Please see my submission attached.
submission by Edwina Barton
10 July 2018
I wish to comment against the following aspects of the ToR in particular -
• driving innovation and productivity in the economy
• delivering high quality policy advice, regulatory oversight, programs and services
• tackling complex, multi-sectoral challenges in collaboration with the community, business
Having worked in the APS, across multiple portfolios, for many decades, I have observed
four recurring weaknesses that I believe hold the APS back from empowering
governments to achieve the best outcomes in the national interest.
These are -
a reluctance to forensically look for, and address, the underlying drivers of policy
problems and instead a tendency to focus on band-aiding symptoms or papering over
failure to use behaviour change science when designing and delivering policy reforms
and programs, in order to select interventions with the highest probability of achieving
the desired policy outcome and behavioural change
failure to build in, fund and use evidence-based evaluation methodology to analyse
whether a particular policy or program is delivering the desired policy goal or not
a reluctance to give frank and fearless advice, including about underlying drivers, for
fear that it will not be what the executive or the minister wishes to hear.
These weaknesses seriously inhibit innovation, lead to poor policy advice, waste
taxpayers’ dollars, and make it almost impossible to effectively tackle complex, multi-
These problems are compounded when ministers, their advisors and senior departmental
executives have little understanding of, or commitment to, the above four issues.
Recommendation 1: Indeed, I would go so far as to suggest that selection processes for all
SES positions in all portfolios must include interrogation on all four issues, and that
competency and commitment to all four must be a prerequisite to any SES appointment.
Band-aiding symptoms rather than addressing underlying drivers
This weakness has several causes, in my view -
• not all public servants, even those in policy roles, have the expertise to drill down
forensically into policy problems and identify the underlying drivers
• SES officers may be reluctant to ask public servants to identify underlying drivers, either
because the SES officers themselves do not have strong policy analysis skills or
because they fear what doing so will discover
• many ministers have a tendency - long demonstrated by studies of decision-making in
the APS - to favour quick-fix ‘announcables’ over evidence-based long-term solutions,
and to favour ‘thought bubble’ ideas which appeal to their world view, rather than
objectively analysed policy solutions based on best available evidence.
Recommendation 2: The solution, in my view, is to -
• give more emphasis to proven policy skills in recruitment processes
• ask the SES to ‘lift their game’ by demanding that public servants put up policy
proposals that address underlying drivers (not just proximate drivers) in all cases, even
if doing so produces uncomfortable policy options that may challenge the minister’s
desire for a quick fix.
Identifying underlying drivers will often reveal complex, multi-sectoral challenges -
challenges which require more than one portfolio to work on together to solve, in a whole-
of-government or even whole-of-community approach. Not all of the policy levers will be in
the hands of a single minister or single portfolio. Population policy and biodiversity policy
are two such examples.
APS officers should never be scared of proposing multi-portfolio solutions, or of
exchanging ideas with officers in other portfolios. Indeed this should be the norm, not the
exception, and SES officers should be open to that type of innovative thinking and should
actively encourage ‘silo busting’.
Failure to use behavioural change science
I commend PM&C’s leadership in driving greater use of behavioural change science in
policy and program design (see http://behaviouraleconomics.pmc.gov.au).
However many portfolios still refuse to use behavioural change science routinely when
designing policies and programs, despite the excellent professional development
opportunities now available to help equip APS staff to do so. (For example, I commend
ANZSOG for its ‘Behaviour Change in Public Policy Masterclass’ which I recently
This is inexcusable, and leads to taxpayer dollars being wasted on initiatives with low
probability of success, and to lack of innovation in designing initiatives.
Recommendation 3: I recommend that selection criteria for all APS positions responsible
for policy or program design include a sound understanding of behavioural change science
principles as mandatory.
Failure to use evidence-based evaluation methodology
In many portfolios, I still see a reluctance to build evidence-based evaluation methodology
into the design phase of policies and programs.
It is often regarded as a nuisance, something to be tacked on at the end once the initiative
has been rolled out, and not properly funded.
Recommendation 4: This is a fatal flaw, and any SES officer who approves the funding or
design of an initiative without such methodology built in does not deserve his or her
position. SES officers must demand that staff prove exactly how they will measure whether
the initiative succeeds or not, including how they will analyse why it failed, if it did.
Recommendation 5: I recommend that selection criteria for all APS positions responsible
for policy or program design include a sound understanding of evidence-based evaluation
methodology as mandatory.
I commend the Canberra Evaluation Forum https://www.act.ipaa.org.au/cef (hosted by the
IPAA) for its tireless efforts to provide free professional development opportunities to APS
officers on evaluation methodology. There is no excuse for APS officers not to understand
such methodology, and to be willing to advocate to their SES for its use.
Reluctance to give frank and fearless advice
This is not a new weakness in the APS, but its negative effects have never been more
stifling to good public policy than now, because policy problems are more complex and
entrenched than ever before.
This weakness manifests itself at every level, from the humble APS5 up to Dep Sec level.
Recommendation 6: The solution in my view is for portfolio heads to demand frank and
fearless advice, and to be willing to give it themselves - even if it’s not what the minister
wants to hear.
Ministers cannot function effectively if they are surrounded by ‘Yes’ men and ‘Yes’ women.
A minister who does not understand this does not deserve his or her ministry, and does not
deserve the confidence of Cabinet or the PM.
This weakness stifles innovation, leads to poor public policy decisions, causes complex
policy problems to be left unresolved, and leads to precious taxpayer funds being wasted
on window dressing or band-aiding.
I understand that it takes courage for an APS officer to say to their boss: ‘No, ma’am, that’s
not what the evidence shows will work - if we recommend that, the policy problem will not
be solved and we’ll be wasting taxpayers’ funds. Let me show you another option - one
which the evidence does support.’.
But an APS officer who can’t muster the courage to do that simply doesn’t belong in the
APS, and should find another job outside the APS.
The Department of the Environment and Energy (DoEE), for whom I worked for 5 years,
between 2008 and 2013, manifested many of these weaknesses to a troubling degree.
I fully acknowledge that successive DoEE ministers have not made it easy for DoEE
officers to avoid those weaknesses, and that federally the environment space is a
contested one involving many complex trade-offs between the goals of different portfolios.
But that does not excuse, in my view, the degree to which some DoEE bureaucrats fell
lamely and submissively into these traps.
- willingness to give frank and fearless advice, including about underlying drivers of
Recommendation 2: That more emphasis be given to proven policy skills in recruitment
processes for positions that involve designing, delivering or reporting on any policy reform
Recommendation 3: That selection criteria for all APS positions responsible for policy or
program design include a sound understanding of behavioural change science principles
Recommendation 4: That SES officers demand that staff prove exactly how they will
measure whether a policy reform or program initiative succeeds or not, including how they
will analyse why it failed, if it did.
Recommendation 5: That selection criteria for all APS positions responsible for policy or
program design include a sound understanding of evidence-based evaluation methodology
Recommendation 6: That portfolio heads demand frank and fearless advice from everyone
in their portfolio, and that they be willing to give it themselves - even if it’s not what the
minister wants to hear.