es, in line wit h t he so-called subsidiarit y principle; and, last ly, t he fact t hat part ners and st akeholders are involved (or at least should be) in t he processes of policy implement at ion, as dict at ed by t he so-called part nership principle (enforced by art icle 11 of t he General Regulat ion, Council Regulat ion no. 1083/ 2006, 11 July 2006).3
These feat ures have made it necessary t o codify account abilit y relat ions in t he field of Cohesion policy. As a result , account abilit y is explicit ly foreseen in t he Treat y on t he Funct ioning of t he European Union and in t he Regulat ions t hat govern t he policy (St ruct ural Funds General Regulat ion, Fund-specific regulat ions and t he EU financial regulat ion).4 These address account abilit y from bot h an inst it ut ional and an operat ional perspect ive.
From an inst it ut ional perspect ive, t hey provide a clear definit ion of roles bet ween all of t he aut horit ies involved in t he policy: bet ween European Commission, Member St at es, European Court of Audit ors and European Parliament , wit h regard t o agenda set t ing, policy
3 Besides, Cohesion policy is no except ion t o t he above not ed t rend regarding t he rise of t he
import ance of t he not ion of account abilit y: it is not by chance t hat t he last European conference on t his policy’ s evaluat ion, in December 2009, was cent red on “ promot ing account abilit y and learning” (Warsaw, 30 November/ 1 December 2009). As point ed out elsewhere, t his increasing emphasis on account abilit y in Cohesion policy has been linked t o t he wider t heme of t he account abilit y of t he governance and policies of t he European Union, following t he scandals of t he Sant er Commission and t he increasingly polarisat ion of net budget ary posit ions amongst Member St at es following enlargement (Davies and Polverari, 2011). It is also t he result of a wider move wit hin t he EU t owards “ good governance” (CEC, 2001; Harlow 2002; OECD, 2005; SIGMA, 1999).
4 Regulat ion (EC) No. 1083/ 2006 of t he Council of 11 July 2006; Regulat ion (EC) No. 1080/ 2006 of t he
European Parliament and of t he Council of 5 July 2006 on t he European Regional Development Fund and repealing Regulat ion (EC) No. 1783/ 1999; Regulat ion (EC) No. 1081/ 2006 of t he European Parliament and of t he Council of 5 July 2006 on t he European Social Fund and repealing Regulat ion (EC) No. 1784/ 1999; and, Council Regulat ion (EC) No. 1084/ 2006 of 11 July 2006 est ablishing a Cohesion Fund and repealing Regulat in (EC) No. 1164/ 94.
formulat ion, oversight and overall policy responsibilit y, and, at a more operat ional level, bet ween Managing Aut horit y, Cert ifying Aut horit y, Audit Aut horit y, nat ional coordinat ing aut horit ies and European Commission, wit h regard t o policy delivery.
From an operat ional perspect ive, t his legislat ive framework est ablishes t he rules and procedures t hat must be complied wit h in policy implement at ion, in part icular wit h regard t o t he involvement of part ners in programme design and implement at ion (art . 11 of t he General Regulat ion), monit oring and report ing (art icles 63-68 and 29-31), evaluat ion (art icles 47-49); financial management (art icles 15, 52-62, 70-102) and t he communicat ion t o pot ent ial beneficiaries and t o t he public (art . 69). As a result of t his comprehensive legislat ive framework wit hin Cohesion policy t here is a st rong emphasis on account abilit y, especially financial and procedural t ypes of account abilit y. This emphasis has however generat ed t he sort of perverse effect s denounced by Mulgan (2003) and Gregory (2007) wit h regard t o effect iveness; for inst ance, an overemphasis on spending per se as opposed t o spending on t hose proj ect s t hat are best suit ed t o deliver t he programmes’ goals (Bacht ler
et al , 2009; Davies and Polverari, 2011).
This paper aims t o assess t he account abilit y/ efficiency t rade-off wit hin Cohesion policy and t he causes for t his focusing on t he second of t he above t wo aspect s, i.e. t he rules and procedures t hat inform t he policy’ s operat ional processes. It addresses t he following key quest ions:
• What is the nature of accountability in the framework of Cohesion policy? Specifically, what t ypes of account abilit y are pursued in t he management and implement at ion of Cohesion policy?
• Are different types of accountability – notably financial, procedural, outcome and performance account abilit y - pursued t o t he same degree?
• Does the pursuit of accountability and, more specifically, of different types t hereof, run count er t he effect ive pursuit of t he policy’ s overarching aims and of programmes’ goals?
• What lessons can be drawn for the reform of the policy for the period 2014-2020? The cent ral t hesis of t his paper is t hat different t ypes of account abilit y are not pursued t o t he same degree, due t o t he different level of ‘ cogency’ associat ed wit h different processes. This in t urn is due t o t he sanct ions associat ed wit h t hese and t heir relat ed ‘ hardness’ . The paper argues t hat t he exist ence of such different degrees of cogency for t he different policy processes det ermines a dist ort ion in t he balance achieved in t erms of t he pursuit of financial and procedural account abilit y over out come and performance account abilit y, and in t erms of t he pursuit of account abilit y over effect iveness.
This t hesis is put t o t he t est in t he following sect ions. Sect ion 2, discusses t he concept of account abilit y and it s operat ionalisat ion in t he cont ext of Cohesion policy; Sect ion 3 assesses t he degree of cogency associat ed wit h each of t he processes reviewed, discussing t he sanct ions in place for each and t he implicat ions t hat t he st ronger or weaker cogency have for t he account abilit y/ effect iveness t rade-off; last ly, Sect ion 4 present s some
conclusions which link t he evidence produced on t he dist ort ive effect of incoherent levels of compliance wit h t he debat e on t he reform of t he policy and t he proposals cont ained in t he Fift h Cohesion Report .
2.
DEFINING ACCOUNTABILITY IN THE CONTEXT OF
EUROPEAN COHESION POLICY
The t opic of account abilit y has been t he subj ect of abundant lit erat ure. One element of consensus in t his wide lit erat ure – and perhaps t he only one - is t hat account abilit y is a word of mult iple meanings (Day and Klein, 1984; Oliver, 1991; Bovens, 2005 and 2007; Dowdle, 2006; Dubnick, 2002; Mulgan, 2000 and 2003; Koppell, 2005). Beyond t he generic definit ion of “ liabilit y t o give account of, and answer for, discharge of dut ies or conduct ” (Oxford English Dict ionary), account abilit y has amongst ot hers been defined as
“ being liable t o be required t o give an account or an explanat ion of act ions and, where appropriat e, t o suffer t he consequences, t ake t he blame or undert ake t o put mat t ers right if it should appear t hat errors have been made” (Oliver, 1991, p. 22);
as
“ a relat ionship bet ween t wo set s of persons or (more oft en) organizat ions in which t he former agree t o keep t he lat t er informed, t o offer t hem explanat ions for decisions made, and t o submit t o any predet ermined sanct ions t hat t hey may impose. The lat t er, meanwhile, are subj ect t o t he command of t he former, must provide required informat ion, explain obedience or disobedience t o t he commands t hereof, and accept t he consequences for t hings done or left undone.” (Schmit t er, 2004, p. 47);
and, more succinct ly, as
“ a relat ionship bet ween an act or and a forum, in which t he act or has an obligat ion t o explain and t o j ust ify his or her conduct , t he forum can pose quest ions and pass j udgement , and t he act or may face consequences” (Bovens, 2007, p. 450).
As t he above definit ions highlight , account abilit y relat es essent ially t o t he relat ionship bet ween t wo act ors or groups t hereof: t hose who are account able for t heir conduct , i.e. t he decision-makers (Held, 2004), account ors (Mulgan, 2003), or account abilit y-holdees (Papadopoulos, 2007), on t he one hand, and t hose t o whom account abilit y is best owed, i.e. t he decision-t akers (Held, 2004), ‘ account ees’ (Mulgan, 2003), and ‘ account abilit y holders’ (Papadopoulos, 2007), on t he ot her. Thus, account abilit y st ems from t wo key principles (Mulgan, 2003, pp. 12-13): t he delegat ion, principal-agent principle and t he affect ed right s principle. The first principle declares t hat when one act or (agent ) act s on behalf of anot her (principal), t he former has t he obligat ion t o ensure t hat t heir act ions or inact ions are in line wit h t he preferences expressed by t he lat t er. Conversely, t he principal has t he right and facult y t o call and hold t he agent t o account for her behaviour. The second principle, on t he ot her hand, places an obligat ion on any public agent (and indeed, more broadly, any
cit izen) t o be responsible for her act ions or inact ions t hat have an impact on a second part y, even out wit h a delegat ion, principal-agent relat ionship.
As such, public account abilit y is part icularly complex and oft en concealed, because of t he dispersed nat ure of act ors and forums at bot h ends - t he account abilit y holders, on t he one hand, and t he account abilit y holdees, on t he ot her - and because of t he lack of a clear-cut principal-agent relat ionship bet ween t he t wo groups in many cases.
In t he framework of Cohesion policy, such complexit y is exacerbat ed by t he shared management principle, and by t he mult i-level nat ure and part nership-orient at ion of t he policy. A considerable body of lit erat ure exist s on t he challenges posed t o account abilit y by mult i-level and net worked governance arrangement s (Piat t oni, 2010; Bache and Chapman, 2008; Benz et al 2007; Harlow and Rawling, 2007; Papadopoulos, 2007; Bache and Flinders, 2004; Rhodes 2003) and much of t his can be applied t o t he assessment of account abilit y in t he cont ext of Cohesion policy. It point s t o t he following main problems:
• first, the problem of ‘ many hands’ , i.e. the difficulty to attribute decisions to any specific act or (Bovens, 2007; Piat t oni, 2010);
• second, the reduced role of hierarchical relations in the organisational arrangement s t hat govern policy-making in mult i-level set t ings, ent ailing t hat “ t he assumpt ion of inst it ut ional hierarchy which underpins so many discussions of bureaucrat ic account abilit y no longer holds” (Rhodes, 2003, pp. 58-59); and,
• lastly, the ‘ uncoupling from the democratic circuit’ of decision making-procedures (Papadopoulos, 2007, 470), which in Cohesion policy is exacerbat ed by t he high t echnicalit y of t he procedures t hrough which t he policy is implement ed (which ent ails t hat a considerable degree of decision-making rest s on unelect ed t echnocrat s at t he mult iple levels t hat t he policy int ersect s).
All of t hese element s can make it challenging t o est ablish: (i) who has t he responsibilit y over policy-decisions and act ions; (ii) who should be quest ioned on t he appropriat eness of such decisions and act ions, and approached t o seek redress; and, (iii) who should be sanct ioned for incorrect conduct . Alt hough t he TFEU and St ruct ural Funds regulat ions address t hese issues in great det ail, as discussed in int roduct ion, t he paper quest ions whet her t hese rules, and t he ensuing pract ices, present grey areas which ent ail t hat t he account abilit y pursued in Cohesion policy management and implement at ion is part icularly geared t owards cert ain t ypes of account abilit y, ult imat ely hindering policy effect iveness.5
To assess whet her t his is t he case, t he analysis focuses on a wider definit ion of account abilit y t han t hose provided above – which includes also t he ex ant e phase of account abilit y, i.e. t he decision-making st ages and t he part icipat ion of account abilit y holders in t hese – and on a dist inct ion of account abilit y t ypes based on t he ‘ obj ect ’ of
5 Thus a key quest ion of t his paper is not whet her such inst it ut ional set -up and operat ional rules are
effect ive as account abilit y t ools, but whet her t hey are indeed inst rument al or det riment al for t he policy’ s abilit y t o achieve it s int ended goals.
account abilit y, i.e. bet ween financial, procedural, out come and performance account abilit y. The definit ion adopt ed of account abilit y is t he following:
a part icular t ype of relat ionship bet ween t wo act ors or groups, decision-makers and decision-t akers, where t he first act s on t he second’ s behalf, or where t he first , because of it s act ions or inact ions, det ermines an impact upon t he second. For t he relat ionship bet ween t hese t wo groups t o be one of account abilit y: (i) decision-t akers must be able t o inform t he decision-makers’ choices; (ii) decision-makers must be prepared t o give account of t heir choices (act ions and inact ions) and of t he out comes of such choices (wit h respect t o a pluralit y of aspect s of t heir act ivit y, ranging from t he use made of input s t o t he performance achieved); and (iii) decision-t akers must have t he facult y t o express dissat isfact ion and request changes t o t he course of act ion adopt ed. Enforcement and sanct ioning mechanisms must be in place t o ensure t hat t he correct course of act ion is rest ored where necessary and t o act as a det errent for account abilit y failings in fut ure. (Polverari 2011, based on Mezlev, 2003; Mulgan, 2003; and, Held, 2004).
This definit ion acknowledges explicit ly t hat for t akers t o be able bring decision-makers t o account , t here needs t o be recognit ion t hat t he recipient s of t his account -giving act ivit y (t he policy-t akers) ought t o have t he opport unit y t o part icipat e in defining what is meant by appropriat e act ion and t hat t his opport unit y must be inst it ut ionalised. This is because implicit assumpt ions of what t he right course of act ion might be may lend t hemselves t o fallacy (Polverari, 2011). Wit hin Cohesion policy t his is enshrined in t he part nership principle. The proposed definit ion also acknowledges t he necessit y of enforcement t ools and sanct ioning mechanisms t o ensure t hat account abilit y is fulfilled, not j ust so as t o rect ify undue act ion, but also t o act as a det errent t o wrong-doing (Papadopoulos, 2007, p. 471).
As ant icipat ed, t he analysis focuses on four part icular t ypes of account abilit y:
(i) Financial account abil it y “ concerns t racking and report ing on allocat ion, disbursement and ut ilizat ion of financial resources, using t he t ools of audit ing, budget ing and account ing” (Brinkerhoff, 2004; also Bovens, 2007);
(ii) Procedural account abil it y relat es t o t he correct compliance of t he act s and procedures put in place for policy delivery wit h t he relevant administ rat ive law, st andards and codes of pract ice (such as t he observance of public procurement and t endering rules for proj ect select ion and of report ing and monit oring obligat ions) (Bovens, 2007);
(iii) Out come account abilit y relat es t o t he out comes achieved, not ably t he out put s, result s and, where t hese can be est ablished, t he impact s of t he int ervent ions (MEANS, 1999);
(iv) Perf ormance account abilit y pert ains t o t he performance of t he policy, assessed on t he out comes achieved or t heir achievabilit y (when assessed ex ant e or in it inere) cont rast ed t o t he goals set . In ot her words, t hat which relat es “ t o demonst rat ing and account ing for performance in light of agreed-upon performance t arget s” (Brinkerhoff, 2004, pp. 374).
3.
DIFFERENT TYPES OF ACCOUNTABILITY PURSUED IN THE
MANAGEMENT AND IMPLEMENTATION OF COHESION
POLICY: DIFFERENT POLICY PROCESSES, DIVERGING
DEGREES OF COGENCY AND COMPLIANCE
Defined as above, account abilit y is fulfilled across all st ages of t he policy cycle. This paper focuses on t he most relevant ones in t erms of t heir pot ent ial impact on effect iveness, not ably t he st ages of: (i) st rat egy formulat ion and programme design (in part icular t hrough t he part icipat ion of part ners and st akeholders in t his); (ii) monit oring and report ing; (iii) evaluat ion; and, (iv) financial management .
3.1
Involvement of partners and stakeholders in policy-making
The involvement of part ners and st akeholders in policy-making processes is required by art . 11 of t he General Regulat ion. This art icle foresees t he involvement of socio-economic part ners, represent at ives of civil societ y, environment al part ners, non-government al organisat ions, bodies responsible for promot ing equalit y bet ween men and women in all st ages of programme design and delivery: from t he preparat ion, t o t he implement at ion (inst ead of ‘ financing’ as previously), monit oring and evaluat ion of Operat ional Programmes.
The involvement of part ners and st akeholders in policy-making could have a marked effect on bot h account abilit y – in all t he facet s above discussed, bot h ex ant e and ex post – and effect iveness. First , it can improve t he responsiveness of programmes (t he ex ant e t ype of account abilit y), by bet t er aligning st rat egies wit h policy needs. Second, it can increase t he effect iveness of programmes by allowing Managing Aut horit ies t o access knowledge which is used t o improve t he t arget ing of int ervent ions, consequent ly improving funding up-t ake and proj ect qualit y. And t hird, it can cont ribut e t o improved ex post account abilit y, insofar as t he part ners, as organised represent at ions of int erest s, act as a t ransmit t er and mult ipliers of programme informat ion t o t heir const it uencies (t hus increasing t ransparency and informat ion) and hold programme aut horit ies t o account for t he act ion t aken, t he way resources are spent , and t he result s achieved (Polverari and Michie, 2009 and 2010).
This said, t here is a considerable gap bet ween t heory and pract ice. The degree of cogency of t he part nership-relat ed regulat ory requirement s is weak: beyond t he preamble t o t he regulat ion and t he specific art icle on t he part nership principle, t here is very lit t le ment ion of part ners or part nership t hroughout t he operat ional sect ions of t he regulat ory t ext s. No precise and formally binding inst ruct ions or guidance have been provided t o programme managing aut horit ies on how t he principle should be applied in pract ice at different st ages or funct ional t asks of t he policy process, aside from t he loose references t o t he need for part ners t o be consult ed on t he NSRF and for OPs t o be drawn up in coordinat ion wit h part ners. This leaves t he act ual int erpret at ion of how t o comply wit h Art icle 11 t o domest ic aut horit ies and t hus t he implement at ion of t he part nership principle reliant on domest ic t radit ions and pract ices (Polverari and Michie, 2009 and 2010).
In addit ion, no real sanct ioning mechanisms – or even inducement s – are foreseen t o st imulat e compliance. Thus, unsurprisingly, compliance wit h art . 11 varies markedly across Europe, depending on domest ic cult ures and pract ices, and, on t he whole remains oft en weak (Polverari and Michie, 2009 and 2010).6 As in t he past periods, part ners are generally more involved in programme design t han in t he ot her processes of programme management , and even in programme design t here are asymmet ries in t he act ual ‘ weight ’ of different part ners and cont rast ing evidence on part ners’ influence in set t ing programme st rat egies.
To furt her reinforce t he assessment t hat t he involvement of part ners and st akeholders in programme management is not part icularly effect ive as a t ool of account abilit y is t he finding of a recent st udy t hat despit e some evidence of inclusion of socio-economic and non government al part ners in evaluat ion processes for example (e.g. t hrough consult at ions for t he draft ing of t he Evaluat ion Plans, evaluat ion St eering Groups, disseminat ion act ivit ies), t hese act ors do not generally appear t o hold Managing Aut horit ies t o account on t he use t hat has been made of resources and t he out comes achieved. Part ner input is concent rat ed in t he init ial st ages of programme design and somet imes in proj ect generat ion/ select ion. Very lit t le int erest (or at least act ivit y) was det ect ed on part ners being involved in assessing programme achievement s, and why cert ain expect ed impact s have not been achieved. This is part of a wider concern wit h t he degree t o which programme aut horit ies and part nership fora (such as t he Programme Monit oring Commit t ee) are giving sufficient at t ent ion t o t he performance of t heir programmes and t he policy as a whole (Polverari and Michie, 2009 and 2010).
3.2
Monitoring and reporting
The regulat ions place considerable monit oring and report ing obligat ions on Managing Aut horit ies, Member St at e aut horit ies and t he European Commission (art . 63-68 and 29-31 of Gen. Reg.). They include t he obligat ions:
• for Managing Authorities, to establish and implement monitoring systems able to t rack financial and physical dat a (in many cases also procedural informat ion) and t o submit annually Implement at ion Report s t o t he European Commission;
• for Member State authorities, to prepare twice over the course of the programme period a “ St rat egic Report ” out lining t he progress being achieved t owards t he goals of t he policy as est ablished by t he Treat y (art . 174 TFEU), t he priorit ies
6 Even t he St rat egic Report produced by t he Commission in 2010 not ed delays in some Member St at es
wit h t he set t ing up of t he procedures t o enable t he part icipat ion of part ners and st akeholders in t he programming processes (European Commission, Communicat ion f rom t he Commission t o t he European Parliament , t he Council, t he European Economic and Social Commit t ee and t he Commit t ee of t he Regions, Cohesion pol icy: St rat egic Report 2010 on t he impl ement at ion of t he programmes
out lined in t he Communit y St rat egic Guidelines, t he goals of t he Lisbon agenda and t he administ rat ion of t he funds (based on a st ruct ure provided by DG Regio).7
In principle, t hese obligat ions are int ended t o fulfil all t ypes of account abilit y and t hey do so t o a significant degree. There are, however, some short comings in t he effect ive realisat ion of t hese t asks. Not wit hst anding considerable improvement s made over programme periods (Bacht ler et al, 2009), monit oring syst ems are st ill most ly focussed on financial rat her t han physical indicat ors and geared t owards t he reaching of N+2 t arget s. Limit at ions and difficult ies are being faced by programme Managing Aut horit ies wit h t he t racking of physical indicat ors, especially where programmes are large and composit e, and involve delegat ion of delivery responsibilit ies t o Implement ing Bodies, wit h t he consequent scope for diverging int erpret at ions and errors. The int ended rat ionalisat ion of indicat ors’ syst ems announced at t he beginning of t he programme period has been achieved only in part and various programme aut horit ies are current ly engaged wit h a revision and simplificat ion of t heir syst ems. Halfway int o t he programme period, t here are st ill OPs whose monit oring syst ems are st ill not fully operat ional (Vironen, 2010, pp. 17-18). From a EU-wide perspect ive, t here is st ill wide variat ion across programmes wit h regard t o t he indicat ors used t o t rack physical out comes (Mendez et al, 2010), which for t his period are only provided at t he level of priorit ies rat her t han measures.
Useful informat ion on financial, procedural and even (limit ed) physical progress can generally be found in t he Annual Implement at ion Report s (AIRs) which present meaningful overviews of programme process. The AIRs are now also required t o provide “ t he indicat ive breakdown of t he allocat ion of funds by cat egories...” (art 67 General Regulat ion), however evidence suggest s t hat not all programmes provide t his t ype of informat ion and even when t hey t ry t o do so, t hey are faced wit h met hodological difficult ies ent ailed by t he ambiguous descript ion of t he codes, which means t hat t he expendit ure under t he same proj ect or measure could be allocat ed t o different codes (Mendez et al , 2010).
Last ly, t here is widespread consensus in t he policy communit y t hat t he 2009 st rat egic report ing exercise has been disappoint ing, wit h it s limit ed act ual ‘ st rat egic’ cont ent and t he rigidit y ent ailed by t he checklist produced by t he European Commission. Import ant ly, whilst t hese report s were supposed t o include informat ion on out put and result s indicat ors, many did not provide any quant it at ive informat ion or qualit at ive assessment of t hese and, whilst t he Commission request ed dat a on t he core indicat ors t o t he nat ional aut horit ies, only half of t hese complied wit h t his request (Mendez et al , 2010, p. 23).
For all t he above processes, t he enforcement can be considered medium, in t he sense t hat compliance is on t he whole ensured but in a pat chy manner and in some cases in more formal t han subst ant ive t erms.
7
In addit ion, for t he European Commission t o submit annual progress report s, synt heses of t he Member St at es’ St rat egic Report s, and periodic “ Cohesion Report s” t o t he Council (art . 175 TFEU).
3.3
Evaluation
The regulat ions foresee a number of obligat ions placed upon different aut horit ies wit h regard t o evaluat ion. Evaluat ion comprises ex ant e evaluat ion, aimed at set t ing programme goals and realist ic t arget s (art . 48(2) of t he General Regulat ion); ongoing evaluat ion, generally int ended as a set of more or less int egrat ed t hemat ic evaluat ions (somet imes complement ary t o int erim st ock-t aking evaluat ive exercises) during t he programme period (Polverari et al, 2007) (art . 48(3)); and, ex post evaluat ion, carried out at t he end of each programme period (art . 49(3)). All t hree t ypes of evaluat ion should in principle fulfil various t ypes of account abilit y. In pract ice, however, t hey all present short comings as inst rument s for account abilit y.
Ex ant e evaluat ion is carried out “ under t he responsibilit y of t he aut horit y responsible for
t he preparat ion of t he programming document s” (art . 48(2)(4)).8 It could be a t ool for financial, out come and performance account abilit y, given t hat it s purpose is t o est ablish t he paramet ers for polit icians and policy-makers on what policy act ion should set out t o achieve. However, a recurring crit icism t o ex ant e evaluat ion, echoed also in t he Fift h Cohesion Report , is t hat more oft en t han not ex ant e evaluat ion is carried out in parallel rat her t han before programme preparat ion, and t hat , rat her t han providing evidence for st rat egy set t ing and programme design, it oft en simply ‘ j ust ifies’ choices t hat have already been pre-made by polit icians and programme-managers (see also Bacht ler et al , 2009). In RCE areas, t he subsuming of Cohesion policy programme wit hin broader domest ic st rat egies in t he current period has furt her limit ed t he subst ant ial nat ure of ex ant e evaluat ions.
In pract ice, t herefore, ex ant e evaluat ion serves as an inst rument for bot h account abilit y and effect iveness only t o a limit ed degree (e.g. providing t ransparency/ informat ion). Alt hough t he compilat ion of ex ant e evaluat ions is required by t he regulat ions, and not wit hst anding a t heoret ical scrut inising role fulfilled by DG Regio’ s Evaluat ion Unit , in realit y t he scope for t he European Commission t o check t he merit of such exercises and seek rect ificat ion on bot h t he evaluat ions and t he programmes is limit ed, and t he t imet able for programme preparat ion is generally such t hat t he evaluat ions (and t he Commission’ s checks) are not able t o subst ant ially influence t he cont ent of programmes.9 In ot her words, enforcement for t his t ype of pot ent ial account abilit y t ool is ‘ soft ’ and, as a result , compliance varies depending on domest ic cont ext and t he possible exist ence, in t he Member St at es, of supplement ary enforcement t ools (e.g. where domest ic evaluat ion unit s
8
For programmes under t he Convergence obj ect ive, t he regulat ions recommend t hat ex ant e evaluat ions be carried out for each OP. For t he ot her t wo obj ect ives, Member St at es can decide whet her t o undert ake evaluat ions for individual programmes, groups of programmes, t hemes or Funds).
9
This quot e, from t he final report of t he recent ex post evaluat ion of 2000-2006 ERDF programmes is illust rat ive of t his: “ There was also a lack, in many cases, of a clear indicat ion in concret e t erms of t he obj ect ives of t he policy implement ed in a form which would enable t he success or failure of t he measures t aken t o be properly assessed. Oft en t he aims of t he policy were expressed in t erms so general (e.g. an improvement in regional compet it iveness) t o make it difficult , if not impossible, t o j udge aft er t he event whet her t hey were achieved or not . Though quant it at ive t arget s were oft en set and an indicat or syst em est ablished, as required by t he St ruct ural Fund regulat ions, in many cases neit her were linked in a meaningful way t o ult imat e policy obj ect ives.” (Ward and Wolleb, 2010, p. 10).
‘ push’ t he domest ic aut horit ies t o pursue a more subst ant ial compliance). On t he whole, t he available evidence suggest s t hat t he ext ent t o which ex ant e evaluat ion fulfils an account abilit y funct ion is weak (except as an addit ional t ransparency t ool).
Ongoing evaluat ion is foreseen by art . 48(3). This art icle is mast erfully vague, however. This vagueness was part offset by t he guidelines published in April 2007 by t he European Commission which were also not prescript ive, considerably wide-ranging and open t o int erpret at ion, allowing for significant room for manoeuvre for t he Managing Aut horit ies in t he Member St at es. In principle, such t ype of evaluat ion can fulfil anyone of t he above list ed account abilit y t ypes. The ext ent t o which it does so depends on t he int erpret at ion t hat is given domest ically of t his t ype of evaluat ion given t hat in principle, according t o t he guidance formulat ed by t he Commission, programme Managing Aut horit ies could cover virt ually any aspect of t he programmes.10 Evidence gat hered t hrough t he IQ-Net research programme shows t hat ongoing evaluat ion is being int erpret ed eit her as a succession of t hemat ic st udies (planned, ad hoc and a mixt ure bet ween t he t wo), or as an int egrat ion bet ween t hemat ic st udies and comprehensive mid-t erm evaluat ions similar in scope t o t hose carried out in t he past programme period (Polverari et al, 2007, p. 35). Whilst t he degree of enforcement is soft (given t hat t here are no real cont rols or sanct ions associat ed wit h t he delivery of poor evaluat ions where t hese are accept ed by t he programmes Managing Aut horit ies), t he earmarking of programme resources for t his purpose (under t he t echnical assist ance budget ) has meant t hat programme aut horit ies do carry out t heir ongoing evaluat ions. However, lit t le research has been carried out on t heir comparat ive overall qualit y; t hey appear t o generally focus predominant ly on financial expendit ure and procedural issues (so as t o support absorpt ion maximisat ion and prevent N+2); and, have been crit icised for lack of independence and real ‘ crit ique’ (Polverari and Vit ale, 2010). The ext ent t o which ongoing evaluat ions fulfil an account abilit y funct ion is t herefore on t he whole probably rat her limit ed.
Last ly, ex post evaluat ion is carried out by t he Commission in cooperat ion wit h t he Member St at es (art . 49(3)(1)). It is int ended t o assess t he ext ent t o which programme resources were used (financial account abilit y), t he effect iveness and efficiency of t he programmes and t heir socio-economic impact s (out come and performance account abilit y) (art . 49(3)(2)). In realit y, t he ext ent t o which ex post evaluat ions have been able t o assess t hese element s in t he last t wo programme period can be quest ioned. For t he 1994-99 period, t he approach t aken was a comprehensive one, whereby all programmes were covered and evaluat ors were asked t o capt ure t he programme effect s on t he whole range of policy areas and priorit ies ent ailed by t he programmes. However, t his degree of generalit y led t o an equally general set of findings, which lent t he evaluat ion t o crit icism. As a result t he approach t aken for t he evaluat ion of t he past programmes has been one of increased select ivit y, based on select ed core t hemes explored largely t hrough case st udies. The ext ent t o which t hese exercises have fulfilled an account abilit y funct ion has been limit ed,
10 Working Paper 5 suggest s t hat evaluat ions focus on t he relevance, consist ency, effect iveness
and/ or efficiency of t he programmes which would mean financial, procedural, out come and performance account abilit y. The exact focus, however, is left t o t he discret ion of t he Managing Aut horit ies.
however. First , whilst t his EU-wide approach is useful t o gauge a macro-pict ure of achievement s, t here has been only very limit ed assessment of impact s. Let us consider, for example, t hat alt hough art . 43 of t he General Regulat ion for t he 2000-2006 period (Reg. No. 1260/ 1999) st at es t hat t he ex post evaluat ions need t o be complet ed by no lat er t han t hree years aft er t he end of t he programming period, t he work relat ing t o t he ex post evaluat ion of t he 2000-06 mainst ream ERDF OPs, on t he cont rary, was concluded in April 2010, wit h evaluat ion work being carried out bet ween 2007 and 2009, even prior t o t he official closure of t he programmes.11 And indeed, t he synt hesis report of t he whole evaluat ion exercise is very caut ious about t he pot ent ial of t he work t o assess impact s:
“ The cont ext in which cohesion policy was implement ed, t he oft en small scale of t he funding in relat ion t o t he forces it was int ended t o count eract and t he many ot her fact ors at work mean t hat it is unrealist ic in most cases t o expect t o be able t o t race a direct link bet ween policy and regional development s. This is all t he more so in view of t he oft en lengt hy t ime lags involved bet ween measures being implement ed and having a discernible effect on development s.” (Ward and Wolleb, 2010, p. 10, emphasis added).
Thus, it could be deduct ed t hat t he current round of ex post evaluat ion was carried out more for polit ical purposes, and t o support t he preparat ion of t he Fift h Cohesion Report , rat her t han t o assess t he use made of funding, t he impact s achieved and t he effect iveness of support . Second, t he fact t hat t he Commission-driven ex post evaluat ion are being by and large not supplement ed by programme-specific ex post evaluat ions does not allow drawing an assessment of t he result s, impact s, efficiency and effect iveness achieved wit hin specific programmes. Since t he Regulat ions do not foresee t his t ype of obligat ion for programme Managing Aut horit ies t his is hardly ever done. In summary, t here is limit ed evidence t o suggest t hat evaluat ion is an effect ive t ool for account abilit y, especially wit h regard t o out come and performance account abilit y.
3.4
Financial management
A crucial aspect of t he programme management process is represent ed by t he efficient financial management of programmes. This embraces t he whole financial cycle of t he programmes, from t he processing of payment claims of final beneficiaries, t o t he payment declarat ions t o t he European Commission and t he lat t er’ s annual account s t o t he European Parliament . Not least in response t o scandals wit h t he use of European resources, bot h in general and wit hin Cohesion policy specifically (Davies and Polverari, 2011), financial management is t he most regulat ed of all programme management processes, wit h a large number of art icles of t he General Regulat ions devot ed t o different aspect s of t his. It is also t he process which present s t he st rongest cogency, given t he exist ence of clear-cut and grave sanct ions (t he loss of resources), for programme managers and polit icians at bot h meso and nat ional levels:
11
• Payment declarations – by both beneficiaries and Certifying Authorities - have to be compiled according t o t he specified st andards, as claims wit h missing informat ion will not be paid out . In addit ion, t he risk of incurring in t he frequent , and oft en overlapping audit s – by nat ional audit aut horit ies, European Court of Audit ors and t he European Commission int ernal audit offices – act s as a st rong det errent t o a superficial approach t o claims handling, given t hat , due t o t he sampling met hod ut ilised, even t he most t rivial mist ake could have considerable consequences in t erms of loss of resources.12
• A further incentive to maintain financial management procedures in good order is represent ed by t he necessit y, in t he current programme period at least , t o have a descript ion of each programme’ s management and cont rol syst em, approved by a nat ional independent aut horit y and by t he European Commission: failing t his, a programme’ s financial circuit is int errupt ed and no payment from t he European budget will be received aft er t he init ial advance (art . 71 and 72 of t he General Regulat ion).
• Lastly, programmes are subj ected to the so-called N+2/ 3 rule (articles 93-97 of the General Regulat ion), which has t he clear-cut consequence t hat resources unspent wit hin a cert ain t ime-frame are lost . This rule has act ed as a st rong incent ive in focusing t he at t ent ion of programme aut horit ies on t his t ask above any ot her. There is evidence of t he dist ort ion t hat t his represent s in t erms of programme out comes (Bacht ler et al, 2009), given t hat t he incent ive t o spend is such t hat proj ect s of lower qualit y or not necessarily t oo fit t ing wit h t he programmes’ obj ect ives – even ‘ coherent proj ect s’ , i.e. proj ect s already implement ed wit h domest ic resources - are pushed t hrough t he proj ect pipeline in order t o keep expendit ure flowing and achieve t he necessary t arget s.
4.
CONCLUSIONS
The above narrat ive shows t hat t he rules and procedures t hat govern Cohesion policy implement at ion det ermine in pract ice different levels of compliance for t he different processes. Such different iat ed compliance is due t o t he variable degree of ‘ cogency’ of t he rules, which is caused by t he combined effect of t he differing nat ure of t he sanct ioning mechanisms foreseen for t he various processes13 - as above discussed - and t he limit ed human and financial resources available t o programme managers, which ent ails t hat different processes are essent ially in compet it ion wit h each ot her.
12 Evidence from research carried out in It aly indicat es t hat is risk is amplified in t he first years of
implement at ion, where given t he limit ed pool of proj ect s being implement ed, audit s by different aut horit ies t end t o concent rat e on t he same group of proj ect s (see on t his Polverari and Vit ale, 2010).
13 Some of t he above processes have no sanct ioning t ools at all, whilst ot hers respond t o sanct ioning
mechanisms of different int ensit y (from harder - as. Programme managers are forced t o privilege t hose processes t hat are accompanied by hard sanct ions.
On t he one hand, alt hough t here isn’ t much evidence on t he administ rat ive cost s of St ruct ural Funds delivery and t he st udies on t his t opic present discordant findings on t he ext ent of such cost s in different administ rat ive syst ems,14 t here is enough proof t o suggest t hat programme Managing Aut horit ies are oft en underst affed and st ruggling t o meet demands, as is t est ified by t he virt ually unanimous (and long-st anding) calls for simplificat ion and proport ionalit y.
On t he ot her hand, only some and not all of t he programme management processes ent ail sanct ions, and t he degree of ‘ hardness’ of such sanct ions, where t hey are in place, is variable. For inst ance, whilst failing t o comply wit h rules in t he field of financial management ent ails t angible and serious consequences (int errupt ion of financial flows and loss of resources), failing t o comply wit h ot her aspect s of programme implement at ion, especially in t he fields of part nership but also of monit oring and evaluat ion, does not ent ail part icular consequences, or formal rat her t han subst ant ial compliance is sufficient t o avoid pot ent ial penalt ies.
Faced wit h mult iple demands and limit ed resources, programme managers are forced t o assign priorit y t o t hose t asks t hat ent ail t angible sanct ions and st ronger cogency. These are also t he processes t hat relat e t o financial and procedural account abilit y. As a result , financial and procedural account abilit y t ake predominance over out come and performance account abilit y, and t his, in t urn, has det riment al effect s on effect iveness: t he key concern is spending money, rat her t han delivering cert ain result s and impact s (because it is on t his aspect t hat aut horit ies and individuals are brought t o account ). Table 1 t o follow provides an overview of t he argument above discussed, providing an assessment of t he compliance and enforcement assigned t o t he phases of policy management assessed in t his paper – involvement of part ners and st akeholders in t he policy cycle; monit oring and report ing; evaluat ion; and, financial management – and t he t ypes of account abilit y fulfilled in pract ice by such programming processes.
Import ant implicat ions can be derived from t he argument proposed in t his paper for t he debat e on t he reform of t he policy for t he period 2014-2020. This debat e has t ouched upon some aspect s of t he above discussed issues. The Conclusions of t he Fift h Cohesion Report st ress t he need t o shift from a logic dominat ed by input s and procedures, t o a logic of based on out comes and performance (European Commission, 2010). According t o t he report , t his should be achieved t hrough a more clear-cut ex ant e indicat ion of goals and t arget s, linked t o efficient monit oring syst ems, and t he int roduct ion of new forms of condit ionalit y, int ended t o st rengt hen t he focus on out comes. Yet , whet her t hese proposals – which are in many cases generic (as is nat ural given t he nat ure of t he document ) – will be able t o achieve t his int ended goal is at best dubious.
The proposals relat ing t o t he st rengt hening of evaluat ion, for example, especially ex ant e evaluat ion, are not accompanied by new mechanisms t hat would ensure t heir enforcement . Aft er all, aren’ t t he Operat ional Programmes required t o provide t arget s and indicat ors already? The only novelt y in t his respect would be t he inclusion of such t arget s and
14
indicat ors in t he new Cont ract bet ween t he Commission and t he Member St at es: a sof t enforcement t ool t hat is likely t o deliver weak subst ant ive compliance.15
As for t he new condit ionalit ies, inst ead of being placed on t hose programming processes t hat would deliver out come and performance account abilit y (especially monit oring of physical indicat ors and evaluat ion)16, t hey are int ended t o support t he achievement of goals - minimum administ rat ive st andards, compliance wit h t he St abilit y and Growt h Pact , and t he goals of t he St rat egy Europe 2020 – t hat would only indirect ly cont ribut e t o t he policy’ s overarching goals and apply t o a level t hat is most ly higher t han t hat of individual programmes. Clearly, t hey will not t ip t he balance in favour of performance-t ype account abilit y wit hin t he programmes. In fact , t hey may make t hings worse, pot ent ially exacerbat ing t he already demanding administ rat ive onus placed on programme managers and cont ribut ing t o furt her goal displacement .
The proposals cont ained in t he Conclusions of t he Fift h Cohesion Report do not appear suit able t o alt er t he exist ing balance in t he degree of cogency associat ed wit h t he different programme management procedures t hat deliver financial and procedural account abilit y (which is st rong and likely t o remain st rong) and out come and performance account abilit y (which is weak and likely t o remain weak).17 In order t o achieve such new balance it would perhaps be more efficient t o pursue ‘ st rong’ and subst ant ive enforcement of t hose processes t hat deliver out come and performance account abilit y (principally monit oring and evaluat ion) wit hin t he programmes. However, t o funct ion as performance t ools and support effect iveness, such new condit ionalit ies would have t o be est ablished as part of an int egrat ed, syst emic framework which fit s wit h t he broader set of rules t hat are already in place, rat her t han in a mere increment al fashion which all t oo oft en opens t he way t o formal, rat her t han subst ant ial, compliance.
15
The same can be said about t he st rengt hening of ongoing evaluat ion by rendering t he Evaluat ion Plans compulsory and linked t o guidance provided by t he Commission as t o what t hey should ent ail.
16
For inst ance, whereas t he Conclusions ment ion t he need t o st rengt hen ex ant e evaluat ion and t arget set t ing, no sanct ioning mechanisms are proposed t o support t his goal.
17
For inst ance, making programmes’ Evaluat ion Plans compulsory and linked t o guidance provided by t he European Commission will not change t he fact t hat programme managers will cont inue t o focus on N+2 and audit compliance above all.
Process / procedure Account abilit y t ype Compliance Enforcement Descript ion of assessment 5CR proposals
Involvement of partners/ stakeholders
In principle all t ypes of account abilit y, but generally not in pract ice.
Weak. None. Involvement of part ners most ly formal; t ick-t he-box approach.
Vague reference t o need t o increase part nership [enforcement likely t o remain unchanged].
Monitoring and Reporting In principle all t ypes of account abilit y, in pract ice most ly financial and procedural.
Medium. Medium. Monit oring syst ems st ill in some cases focussed on financial and procedural indicat ors and facing problems wit h dat a gat hering. Report ing on out comes st ill want ing.
Vague reference t o need t o st rengt hen indicat ors and t arget set t ing and report ing [enforcement likely t o remain unchanged].
Programme evaluation
- ex ante In principle financial and out come, in pract ice largely depending on cont ext and generally not effect ively as it could be.
Weak or st rong depending domest ic on cont ext s. Oft en weak.
Soft . Ex ant e evaluat ions j ust ify choices
already made.
Deficient independence (depending on exist ing inst it ut ional framework).
Ex ant e t o be reformed so t hat it
informs rat her t han j ust ifies policy choices. [unspecified, enforcement likely t o remain unchanged].
- ongoing In principle financial, procedural, out come and even performance, in pract ice largely depending on cont ext .
Weak or st rong depending domest ic on cont ext s.
Soft . Tot al flexibilit y on when, how and on what t o carry out evaluat ions during t he programme period. What is done depends largely on exist ing inst it ut ional framework and degree of awareness.
Ongoing programme evaluat ion t o be linked t o compulsory Evaluat ion Plans, draft ed in compliance wit h COM guidance. [st rengt hened compared t o 2007-13, but st ill soft and pot ent ially even count er- product ive (if it result s in formal rat her t han subst ant ial compliance)]
- ex post In principle financial, procedural, out come and performance. Out come and performance account abilit y could be reinforced.
Mixed (COM in charge under st rong polit ical and administ rat ive cont rol by EP, ECA and MSs, but polit ically-driven compliance).
Medium (st rong polit ical cont rol, but subst ant ial emphasis on out come (impact s) and performance account abilit y could be improved).
Lack of assessment of policy impact and on programme impact s.
Suggest ion t hat MS prepare t heir own
ex post report s in addit ion t o t he
evaluat ion work carried out by COM, based on programme ongoing evaluat ions. [unspecified, not likely t o reinforce evaluat ion as account abilit y t ool].
Financial Management
- (N+2) Financial account abilit y. St rong. Hard. Unspent resources are lost . Reformed t o st rengt hen feasibilit y [enforcement likely t o remain unchanged].
- Claims processing/
Payments
Financial/ procedural account abilit y. St rong. Hard. Frequent audit procedures and recovery of unduly paid sums, irrespect ive of whet her minor error or maj or fraud; sampling met hod amplifies risk.
Vague references t o simplificat ion, but no radical overhaul [enforcement likely t o remain unchanged].
- Systems description Financial/ procedural account abilit y. St rong. Hard. Condit ions int ermediary payment s from EU budget .
-
Table 1: Degree of compliance and accountability pursued
5.
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