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Methodologies: UK
Rachel Holloway
Regulatory Delivery
Objectives
• Methodologies in the UK
• Tools, techniques & guidance to assist
• Example of a method: Small and Micro Business
Assessments
• Cost Benefit Analysis
• Strategies for dealing with an absence of data
• Q & A
Available guidance
Green Book and Magenta Book
Framework for the appraisal and evaluation
of all policies, programmes and projects in
Central Government
Tax policies
HMT specialism
Spending policies
Business Case
Guidance
Regulatory Policies
Better Regulation
Framework Manual
The Purpose of IAs
• To make policy making more effective and evidence
based
• Ensure stability in the legislative environment
• Ensure stability in the business environment
• Increased transparency in policy making
The RIA Process
Research skills are necessary to find, analyse and interpret
Information, data and other evidence
Ask experts in Government and Stakeholders outside to help you
analyse your data and build relationships.
Step 1
Identify
the
problem
Step 2
Set
Objectives
Step 3 Step 4 Step 5 Step 7
Identify
Options
Identify
Impacts
Value Costs
and
Benefits
Public
Consultation
Monitoring
and
Evaluation
Step 6
5
Analytical frameworks
Prompts key questions to be asked:
1. What is the problem?
2. Why is change needed?
3. Where do we want to be?
4. How could we get there?
5. What are the possible impacts of these options?
6. Which is the best route based on the evidence?
7. How will legislation be implemented, enforced and monitored?
8. Will the benefits justify the costs?
6
The RIA Process
Policy
Development
Stage
Progression of analysis – assuming full quantification is possible
and proportionate
1: Identify 2: Describe 3: Quantify 4: Partially
monetise
5: Fully
monetise
Development   ? ? 
Options   ? ? 
Consultation   ? ? ?
Final Proposal     
Enactment     
Core Principle – Proportionate Analysis
7
Better Regulation in practice
• Guidance for officials. Sets
out:
• What you must do
• Provides tools, techniques
and points of contact to
help develop your IA.
• An example and some case
studies.
• Is published online &
promoted to business
• Living document –
currently under revision
8
The RIA Process
Research skills are necessary to find, analyse and interpret
Information, data and other evidence
• Quality in RIA is entirely dependent on how you work
• You need to develop a number of core skills to be
successful
• A RIA Report takes time. It is a record of the
development of a proposal.
• Proportionate analysis is a core principle.
9
The RIA Process
Core Skills
• Developing and using a
sound evidence base
• Data Analysis
• Quantitative
• Qualitative
• Stakeholder engagement
and management
• Effective communication
RIA is like
doing a...
10
Definitions
What is a small/micro business or civil society
organisation?
Defined in the BRFM as those employing up to 50 full-
time equivalent employees.
When is a SaMBA required?
BRFM states that it is mandatory for all new domestic
regulatory proposals, except those which qualify for the
Fast Track.
Exemption
• Assumption that when a large part of the intended
benefits can be achieved without including smaller
businesses, an exemption will normally be applied.
• Should also consider partial exemption or mitigation.
• Think carefully whether it is necessary to extend a
measure to small and micro businesses at the outset of
policy development.
Not exempting
A regulation can be extended to smaller businesses if:
• any disproportionate burdens have been mitigated; and
• the exemption of small businesses is not viable or
compatible with achieving a large part of the intended
benefits of the measure.
Exemption and mitigation
Source: RPC guidance
Large parts of benefits maintained when
applying an exemption
YES NO
Disproportionate
burdens and / or
if it is viable to
mitigate costs
YES
Exemption
should be applied
Disproportionate
costs to small
businesses should be
mitigated
NO
Neither
exemption nor
mitigation required
Why is cost benefit analysis
important?
• Allows us to:
• Choose the best available policy option
• Identify key impacts of a policy
• Measure how different groups will be affected
• This in turn leads to:
• Maximum benefit for society
• Minimum cost to the taxpayer
• Transparency about what government is doing
Key elements of cost benefit analysis
• You should aim to identify all costs and benefits, describe them as
well as you can. There is sometimes no market price for benefits.
These should be thoroughly assessed and described qualitatively.
There are methodologies available to apply a monetary value to
them.
Example: Impact of a proposal to reduce regulatory requirements
under an existing inspection regime. This proposal would reduce
burdens on business. The proposal is expected to affect 18K
businesses, and reduce the time needed for the business manager
(wage rate of €27) to prepare for the inspection, from 8hrs to
6hrs, and also reduce the frequency of inspection from once a
year to once every two years.
What to do when you have incomplete
data?
• Use best available data & consult!
e.g. “Do you believe the assessment of costs and benefits
in the Impact Assessment are realistic? If not, is there any
further evidence that you can provide that should be
taken into account?”
• 75% of responses said they estimated higher costs for
average cost per hour of senior qualified inspector than
our RIA had.
• We revised initial RIA for the draft Bill upwards by 50%
from £18.50 to £27.75
17
International comparisons & links
• Very limited comparators, only 1 other country was about
to introduce the same system
• The RIA was explicit about the poor data, the work they
were undertaking to address & caveated their analysis
“A key difficulty in evaluating this policy, however, is the lack of
quantifiable evidence on the likely impact of standardised
packaging, given that no country has yet introduced this
measure. One approach to address this limitation is to elicit
subjective judgments on the likely impact of standardised
packaging from a range of experts in this area.”
“A substantial impact on consumption is plausible but we need a
better idea of its likely scale (from our expert panel), its cost
implications and any impact on duty free imports.”
18

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Methodologies: UK

  • 2. Objectives • Methodologies in the UK • Tools, techniques & guidance to assist • Example of a method: Small and Micro Business Assessments • Cost Benefit Analysis • Strategies for dealing with an absence of data • Q & A
  • 3. Available guidance Green Book and Magenta Book Framework for the appraisal and evaluation of all policies, programmes and projects in Central Government Tax policies HMT specialism Spending policies Business Case Guidance Regulatory Policies Better Regulation Framework Manual
  • 4. The Purpose of IAs • To make policy making more effective and evidence based • Ensure stability in the legislative environment • Ensure stability in the business environment • Increased transparency in policy making
  • 5. The RIA Process Research skills are necessary to find, analyse and interpret Information, data and other evidence Ask experts in Government and Stakeholders outside to help you analyse your data and build relationships. Step 1 Identify the problem Step 2 Set Objectives Step 3 Step 4 Step 5 Step 7 Identify Options Identify Impacts Value Costs and Benefits Public Consultation Monitoring and Evaluation Step 6 5
  • 6. Analytical frameworks Prompts key questions to be asked: 1. What is the problem? 2. Why is change needed? 3. Where do we want to be? 4. How could we get there? 5. What are the possible impacts of these options? 6. Which is the best route based on the evidence? 7. How will legislation be implemented, enforced and monitored? 8. Will the benefits justify the costs? 6
  • 7. The RIA Process Policy Development Stage Progression of analysis – assuming full quantification is possible and proportionate 1: Identify 2: Describe 3: Quantify 4: Partially monetise 5: Fully monetise Development   ? ?  Options   ? ?  Consultation   ? ? ? Final Proposal      Enactment      Core Principle – Proportionate Analysis 7
  • 8. Better Regulation in practice • Guidance for officials. Sets out: • What you must do • Provides tools, techniques and points of contact to help develop your IA. • An example and some case studies. • Is published online & promoted to business • Living document – currently under revision 8
  • 9. The RIA Process Research skills are necessary to find, analyse and interpret Information, data and other evidence • Quality in RIA is entirely dependent on how you work • You need to develop a number of core skills to be successful • A RIA Report takes time. It is a record of the development of a proposal. • Proportionate analysis is a core principle. 9
  • 10. The RIA Process Core Skills • Developing and using a sound evidence base • Data Analysis • Quantitative • Qualitative • Stakeholder engagement and management • Effective communication RIA is like doing a... 10
  • 11. Definitions What is a small/micro business or civil society organisation? Defined in the BRFM as those employing up to 50 full- time equivalent employees. When is a SaMBA required? BRFM states that it is mandatory for all new domestic regulatory proposals, except those which qualify for the Fast Track.
  • 12. Exemption • Assumption that when a large part of the intended benefits can be achieved without including smaller businesses, an exemption will normally be applied. • Should also consider partial exemption or mitigation. • Think carefully whether it is necessary to extend a measure to small and micro businesses at the outset of policy development.
  • 13. Not exempting A regulation can be extended to smaller businesses if: • any disproportionate burdens have been mitigated; and • the exemption of small businesses is not viable or compatible with achieving a large part of the intended benefits of the measure.
  • 14. Exemption and mitigation Source: RPC guidance Large parts of benefits maintained when applying an exemption YES NO Disproportionate burdens and / or if it is viable to mitigate costs YES Exemption should be applied Disproportionate costs to small businesses should be mitigated NO Neither exemption nor mitigation required
  • 15. Why is cost benefit analysis important? • Allows us to: • Choose the best available policy option • Identify key impacts of a policy • Measure how different groups will be affected • This in turn leads to: • Maximum benefit for society • Minimum cost to the taxpayer • Transparency about what government is doing
  • 16. Key elements of cost benefit analysis • You should aim to identify all costs and benefits, describe them as well as you can. There is sometimes no market price for benefits. These should be thoroughly assessed and described qualitatively. There are methodologies available to apply a monetary value to them. Example: Impact of a proposal to reduce regulatory requirements under an existing inspection regime. This proposal would reduce burdens on business. The proposal is expected to affect 18K businesses, and reduce the time needed for the business manager (wage rate of €27) to prepare for the inspection, from 8hrs to 6hrs, and also reduce the frequency of inspection from once a year to once every two years.
  • 17. What to do when you have incomplete data? • Use best available data & consult! e.g. “Do you believe the assessment of costs and benefits in the Impact Assessment are realistic? If not, is there any further evidence that you can provide that should be taken into account?” • 75% of responses said they estimated higher costs for average cost per hour of senior qualified inspector than our RIA had. • We revised initial RIA for the draft Bill upwards by 50% from £18.50 to £27.75 17
  • 18. International comparisons & links • Very limited comparators, only 1 other country was about to introduce the same system • The RIA was explicit about the poor data, the work they were undertaking to address & caveated their analysis “A key difficulty in evaluating this policy, however, is the lack of quantifiable evidence on the likely impact of standardised packaging, given that no country has yet introduced this measure. One approach to address this limitation is to elicit subjective judgments on the likely impact of standardised packaging from a range of experts in this area.” “A substantial impact on consumption is plausible but we need a better idea of its likely scale (from our expert panel), its cost implications and any impact on duty free imports.” 18