Introduction to the Impact Assessment Process When are
Introduction to the Impact Assessment Process When are they needed? When Government regulatory proposals: impose or reduce costs on business / third sector affect costs in the public sector, unless the costs fall beneath a preagreed threshold (generally 5m) involve a redistribution (eg an exchange or 'transfer' of costs or benefits from one group to another) involve a change in administrative costs seek collective agreement for UK negotiating positions on EU proposals submit bids for primary legislation to the Legislative Programme Cabinet Committee But not . where policy changes will not lead to costs or savings for business, the
public sector, third sector organisations, regulators or consumers for road closure orders where changes to statutory fees or taxes are covered by a predetermined formula such as the rate of inflation, or in respect of other changes to taxes or tax rates where there are no associated administrative costs or savings. Is this a new thing? Absolutely not. Cost Compliance Assessments since the late 1980s Regulatory Impact Assessments required since mid 1990s Impact Assessment with fixed format introduced in 2007
Why make the change? Insufficient recognition of fundamental purpose: rigorous analysis for policy-making RIAs often seen as the last obstacle before bringing in regulation not properly embedded in early analysis Often no clear statement of underlying problem Alternatives not sufficiently considered
Critical data especially on costs and benefits hard to find or missing Arguments and evidence inaccessible - narrative too discursive RIAs often duplicate other documentation Guidance overly bureaucratic and too long What has changed? What has changed? Improved quality of economic and other analysis that underpins policymaking Sharpened focus on policy rationale
More prominence given to costs and benefits Stronger commitment to specify ex post review date Integrated with the Standard Cost Model Integrated approach maintained Specific Impact Tests Increase transparency of analysis Fixed template Improved Ministerial Declaration Impact assessment part of consultation and final policy decision Embed impact assessments at the heart of policy-making Impact Assessment Library Where you can find more information IA Guidance: http://www.berr.gov.uk/files/file44544.pdf IA Toolkit: http://www.berr.gov.uk/bre/policy/scrutinising-newregulations/preparing-impact-assessments/toolkit/page44199.html
IA online Training: http://www.iatraining.berr.gov.uk Treasury Greenbook: http://greenbook.treasury.gov.uk Measuring administrative burdens, UK outcomes and next steps Headlines Measurement and simplification planning exercises between May 2005 and Dec 2006 Simplification plans and measurement results published in December 2006, 2007 and 2008 Plans published for 19 departments
Over 500 simplification measures identified delivering an estimated 3.4bn of savings by May 2010 240 simplification measures implemented reducing admin burdens, savings business and third sector organisations an estimated 1.9bn each year Context Well developed better regulation agenda but no specific focus on administrative burdens
BRTF report Less is More stated what gets measured gets done Politically driven timescales one year from start to finish 3 exercises covering Tax and customs, Financial services and the rest of government, but led centrally Limited information at start number of regulations, populations, etc Key points about the Standard Cost Model
Simple, pragmatic framework for measuring costs Indicative - not statistically representative Means to an end: aim is reductions in burdens Provides consistent baseline for setting targets Rapidly growing international use, including EU and OECD, and effective SCM network
Main measurement exercise: approach Departments identified regulations summer 2005 Central procurement exercise - PwC appointed September 2005 Mobilisation and mapping (legal and process) September to November 2005 Fieldwork between October 2005 and April 2006
Departmental reports with measurement outcomes April to July 2006 A sense of scale 20,000 Information Obligations measured Over 90% of baseline (by cost) measured by direct engagement with business Over 75% through engagement with small & medium sized enterprises Over 8,500 interviews and over 200 expert panels
At peak over 700 PwC people, over 300 in departments and up to 23 in BRE team Lessons learnt More time for preparatory work Better departmental buy-in from outset at top level More prioritisation and be realistic
Strong project and resource planning Manage departments expectations of the extent of their involvement Allow time to sanity check numbers before they go anywhere Support of business stakeholders is essential Business As Usual Adjustments Business as usual costs
Pressure from departments and business to identify BAU costs (HMRC measurement excluded BAU costs in line with NL tax department) Methodology developed aim to be: Credible, pragmatic and as open as possible Consistent across departments; Approved by business stakeholders independent panel to review outcomes
Net costs agreed Enables focus on delivering visible outcomes Summary of UK Administrative Burden Measurement Results Administrative Costs 25.2bn Administrative Burdens (excluding business as usual costs) 13.2bn Administrative Burdens (excluding business as usual costs) Tax and Customs 5.1bn Financial Services 855m Totals including tax/customs and financial services Admin Costs 31.2bn Admin Burdens 19.2bn
m's Annual net reduction in costs to business Progress towards 2010 net reduction target 4,000 30% 3,353 3,500 25% 3,000 2,635 20% 2,500 1,906
2,000 1,485 1,500 10% 1,000 500 15% 633 5% 321 0
0% May 2006 May 2007 May 2008 Delivery to date Dec 2008 May 2009 May 2010 Planned delivery Burdens by department Business Enterprise and Regulatory Reform HM Revenue & Customs (Forms & Returns) Communities and Local Government
Health and Safety Executive Department for Health Department for Transport Department for Innovation, Universities and Skills Department Environment, Food and Rural Affairs Department for Work and Pensions Ministry of Justice Department for Culture, Media and Sport Department for Children, Schools and Families HM Treasury HM Revenue & Customs (Audits & Inspections) Food Standard Agency Home Office Charity Commission Office for National Statistics Cabinet Office Government Equalities Office Forestry Commission 0.0
0.5 1.0 1.5 2.0 2.5 bns 3.0 3.5 4.0 4.5 % of admin burden by Origin C - Domestic
B - International, but domestic discretion A - International no domestic discretion 100% 90% 20 28 28 80% 70% 43 14 12 15
60% 13 50% 40% 30% 66 60 57 44 20% 10% 0% UK (Burden) UK (Cost)
Denmark The Netherlands Biggest information obligations Department Regulation IO Description Admin Burden Communities and Local Government Town and Country Planning Application for 1,110 million Act 1990
planning permission Health and Safety Executive Management of Health & Safety at Work Regulations 1999 Risk assessment 600 million Business, Written statement of Enterprise and Employment Rights Act 1996 586 million employment Regulatory Reform Business,
Consumer Protection Act Provision of safety Enterprise and 443 million 1987 information Regulatory Reform Health and Safety Executive Gas Safety (Installation and Use) Regulations 1998 Gas safety checks 237 million Department of Health Medicines for Human Use
(Marketing Authorisations Etc.) Regulations 1994 Authorisation for marketing of medicines 208 million Communities and Local Government Housing Act 1985 Houses in multiple occupation 207 million Type of information obligation Providing statutory information for third parties
Keeping records Applications for permission for or exemption from Returns and reports Statutory labelling for the third parties Notification of activities Applications for authorisation Cooperating with audits/inspections of Applications for subsidies or grants for Carrying out inspections of Updating commercial emergency plans & programmes Entry in a register Framing complaints and appeals Carrying documentation Agreeing contracts Requesting information 0% 5% 10%
15% 20% % of Baseline 25% 30% 35% Distribution of administrative burden And after initial measurement The next challenge Measuring administrative burden of new regulations
Identify further simplification measures Both are crucial to ensure that net reduction targets are meet Measurement approaches High cost / high profile / high irritants Use approaches developed by PwC including: Interviews with business (face-to-face or telephone) Expert Panels
Low cost / low profile / low irritants Use Admin Burdens Calculator Identify similar regulations / obligations as a basis for modelling UK Framework Guidance Simplification Guidance & checklist for departments Training Facilitated sessions for Better Regulation Units
and economists On-line training for policy officials etc. Tools Admin Burdens Calculator and Database Spreadsheet Simplification Plans Simplification Plans An annual insight into individual Departments efforts/ work to reduce administrative and policy costs and to address main regulatory irritants:
- Covering: Business with a dedicated strategy for Small Firms, Third sector organisations Public sectors front line workers (since June 2007) - Focusing on three main areas: Whether simplifications measures that have been implemented delivered planned reductions Further quantification for simplification measures yet to be implemented New simplifications measures to meet reduction targets Targets, reductions identified and delivered 80%
60% -60% -80% -100% ONS MoJ HSE Home Office HM Treasury GEO FSA DWP
-20% Charity Commission 0% Cabinet Office 20% BERR % Redution by 2010 40% % reduction identified Target Net savings delivered to date (Dec 08)
Validating achievements Making sure savings are felt by business External Validation Panel Members: representatives of key business organisations (British Chambers of Commerce, Confederation of British Industry, Federation of Small Businesses, Institute of Directors and the Trades Union Congress) Role: review and challenge the assumptions underpinning the top administrative burden reductions Departments have implemented from May 2005 to May 2008 Outcome: An estimated 1.5bn of gross simplifications approved Examples of simplifications Improvements to Employment Guidance (BERR) The Employment Guidance Programme was established to reduce the administrative burdens imposed by employment
law, improve peoples perceptions and drive wider business cultural change around compliance. The programme has produced and promoted free to use and legally compliant online tools, proforma letters and agreement forms, accessible through the BusinessLink website. Independent research shows that peoples perceptions are changing with the introduction of these tools. 418 million of annual net savings have also been achieved by December 2008 Fewer Annual General Meetings for private companies (BERR) Company Law has been substantially rewritten to make it easier for the UKs one million companies to understand, and more flexible for them to manage, especially for small businesses. The changes have removed a number of outdated and often archaic rules such as the need to hold an AGM and the need for paper-based communication with shareholders. The new Companies Act also brings together measures from many separate pieces of legislation in to a single place and introduces easier and cheaper
forms of decision-making for companies By simplifying company law and making it easier to understand, companies over time should be easier to manage and businesses. 500 750,000 private companies no longer need to hold an annual general meeting (AGM) delivering 45m annual savings delivered. Around 60,000 private companies no longer need to appoint a company secretary, saving 50 100 per business each a year. Sensible Risk Management Risk Assessments (HSE) Small businesses often find it difficult to work out what health and safety rules mean for their workplace, and are unsure where to go for advice on developing a health and safety plan. The Health and Safety Executive have published guidance on how to complete a health and safety risk assessment in one place at www.hse.gov.uk/risk. The site tells them what the key risks are for their industry, what practical measures they need to have in place, and has examples on what good enough looks like for their industry. Convenience stores, estate agencies, dry cleaners, and hairdressing salons are among the 18 sector-specific businesses that can now benefit from these example risk assessments. This means lower risk businesses will spend significantly less time completing their assessments as a result.
182 million of annual net savings have been achieved by December 2008 Electronic Planning Applications (CLG) Inconsistencies and over-regulation in the planning system have long been an irritant for business. Changes have been introduced to provide a faster, more efficient planning system with less red tape. One example is that planning applications can now be submitted electronically, using a single national application form. This makes the process for obtaining planning consents simpler and more consistent across all local authority areas, and gives businesses greater certainty for planning and fewer administration costs. Greater consistency is also being achieved through access to better information and clearer criteria on what is needed for applications. 120 million of annual net savings have been achieved by December 2008 Where you can find more information
Portal: www.betterregulation.gov.uk Any questions? Mark Hammond Better Regulation Executive, Department for Business, Enterprise and Regulatory Reform 1 Victoria Street, London, SW1H 0ET [email protected] +44 20 7215 0339
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