When we try to feed policy decisions with evidence, a key milestone is developing good policy recommendations. When possible, evidence identified must be applied and translated into recommendations for decision makers. This is not always viable nor appropriate so first of all one needs to make the decision on whether the findings/knowledge one has allows to draw conclusions on potential changes or innovations to be discussed with policymakers. If one thinks that recommendations are possible and valuable, then one should start strategically thinking about different key issues: how this knowledge could be used/applied by different types of policymakers, according to their roles. Also, the relationship with and access to them are crucial in terms of deciding when, how and in through which channel share recommendations.
In this brief article we would like to highlight some criteria that it would be important to consider when making public policy recommendations. For this purpose, we turn to Eugene Bardach’s A Practical Guide for Policy Analysis (1998). While his work is focused on policy analysis, he distinguishes some criteria that are also worth to consider for recommendations. He distinguishes between evaluative criteria and practical criteria. The former are “evaluative standards used to judge the goodness of the projected policy outcomes that are associated with each of the alternatives“: efficiency, equality, equity, fairness, justice, freedom and community, among others.
The practical criteria “have to do with what happens to an alternative as it moves through the policy adoption and policy implementation processes.” These practical criteria are very helpful when shaping policy recommendations and are not always considered by advisers. The main ones are legality, political acceptability, robustness under conditions of administrative implementation, and improvability.
Legality. A viable policy shall not violate the people’s constitutional rights or the law. However, the author highlights the difference between legal rights and the so called “natural” or “human” rights, such as the “right to abortion”, the “right to life” or “the right of every woman to make decisions regarding her own body”. Public policy recommendations on this type of rights shall bring about more debate and/or rejection, depending on the audience.
Robustness. Many policy ideas may seem very good on paper, but they often fail in their actual implementation. “The implementation process has a life of its own. It is acted out through large and inflexible administrative systems and is distorted by bureaucratic interests.” Therefore, policies stemming from practice may significantly differ from the designed and adopted policies. Consequently, a policy option must be robust enough so that, even though the implementation process may not be easy, policy results are satisfactory. Among adverse implementation results that are worth considering are long delays, “capture” of policy program benefits for a group of citizens that have not been considered for said benefits, excessive budgetary or administrative costs, administrative complexities, etc.
Political acceptability (or we can also say ‘political viability’). Political unfeasibility may be a combination of two things: ” too much opposition (which may be wide or intense or both) and/or too little support (which may be insufficiently broad or insufficiently intense or both).” We can share an example: if it is recommended for public primary school students in vulnerable areas to stay longer at school (for example, implementing a double shift) as a measure to increase their educational level, and that is not accompanied by a teachers’ salary increase who should work over time, it may create opposition by the unions, which should undermine the proposal’s political viability. However, “unacceptability” is not a static issue and it is always worth asking ourselves if it may change. Developing creative strategies may open options that have not been taken into account before.
Improvability. When recommending a public policy, it is not possible to have all the right details to design a scenario. Therefore, a certain leeway must exist for policy implementers to perfect the original design. The most common element for said improvement is involving in the implementation process those individuals and groups whose experiences or points of view have not been included in the design phase.
Besides Bardach’s criteria, it is also worth to consider the budgetary viability and integrity of a policy recommendation. That is, if more than one public policy solution is recommended, it is important to integrate them to the political and budgetary feasibility analyses. As an example, a recurring tax policy contradiction is recommending an increase in expenses in an area deemed a priority (for example, education) while also recommending to maintain the tax balance because an expansive tax policy may cause inflation and deteriorate teachers’ salaries, or even worse, deficit may bring about a crisis. Every time we propose a tax policy change it affects the general balance and that has secondary effects. Therefore, if we propose an increase in expenses, it is important to clarify how it would be funded (what other expense to lower or tax to raise).
Accounting for the budgetary feasibility of implementing the proposal contributes to its robustness, together with political viability. It also demonstrates maturity in the context of understanding the decision makers’ work.
Finally, Leonardo Garnier (twice Minister of Education and Minister for National Planning and Economic Policy of Costa Rica) contributes with another criterion to be considered when making public policy recommendations: the criterion of opportunity. Political actions always compete among them for the scarcest resources – time, financial or institutional resources, political capital – and, therefore, recommendations must have not only the abovementioned characteristics but they must also be “timely” in the sense that it is “their moment”. They must not become an obstacle to other priority reforms, but rather they should be reforms that facilitate or promote other expected reforms. There will always be recommendations with “all the sense in the world… except the sense of opportunity.” Obviously, it is a dynamic criterion that must be valued in every situation: what was not timely yesterday may be completely timely tomorrow.
The policy makers who participated in the online course “Leaders of change: developing Latin American policymakers´capacity to promote the use of knowledge in policy” generally acknowledged the universality of these criteria. Moreover, many of them admit that they are implicitly applied in their daily work. However, they recognized that there are some difficulties when moving from theory to practice. Sometimes it is not easy to make recommendations beyond the mere perception of who recommends, involving a more comprehensive analysis of the chances of being implemented.
In general, the criterion of legality is present in the recommendations, whether they are made by policy makers themselves or by external consultants or evaluators. However, it is important to know the intricacies of laws and regulations, because sometimes what seems possible is blocked due to biased interpretations of the regulation gaps.
The criterion of robustness is one of the less considered, especially by the external consultants. The features of public administration, their tricks, their intricacies, are not always visible to those unfamiliar with the State on the inside, and that is evident when they make some recommendations.
The political feasibility is another aspect that sometimes is lost. Firstly, it is important to consider the interests of the decision maker in terms of political career. For example, sometimes certain political actions whose results are not visible in the short term are recommended. For a politician is not the same to carry out infrastructure project to initiate a process of awareness of a certain issue (i.e.: early childhood development): the former is often more politically fruitful than the latter. The political cycle is another aspect to consider, as the rotations in high level positions affect the potential to apply this or that recommendation.
In terms of budgetary viability, it often happens that many recommendations aim to raise the budget of a certain program. However, the decision maker or area that receives the recommendation is not in charge of making those decisions. Hence it is important to know also the field of action and the capacity to share the decision-maker that you are approaching. Another useful strategy when making feasible recommendations from the budgetary point of view is to introduce stepped implementation models, considering the priorities and their respective budgets.
In addition to recognizing the distance between theory and practice, participants shared some other criteria they usually consider in their work:
- The criterion of negotiation: between different sectors of society and among political actors must agree to implement a particular policy. This criterion is similar to the political viability one.
- The criterion of relevance: as mentioned in the case of the politically and economically viable recommendations, it is important to know the characteristics and interests of the receptor of such recommendations and their scope for action.
Although they highlighted some difficulties to always apply this set of criteria in practice (due to lack of time, enough informaiton, etc.), most of the participants did not hesitate to recognize the importance of counting with a clear ser of criteria when making recommendations. In fact, many have begun to promote them within their agencies through different means: from workshops to share the criteria with their teams, to the development of guidelines to be considered when making recommendations to be shared with external evaluators.
For more work on evidence and policy by P&I, look at our framework to bring knowledge into policy.