ministry of territorial policy and...

DIRECTORATE GENERAL OF ADMINISTRATIVE ORGANISATION AND PROCEDURES DEPUTY DIRECTORATE GENERAL OF PROCEDURAL REGULATION SIMPLIFICATION AND IMPROVEMENT

MARÍA DE MOLINA, 50 28071 MADRID TEL.: 91 273 24 62 FAX: 91 273 23 98 [email protected]

MINISTRY OF TERRITORIAL POLICY AND PUBLIC ADMINISTRATION

20 October 2011

Mr. Agustín Torres Herrero

Director-General of Administrative Organisation and Procedures

Secretary of State for Public Service

Ministry of Territorial Policy and Public Administration (Spain) Speech at High Level Group of Independent Stakeholders on Administrative Burdens

Good morning, ladies and gentlemen, First and foremost, I would like to thank you, on behalf of the Government of Spain, for inviting us. It is an honour for me to be here on this platform, where so many prestigious speakers have been before me. A few days ago, after receiving the invitation to attend this event, I read an article in the newspaper that caught my attention. The article said that the so-called “POINTS diet” was easier to follow and had better results than traditional low-calorie diets, even when both are based on similar principles. The reason for the POINTS diet’s success seems to be that it is less complex, and so I thought this was a good example to illustrate what we have tried to do in Spain with the Standard Cost Model.

GOV ERNM ENTOF SPAIN

VICE PRESIDENCYOF THE GOVERNMENTOF TERRIT ORIAL POLICYMINISTRYOF TERRIT ORIAL POLICY AND PUBLIC ADMINISTRATION

SE CRE TA RY OF S TAT E FO R

PUB LIC SERVICE


2

GOVERNMENTOF SPAIN

VICE PRESIDENCYOF THE GOVERNMENTOF TERRITORIAL POLICYMINISTRYOF TERRITORIAL POLICY AND PUBLIC ADMINISTRATION

SECRETARY OF STATE FOR

PUBLIC SERVICE

STANDARD CALORIE CALCULATOR VS. CALCULATOR BY POINTSSTANDARD CALORIE CALCULATOR VS. CALCULATOR BY POINTSSTANDARD CALORIE CALCULATOR VS. CALCULATOR BY POINTS

Calculate Points

Traditional diets and the POINTS diet are based on the same assumption: we must eat fewer calories than we burn if we want to put down weight. The difference is that in traditional low-calorie diets prescribed by doctors you have to weight, calculate and count the calories in each of the foods that make the dish you are going to eat, whereas in the POINTS diet it is the finished dish that gets an overall rating. There are differences in complexity between the two models. That is the reason why Spain adapted the Standard Cost Model into a friendlier version, which I want to call today “Standard Cost Model by Points”, although its real name is “Simplified Model for the Measurement of Administrative Burdens” As you know, in Europe, and with particular intensity in Spain, we have known we need to be more competitive for quite long. A brilliant solution suggested by the European Commission is “to drop ballast” or “to be lean and mean”. We all agreed that the first step we should take was doing away with the unnecessary bureaucracy that burdened our companies and bringing regulation back to target basic goals. So, if I may continue with my diet metaphor, our first goal was burning fat, not oil, and we realised that the Standard Cost Model is a great tool to achieve it.


3

GO VERNME NTOF S PAIN

VICE PRESIDENCYOF THE GOVERNM ENTOF TERRITORIAL POLICYMINISTRYOF TERRITORIAL POLICY AND PUBLIC ADMINISTRATION

SECRE TARY OF ST ATE FOR

PUB LIC S ERV ICE

SPANISH ADAPTATION OF SCM: SPANISH ADAPTATION OF SCM: STANDARD COST MODEL BY POINTS STANDARD COST MODEL BY POINTS ((whole burdens instead of whole burdens instead of ““burden burden ingredientsingredients””))

GOVERNMENTOF SPAIN



PUBLIC SERVICE

Administrative Burden Reduction (Standard Cost Model)AdministrativeAdministrative BurdenBurden ReductionReduction (Standard (Standard CostCost ModelModel))

However, there are some flaws in the Standard Cost Model that we could not overlook. They are similar to the problems with low-calorie diets as prescribed by doctors and nutritionists. The method is complex, and it


4

requires data that can be difficult to collect, for you need to rate different burdens and measure their individual cost. Sometimes this task has to be outsourced and performed by consulting firms. So, even before launching this programme, the Government of Spain knew we were facing big challenges. The first is its own character, for Spain is a highly decentralised country. Autonomous Communities are self-governed entities with lots of competencies, and there are over 8,000 (eight thousand) local governments. Thus, right from the start, we relied on the ideas and the cooperation of Autonomous Communities and local governments to jointly design a model of our own. This is why the model is also called “Public Administration Shared System.” Secondly, the resistance to change in the traditional administrative culture of our government agencies and, finally, the task’s inherent complexity. These are some of the reasons why it was necessary to have a more accessible version of the Standard Cost Model. Moreover, the overlapping administrative structure made necessary to increase the administrative burden reduction goal from 25% common aim, to 30%. Besides, we decided that we should have one shared model to facilitate data comparison. In addition, our strategy comprised a Government Action Plan including the following measures: - The simplification of administrative burdens should be part of the Report on Regulation Impact Assessment (RIA).

GOVERNM E NTOF SPAIN

VICE PRESIDENCYOF THE GOVERNMENTOF TERRIT ORIAL POLICYMINISTRYOF TERRIT ORIAL POLICY AND PUBLIC ADMINISTRATION

S ECRE TA RY OF STAT E FO R

PUBLIC SE RVICE

Spanish RIA Executive Summary (to be made by the administrative unit which proposes the regulation)

Spanish RIA Executive Summary (to be made by the administrative unit which proposes the regulation)

Reduction of administrative burdensQuantitative estimate: €6,740,000

Introduction of new administrative burdens€21,000,000

No effects on administrative burdens

Effects on administrative burdens

No signif icant effects on competition

Positive effects on competition

Negative effects on competition

Effects on competition

No significant effectEffects on the economy as a whole

ECONOMIC AND BUDGETARY IMPACT

This Royal Decree follows the provisions in Article 149.1… of the Constitution, assigning the State exclusive competencies in the f ield of…

COMPETENCE ADEQUACY

IMPACT ASSESSMENT

- The benefits of administrative burden reduction were extended to the regulations affecting citizens. - Six out of the thirteen areas suggested by the European Commission were selected that are related to competitiveness and employment: Corporate Law, Tax Regulations, Statistics, Public Procurement, Environment, and Labour Relations.


5

- The Government promoted a significant package of broad-scope legislative measures in the wake of the EU Services Directive (Umbrella Law and Omnibus Law) and beyond, also making commitments to regulation quality improvements; for instance, improvements in the consultation system with stakeholders and ex-post evaluation, in the recently passed Law for a Sustainable Economy. - Six agreements were signed by the Council of Ministers in the past three years containing 283 (two hundred and eighty-three) measures (fast-track actions) aimed at the reduction of the administrative burdens for both companies and citizens. - The simplification introduced by twenty new e-services and the enforcement of the Services Directive was assessed and measured. - And hotlines were set up with the leading business organisations: CEOE, CEPYME, and Chambers of Commerce.

GOVERNM ENTOF SPAIN

VICE PRE SIDENCYOF THE GOVERNMENTOF TERRIT ORIAL POLICYMINISTRYOF TERRIT ORIAL POLICY AND PUBLIC ADMINISTRATION

S ECRETA RY OF STAT E FO R

P UBLIC SERVICE

Based on Standard Cost Model and adapted to the Spanish territorial model

Agreed by consensus with all government agencies

Allowing the identification and uniform measurement of administrative burdens by all government agencies

Offering mechanisms to eliminate or reduce burdens

Based on past experience

Used as guidelines for civil servants

Main Characteristics of Spanish Simplified MethodMain Characteristics of Spanish Simplified Method

So now I can tell you about Spain’s simplification of the Standard Cost Model. Instead of breaking down an administrative burden into its components and assigning each of them an average cost, we took advantage of the measurements of the first three agreements by the Council of Ministers by consulting firms using the Standard Cost Model proper to identify the administrative burdens of companies (finished dish) according to the data collected and assign them an indicative cost in accordance with checked statistical information. This was done with the consent of the Regional and Local Spanish Administrations.


6

GOVERNMENTOF SPAIN



PUBLIC SERVICE

Simplified Burden Measurement MethodSimplified Burden Measurement Method

Time (H) Labour costs (T) Procurement (A) andexternal costs (E)

Number of affected

companies (N)

Frequency ofcompliance (F)x+x

Coste por actividad Número de actividades al añoXX

Datos obtenidos de la Legislación y de los Centros Gestores

Datos Estimados

REGULATION

Administrative burden

Coste UnitarioCoste por actividad Number of activities per yearXX

Data from laws and administrative centresPredetermined data

Individual cost

As you can see, we took into account specific activities like submitting a form, submitting documents, or submitting a report, introducing another table to measure those burdens that did not fit any category of the list shown.

GOVERNMENTOF SPAIN



PUBLIC SERVICE

1. Submission of print form €802. Submission of e-form €53. Procedures through intermediaries (banks, doctors, etc.) €354. Traditional submission of required documents, invoices, and others €55. Potential submission of a communication €306. Electronic submission of a communication €2 7. Electronic submission of required documents, invoices, and others €4 8. Provision of data €29. Submission of certified copies (added to cost of document) €110. Submission of reports €50011. Obligation to keep documents €2012. Traditional registration €11013. Electronic registration €50 14. Book keeping €30015. Electronic book keeping €15016. External audits and controls €1,50017. Information disclosure to third parties €10018. Legalisation of facts or documents in public documents €50019. Obligation to communicate or publish information €100

Checklist and Table of Burden CostsChecklist and Table of Burden Costs


7

GOVERNMENTOF SPAIN



PUBLIC SERVICE

• 1. Automatic renewal of authorisations and licences €175• 2. Proactive procedures €100• 3. Immediate response to procedures €200• 4. Shorter response times from government agencies **• 5. Special help systems to complete procedures €30• 6. Information campaigns for stakeholders €15

** Range of values according to reduced time

Cost Reduction Measurement Table (when main table is not applicable)Cost Reduction Measurement Table (when main table is not applicable)

Although the list shows 19 activities, regulation assessments from 2007 onwards show the most frequent administrative burdens are applications, communications, attachment of documents or reports, and conservation of data (5 out of 19).

GOVERNMENTOF SPAIN



PUBLIC SERVICE

-Forms (in authorisation systems)

-Communications (in responsible statement or previous communication systems)

-Documents attached to a form or communication

-Mandatory reports and audits

- Mandatory conservation of documents and book keeping

Most Frequent Administrative Burdens (90%)Most Frequent Administrative Burdens (90%)


8

The examples here show how, on the whole, the resulting method was quite friendly-user and agile.

GOVERNMENTOF SPAIN



PUBLIC SERVICE

• Example

Law 0/2011, regulating study grants abroad

Art.5: Interested citizens must submit a form at the administrative register

Art. 6: The form must be accompanied by the following certified copies:

1. Academic degree

2. Grade certificate

3. ID card

4. Family record

• Burden reduction mechanisms

• Art. 5: Interested citizens must submit a form at the administrative register or using an e-channel

• Art. 6: The form must be accompanied by the following certified copies:

• Grade certificate

Identification of Administrative BurdensIdentification of Administrative Burdens

GOVERNMENTOF SPAIN



PUBLIC SERVICE

240,000 €3,00080Submission of

Total cost (€)Number of filesPopulationFrequencyQuantityIndividual

cost (€)Administrative burdens

240,000 €3,00080Submission of



15.000 €3,0005Submission of print form



15.000 €3,0005Submission of print form



1. When fishing products unloaded are not for sale or are sold later in time, their product or legal representative must fill in the catch report form and submit it to the relevant agency of the regional government.

1. When fishing products unloaded are not for sale or are sold later in time, their product or legal representative must fill inthe catch report e-form and submit it to the relevant agency of the regional government.

Royal Decree XXXX/2009Article 6.1

Royal Decree XXXX/2004Article 6.1

IDENTIFICATION


9

Once the values were agreed upon by all government agencies, the General Administration developed a software application to implement the new system which we called APLICA. The following slides show the differences between the EC burden calculator and the Spanish application. The EC calculator, a tool of great technical quality, requires considering the time and cost of each administrative burden for the population of final users affected, including factors like getting familiar with the burden, training the staff, using files, and up to 14 different items.

GOVERNMENTOF SPAIN



PUBLIC SERVICE

The Calculator 1/2The Calculator 1/2


10

GOVERNMENTOF SPAIN



PUBLIC SERVICE

The Calculator 2/2The Calculator 2/2

On the other hand, the Spanish model makes it possible to calculate the value in euro of the most frequent activities, such as submitting a form in person (€80) or submitting electronically (€5). So you just need to identify the type of burden and then you get its value, which multiplied by the frequency of the burden and the population it affects, gives you the final cost of the administrative burden. When it is not easy to identify a burden’s frequency and population, you can substitute these inputs by the number of files processed per year.

GOVERNMENTOF SPAIN



PUBLIC SERVICE

DIRECTORATE GENERAL OF ADMINISTRATIVE ORGANISATION AND PROCEDURES

Deputy Directorate General of Procedural Regulation Simplification and Improvement

Software Application for Administrative Burden Measurement


11

GOVERNMENTOF SPAIN



PUBLIC SERVICE

IdentificationIdentification ofof MeasurementMeasurementDetailedDetailed MeasurementMeasurement

GOVERNMENTOF SPAIN



PUBLIC SERVICE

AddAdd, , deletedelete, , copycopy, , andand changechangeburdensburdens in in measurementmeasurement

This model would be useless, however, if the measurements were not accurate so the Authorities of Spain decided to send out the amendments made to the model to an consulting firm that validate the method as they


12

came to the conclusion that the results obtained with the Spanish application were practically equivalent to their own measurements, although the results obtained with our table were slightly lower than those calculated by them. In our opinion, the objection that our system led to underestimate the value of burden does not invalidate the system but makes it even more reliable by introducing a principle of prudence. So, coming to this point, is the moment to wondering ¿has it worked? ¿what are the concrete results of Spain’s administrative burden reduction programme by applying this method? As you can see, the estimated savings so far total more than €10,000 million (ten thousand million euro). More than the half of this amount is related to burdens affecting companies (€5,385,367,606), while the other half is associated with citizens. Nevertheless, we know that the system needs consolidate itself. This is why we have offered training courses to civil servants to good results, but several improvements still have to be made. Thanks to the system’s lack of complexity, almost half of the assessments of administrative burden included in regulation impact assessments have been done in a satisfactory way. In general, our experience with the application of a more accessible version of the Standard Cost Model has been positive. We have managed to implement a plan to reduce administrative burdens in Spain solving a series of difficult initial problems. The current financial crisis requires imaginative and innovative responses and one example is our adaptation of this system that enables us to apply the Standard Cost Model without resorting to external consultants, which means significant budget savings.

GOVERNMENTOF SPAIN



PUBLIC SERVICE

ADMINISTRATIVE BURDEN REDUCTION MEASURED SO FARADMINISTRATIVE BURDEN REDUCTION MEASURED SO FAR

END-USERS REDUCTION (€)

Businesses 5.710.226.264 €

Citizens 5.027.427.670 €

Total 10.737.653.934 €


13

GOVERNMENTOF SPAIN



PUBLIC SERVICE

HIGH LEVEL GROUP OF INDEPENDENT STAKEHOLDERS ON ADMINISTRATIVE BURDENS:The Spanish Experience with The Standard Cost Model: Making It Work

THANK YOU FOR YOUR ATTENTION!

HIGH LEVEL GROUP OF INDEPENDENT HIGH LEVEL GROUP OF INDEPENDENT HIGH LEVEL GROUP OF INDEPENDENT STAKEHOLDERS ON ADMINISTRATIVE BURDENS:STAKEHOLDERS ON ADMINISTRATIVE BURDENS:STAKEHOLDERS ON ADMINISTRATIVE BURDENS:The Spanish Experience with The Standard Cost The Spanish Experience with The Standard Cost Model: Making It WorkModel: Making It Work

THANK YOU FOR YOUR ATTENTION!THANK YOU FOR YOUR ATTENTION!THANK YOU FOR YOUR ATTENTION!

Before concluding, I would like to mention the valuable work being done by the High Level Group led by Dr. Stoiber. If there are regulations that can help us accomplish public goals in more efficient ways, we must take them as a benchmark to improve our own. We must do more with less; therefore, regulatory improvements must be on every government’s agenda. I would like to conclude by thanking all of you for your excellent work so far, and asking you to keep working. Your conclusions will be extremely useful and necessary to European businesses and citizens now and in times to come. Thank you very much for your attention. If you have questions or comments, please share them with me. And if you need additional information, you can ask for it by email or any other means.


14

GOVERNMENTOF SPAIN



PUBLIC SERVICE

PleasePleasePlease, I, I, I welcome your suggestions, welcome your suggestions, welcome your suggestions, comments or questions!comments or questions!comments or questions!

[email protected]@[email protected]