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WHITE PAPER

Designing KPIs for improved Public Sector PerformanceHow to turn data into actionable information for better decision making

DESIGNING KPIs FOR IMPROVED PUBLIC SECTOR PERFORMANCE

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Foreword

Public sector organisations of all types are facing intense pressure to do more with less and better match their priorities with the needs of citizens. Governments in almost all the countries in the world are feeling some sort of fiscal squeeze.

Pressures on governments are forcing them to adopt enterprise performance management methodologies – a focus on accountability for outputs and outcomes rather cries for higher inputs (i.e., more budget funding and employees). Core methodologies include performance indicator scorecards and dashboards, visual strategy diagrams, advanced costing methods and driver-based budgeting.

The emerging interest in identifying strategic KPIs and operational PIs comes from the old adage: “If one cannot measure it, one cannot manage it. If one cannot manage it, one cannot improve it.” Evidence that this is relevant today comes from a recent survey by Accenture that reported that most organisations are far from where they want and need to be when it comes to implementing measures and analytics and that they are still relying on intuition, rather than hard data, when making decisions. Performance indicators are collectively intended to align manager and employee behaviour priorities with their limited resources to focus on the organisation’s strategic priorities and objectives.

One could also argue that an organisation does not really have a strategy, but rather it has its leadership team’s vision of where they want their organisation to go. The linked strategic objectives, like the musical instruments in a Beethoven symphony, then become the strategy. This is not about every instrument playing loudly, but rather playing together in harmony.

There is confusion and lack of consensus as to what KPIs, scorecards and dashboards are. To complicate matters, organisations struggle with properly identifying their correct KPIs. Regardless of which KPIs they select, a problem is they often identify hundreds of them. This begs questions like: How can they all be a ‘K’ – key measure? How does one determine them? Are there different purposes for KPIs and their scorecards and for PIs and their dashboards? And once KPIs are agreed on, how challenging or not should the target quantities be to motivate achieving them?

A lesson learned from experience is that scorecards and dashboards should be viewed more as social tools than technical ones. Software technologies support these methodologies, but unlike transactional systems, this type of software involves flexible modeling. Software is an enabler and can assure higher data integrity, visualisation and timely reporting with analysis compared to manual or spreadsheet alternatives.

Another lesson learned is the importance of cascading the strategic measures downward into the organisation with cause-and-effect relationships. This is superior to simply displaying dozens of KPI dials without understanding how changes in one KPI affect others. Advanced scorecard software includes statistical correlation analysis to evaluate the explanatory power of KPIs. This can assist in validating the correctness of the measures.

Gary Cokins MBA Manager, Performance Management Solutions, SAS [email protected]

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Table of Contents

Foreword ............................................................................................................. iExecutive Summary ..........................................................................................1Introduction .......................................................................................................2Defining KPIs .....................................................................................................3 What is a KPI? .............................................................................................3 Why are KPIs important? ............................................................................4 What does a KPI look like? .........................................................................4 KPI Scorecards v Dashboards ...................................................................5 How analytics can help establish KPIs .....................................................6Setting and Measuring KPIs ...........................................................................6 Set the strategic vision ...............................................................................6 Establish a supporting information infrastructure ...................................7 Align to deliver your strategy .....................................................................8 How can analytics help deliver objectives? ..............................................8Communicating KPIs ........................................................................................8 Effective communication ............................................................................8 Visual tools for communication ............................................................. 9 Creating a communication culture .........................................................10 Balancing internal and external pressures .............................................11Final Thoughts ................................................................................................11Examples of Effective KPI Management in the Public Sector ..................11About SAS in the Public Sector .....................................................................13About SAS Strategy ........................................................................................13SAS Public Sector Partners ...........................................................................14



1

Executive Summary

Priorities are always shifting in government according to new political appointments, world events, demographic changes and changing environments. This can mean it is difficult for public sector managers to measure performance as goal posts constantly shift. However, that does not mean performance management can be overlooked – in fact, in may be the most effective way to achieve policy and strategic objectives.

As the economy dips and belts tighten, the public is even more aware of how taxpayer funds are spent; and they want to be reassured of continual improvements, efficiencies and revised priorities. A major part of delivering the accountable and transparent government pledged by the Prime Minister is setting and, more importantly, communicating an appropriate strategic vision as well as implementing the supporting infrastructure.

Executed well, Key Performance Indicators (KPIs) are the right way to measure performance. But all too often KPIs are set against operational or financial points of measurement with no clear link back to the strategy.

Public sector managers should focus on communication of the KPIs in an effective manner and quantifying performance in meaningful ways to gain staff buy-in if they want to credibly demonstrate success. The journey is not easy, and there are many challenges – both with culture, resources and technology – but progress can be made with the right approach.

This white paper sets out a series of best practice approaches to help public sector managers set correct and measurable KPIs. Crucially, it explains how to turn data into actionable information so better decisions can be made about how to improve services for citizens.

This paper seeks to answer the following questions:

• What is a KPI?

• Why are KPIs important?

• How do you define KPIs?

• What are the differences between KPIs, policy objectives and targets?

• What is the difference between KPIs and operational performance indicators (PIs)?

• How do you set and measure effective and strategic KPIs?

• How do you establish a communication culture?

• Where are the most effective examples of effective KPIs in government?

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Introduction

With the spotlight on every government department to produce detailed plans in line with the spending cuts, there is a renewed focus on managing performance to ensure every organisation is delivering, to improve frontline services.

If government is going to achieve its policy objectives with the current or reduced levels of resources available, then it needs to become more effective at executing strategies effectively and efficiently. This need for policy objectives is reflected in increased demands for government departments, and their agencies, to be both transparent and accountable to the public.

KPIs are an essential tool for improving services for citizens. But, gaining staff buy-in, establishing the right strategic vision and implementing sound processes can be challenging.

The private sector has long known that high levels of internal transparency and accountability are critical in effective strategy execution. Consequently KPIs have been adopted by many companies as a powerful tool to support strategy.

Measuring KPIs should be about extracting value from data and turning it into actionable information that can be used to align staff work activities, behaviour and priorities with the strategic and policy objectives, and to make continued improvements to frontline services. Implemented well, KPIs can have a dramatic impact on a government department. But, as with any such initiative, a successful implementation needs to be well thought through, and delivery can disappoint if approached the wrong way.

SAS has been at the forefront of providing effective corporate performance management systems, powered by predictive analytics, for private and public sector organisations in the UK and internationally for over 30 years.

In this paper we share some of the practices that we have found help managers deal with both internal and external pressures to formulate effective and appropriate KPIs, that not only measure performance but also point to prioritised areas for continued improvements.

If government is going to achieve

its policy objectives with the current

or reduced levels of resources

available, then it needs to become

more effective at executing

strategies effectively and efficiently.


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Defining KPIs

What is a KPI?

There are many measures that are important to an organisation, government department and team for monitoring achievement of policy objectives, actual results against targets, and departmental and personal job performance. But there is also often confusion between types of measurement, all of which have their place, making it difficult for managers to agree on which types are relatively more or less important.

KPIs provide government departments with a way of ensuring that policy objectives will be achieved in the future. They provide a framework to ensure policy objectives will achieve the desired outcomes, and that strategies are translated into action. Critically, they provide management teams with an early warning system that policy objectives may not be met as a result of internal shortcomings.

KPIs should not be confused with policy objectives and their measures of the external environment. KPIs monitor how well policy objectives are met. Since changes to the external environment require reactions that cannot always be planned for, some KPIs are added and some removed or targets for existing ones are adjusted. In short, KPIs are a measure of current activity and desired outcomes that will have an impact on a department’s ability to deliver on policy objectives and targets in the future.

KPIs provide government

departments with a way of ensuring

that policy objectives will be

achieved in the future. They provide

a framework to ensure policy

objectives will achieve the desired

outcomes, and that strategies are

translated into action.

Fig 1: The relationship between KPIs, policy objectives and targets

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Why are KPIs important?

The approach to performance management is changing as the government strives to provide greater transparency, ‘openness’ and accountability. In this time of change and drive for greater efficiency in this ‘age of austerity’, performance management is firmly under the spotlight.

Public sector managers need to ensure they can set the right strategic KPIs to measure and improve both short and long-term performance initiatives, otherwise managers risk scrutiny from increasingly cynical UK taxpayers.

KPIs provide a mechanism for moving an organisation, department or team from a management style that reacts to the past performance to a department delivering on its policy objectives. Focusing the management and staff on what needs to be done to maximise the probability that future policy objective outcomes will be achieved, will increase long term success, reducing costly reactive actions and the risk of failure.

What does a KPI look like?

KPIs will differ between organisations, and should be defined according to what success looks like for a department or team. To be successful, the strategic vision should be specifically tailored to the organisation’s goals.

For example, success in a hospital may be to reduce the incidence of deaths as a result of breast cancer. To measure success, hospital management might establish a framework that measures progress against that goal and defines how progress is reported. A KPI for the hospital could be to find a way to increase the number of mammograms, leading to a higher incidence of detecting breast cancer at an early stage and reducing the number of deaths.

There are a number of defining characteristics a KPI should have, such as;

• Having a clearly accountable owner, at a senior level

• Being controllable by the owner

• Making a significant impact on current or future performance

• Be aligned to the departmental strategy

• Having a defined level of success to deliver the desired policy objective outcome

• Can be financial, non-financial or a progress metric typically monitored at the level of government department or agency.

One of the biggest and most common mistakes is setting too many KPIs. Whilst a policy objective could have up to 20 KPIs, an individual team within a government department or agency should have fewer. These should either derive from, or contribute explicitly to, a subset of the wider departmental policy objectives.


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KPI Scorecards v Dashboards

There is confusion about what the difference is between a balanced scorecard and a dashboard. The two terms – scorecards and dashboards – have a tendency to confuse, or rather get used interchangeably, when each brings a different set of capabilities. The sources of the confusion are:

• Both represent a way to track results

• Both make use of traffic lights, dials, sliders and other visual aids

• Both can have targets, thresholds and alert messages

• Both can provide drill-down to other metrics and reports.

The difference comes from the context in which they are applied.

Scorecards chart progress toward strategic objectives. A scorecard displays periodic snapshots of performance associated with an organisation’s strategic objectives and plans. It measures organisational activity at a summary level against pre-defined targets to see if performance is within acceptable ranges. Its selection of KPIs helps executives communicate strategy to employees and focuses users on the highest priority projects, initiatives, actions and tasks required to execute plans. The adjective ‘key’ differentiates KPIs from the PIs reported in dashboards.

Dashboards monitor and measure processes. A dashboard, however, is operational and reports information typically more frequently than scorecards and usually with measures. Each dashboard measure is reported with little regard to its relationship to other dashboard measures. Dashboard measures do not directly reflect the context of strategic objectives.

In summary, scorecards are intended to be strategic. They align the behaviour of employees and partners with the strategic objectives formulated by the executive team. In contrast, dashboards are intended to be operational.

A scorecard’s selection of KPIs helps

executives communicate strategy to

employees and focuses users on the

highest priority projects, initiatives,

actions and tasks required to

execute plans.

Fig 2: Key Performance Indicators v Performance Indicators

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How analytics can help establish KPIs

There are a number of ways that analytics can help managers to identify effective KPIs. Faced with a choice of different measures, all of which potentially affect a policy objective, analytics can help to identify which one or two measures had the greatest impact on the policy objective in the past, and therefore which of these measures should be selected as a KPI.

Analytics can also provide information on which KPIs will be most relevant in the short- and the long-term. It can also tell you about the impact of external variables that can affect the outcome, as well as factors outside a department’s control but within the control of other government departments and agencies, which have a direct bearing on the ability to achieve the policy objectives.

Specifically analytics can help identify the:

• Key variables when several potential candidates exist

• Extent that policy objective outcomes can be influenced, and to what extent dependent factors are outside of your control

• Factors which may be influenced by other government agency policies or performance

• Time period over which the variable has influence

• Amount of resources you need to achieve the desired policy objective target, thus reducing the risks of under/over resourcing the activities to attain the KPI’s target.

Setting, Measuring and Delivering Key Performance

Taking the right steps to providing meaningful KPIs for your department is a vital part of delivering your policy objectives. You will need to: set the strategic vision; establish a supporting information infrastructure; and align your budget and teams to deliver your strategy.

Set the strategic vision

Government policy objectives require an appropriate delivery strategy to be developed. Establishing a clear strategy is of paramount importance before you select your KPIs, because it is from them that the KPIs are derived. Defining the right metrics helps communicate the executive team’s strategic vision and aligns the workforce’s activities and priorities. It is at this time that strategy maps provide a powerful tool for senior managers to visualise their strategy and its critical linkages as they develop it.

Analytics can help to identify

which one or two measures had

the greatest impact on the policy

objective in the past, and therefore

which of these measures should be

selected as a KPI.


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Establish a supporting information infrastructure

Defining the processes and supporting infrastructure that will enable the public sector to achieve the targets set for KPIs is one of the more important and complex aspects of performance management. It is not just about monitoring the dials of a KPI scorecard but rather moving the dials!

Implementing the following critical success factors will ensure support for realising the strategic vision and attaining the targets of its underlying KPIs.

• Educate civil servants – Use training and feedback to show the value of keeping data up-to-date; communicate the financial and social implications of reducing human error to improve data quality.

• Maintain clean data – Ensure that data entry is ‘fool proof’ to prevent error, including automated checks to spot anomalies and missing data. This will ensure data is accurate, ‘trusted’ and, most importantly, used by staff.

• Move from data to information - Answering the following questions will enable policies, procedures and processes to generate the data, convert it into information, and support better, more informed decisions.

o Relevant questions, such as:

- What problems do we need to resolve?

- What data is most valuable for making those decisions to solve this problem?

- What are the sources of that data? How can we automate its collection?

o There are far greater levels of data within government, compared with private sector companies. Most organisations are drowning in data but starving for information. The challenge is how to structure data so that it can be transformed into information that is then useable and accessible to authorised civil servants.

• Develop role-specific reporting – Ensure that reports align with the roles and positions of the individuals using them, and make continual changes to improve the value they offer those roles.

• Tailor KPIs – It’s essential that KPIs are tailored for individual government departments, agencies, NHS or local government and educational organisations. A ‘one size fits all’ does not take into account the nuances of the organisation’s individual strategy and plan.

• Track how reports are being used – Make changes to improve the usability of reports. Reports that are not helping to control or improve departmental and government performance should be evaluated or be discontinued.

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Align to deliver your strategy

No matter how well conceived or communicated a strategy is, it will still fall short of its expected results if the teams within the department do not take the necessary actions to deliver the strategy. Individual teams need to align their work activities with their local objectives comprised in the strategy. They should attempt to determine the level of resources and spending required to deliver on their objectives, and negotiate for them if they are insufficient (or at least signal the adverse impact without the required resources).

Top-down selection of staff projects or processes for improvement to attain the senior management’s strategic objectives without staff involvement has fallen out of favour in the private sector. Based on the defined objectives, staff involvement in project identification and process improvement candidates as well as the associated KPIs not only creates greater buy-in and commitment by staff, but is important as it assures that staff understand what the executive team’s strategy is. This type of bottom-up approach is now more common. Each team defines its local activities and projects as well as their KPIs and then demonstrates that they will support the delivery of policy objectives. Typically, a team would expect to be responsible for supporting only those KPIs they can directly influence, which would be a subset of all the KPIs.

How can analytics help deliver objectives?

As any manager knows, it is not wise to set objectives without the resources needed to deliver them. So a team’s objectives should play a significant role in the budget settlement for that team. Predictive analytical models, such as Activity-Based Costing (ABC) models, allow a department to understand the relationship between resource inputs, KPIs, and policy outcomes. Providing a validated model describing the relationship between inputs and outcomes removes the subjectivity from the discussion and reduces the risk of both padding and under-resourcing of budgets.

Communicating KPIs

Effective communication

One of the biggest reasons for strategy implementation to fall short in translating it into action is due to inadequate or non-existent communication of the executive team’s strategy to its employees . Experience from commercial businesses shows that communication needs to be clear and accessible to all relevant staff. The strategy map communicates how accomplishing its various objectives achieves the strategy. The KPIs are an element but more for steering and controlling, not identifying the destination.

Staff involvement in project

identification and process

improvement candidates as well as

the associated KPIs not only creates

greater buy-in and commitment by

staff, but is important as it assures

that staff understand what the

executive team’s strategy is.


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Effective communication is twofold. First, a plan needs to be established with a sufficient level of detail while ensuring there is some flexibility built-in to allow for changes. Secondly, it should be adequately communicated to ensure that the team knows what the plan is and understands how to execute on it, to encourage their buy-in.

Staff involvement in the identification of KPIs, tied to pre-defined objectives, gives staff a sense of ownership and buy-in. This behavioural aspect is important because they will ultimately be held accountable. Ultimately, all staff should understand:

• What the KPIs are for the government department as well as their own team

• Why these KPIs are critical to success

• How they impact on the policy objective targets

• Who is accountable for their delivery

• What the targets are for the KPI and how they were determined.

Visual tools for communication

Some organisations prefer to use powerful visual motifs to measure and track progress against objectives.

For example, police forces might accompany their strategy map with a visualisation map to display crime trends. This enables them to deploy the right types and levels of resources at the right time. It also allows teams to map their progress against the plan straight away, helping to foster a culture of accountability.

Below is an example of SAS’ headquarters overlaid with the KPIs associated with its sustainability strategy. To measure its actual progress against the targets set for its KPIs, users can click on the building then the image zooms in with more detailed programmes and measures displayed. Visual maps that reveal critical programmes and KPIs in a context help to reinforce the communication of the strategy.

Fig 3: Visual Map of SAS Headquarters

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Creating a communication culture

Gaining staff buy-in, acceptance and commitment is the primary challenge for effective and timely reporting of KPIs. Fostering a culture of accountability mainly comes down to earning staff buy-in – a complicated task that is often overlooked.

But it’s crucial that managers communicate to staff why accurate and timely reporting of KPIs is important and how changes will benefit the individual as well as the government department or agency. A vital component is educating employees that KPIs should not be seen as a threat or a tool to expose them but a measure to ensure that all the good work that is being achieved is on track and aligned with attaining the strategy and its related objectives.

Public sector managers have the weighty responsibility to encourage people to adopt new ways of working in order to move in a better or revised direction. This can only be achieved by communicating the benefits of this new way of working and delivering measured improvements.

Realigning the cultural framework takes time, firm guidance and initiative. Below is an outline of practical recommendations for successfully creating a communication culture.

• Establish a change agent – Select a senior person within the agency or department as a visionary, champion or change agent. This individual must have the drive, authority and power to instigate real change through persuasion to help staff to get on board. Alternatively, hire an external consultant who is responsible for spearheading change.

• Align processes and organisations with KPIs – Marrying processes with KPIs will ensure that each KPI is well-resourced and assign individual responsibility. Establish a ‘feedback loop’ to see how well processes are working and to determine how they may need to be tweaked or eliminated to maximise efficiencies.

• Start with small changes – People are naturally resistant to change. Communication and understanding are key so that teams comprehend the relevance of the KPIs and how and when they will be monitored. To get teams on board you could start with low-risk changes to slowly earn support from staff.

• Recognise that there is no ‘one size fits all’ – Every government organisation is different and best practices should be customised to suit different ways of working, to be successful. Sharing success and failures with other departments will help encourage continual improvements to services and foster co-operation between government departments.

• Understand who your audience is – Know the aspects that are most likely to motivate employees to adapt and use them to help communicate and introduce cultural changes.


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Balancing internal and external pressures

Unlike the private sector, the public sector has a responsibility to make public any changes to its management, vision or strategy often before plans have been crystallised and communicated to staff. This can sometimes have an adverse impact on employee morale.

This environment sometimes can mean that KPIs may be misinterpreted by staff as management setting arbitrary metrics to justify reductions in spending. This in turn makes it difficult to effectively communicate why KPIs are being established and how they will help to improve measurement and ensure accountability.

It is clear that public sector managers have additional challenges when it comes to KPI setting. In government, it can be difficult to gain a cross-government view of information across vast amounts of data and many grapple with a lack of integrated databases, and the quality of data. These challenges mean the effective and successful communication of the role of performance management, is more important than ever.

Final Thoughts

There’s no getting away from it, implementing KPIs, whether in a government department, unit or team, takes a lot of thought and hard work. With the need to deliver on policy objectives in an efficient and timely manner, and increasing public demands for transparency, measuring performance has never been more important. But the benefits you stand to gain in terms of the focus on, understanding of, and alignment behind a common strategy are enormous.

Examples of Effective KPI Management in Action

Below is a series of examples of UK public sector organisations successfully implementing and measuring performance using KPIs powered by analytics.

Croydon Drug & Alcohol Action Team use SAS to tackle drug abuse

The Drug & Alcohol Action Team (DAAT) in the London Borough of Croydon has deployed SAS® Analytics to automate statutory reporting, using the time saved for value-added analysis to improve joined-up working at a local level. SAS helps the team to monitor agency performance, perform the annual Needs Assessment, budget more effectively and target resources to have the biggest impact. The DAAT has also started to carry out analysis across quarterly Green Reports to identify trends, predict future behaviours and so enable more effective preventative action.

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London Fire Brigade predicts fire risk and saves lives

The world’s third largest fire fighting organisation uses SAS to explore risk and drive prevention strategies aimed at reducing fires, death and injury in the UK capital. London Fire Brigade can now reveal high risk areas and target resources, ensuring a focus on the biggest opportunities to protect life and property.

Gloucestershire Constabulary cleans up its data and gains new intelligence

Gloucestershire Constabulary uses SAS to ensure data quality and achieve new levels of business intelligence and reporting, helping improve accuracy and operational efficiency to enhance intelligence led policing.

NHS Blood and Transplant optimises resources to improve survival rates

The big challenge facing the UK National Health Service (NHS) in transplantation is that demand for donor organs outstrips supply. In the UK, over 7,000 patients are on waiting lists while around 3,000 transplants are performed each year. For over a decade, SAS data management and analytics have been helping increase chances of survival and improving quality of life for patients.

The National Patient Safety Agency uses SAS to minimise patient risk

The NHS is using SAS to store, manipulate, prioritise and analyse over 1.6 million patient safety reports held in its database. The database allows the NHS to identify risks rapidly to prevent patient harm and learn lessons from incidents to make improvements to the way care and treatment is organised and delivered. The project informs national goals and establishes mechanisms to track progress again the group’s objectives.


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About SAS in the Public Sector

SAS has over three decades of experience working with the public sector and more than 100 public sector customers across the UK. Its powerful predictive analytics software solutions and services enable government organisations to mitigate the risk of failure, optimise performance and accelerate the deficit reduction to ultimately provide a better service for citizens at the lowest possible cost for taxpayers.

SAS helps public sector organisations to run and defend the country, target benefits, prevent crime and increase the quality of life for citizens. It does this by cleansing, integrating and securing data to extract knowledge that supports public sector managers, policy makers and front line service staff. These customers include HMRC, DWP, MoD, Home Office, NHS, police forces and more.

About SAS® Strategy

SAS software helps companies in every industry transform their data into predictive insights to help form policy, save money and improve efficiencies.

SAS is the only company to offer a complete, integrated range of predictive analytics software and services which enable government departments to provide the foresight needed to develop preventative policies and drive performance in the public sector, including:

• Meet regulatory requirements accurately, quickly and securely

• Integrate data from a variety of internal and external sources to boost collaboration and deliver joined-up services

• Move from a reactive ‘fail and fix’ model to the ‘predict and prevent model’ essential to transforming performance.

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SAS® Public Sector Partners

The SAS® Alliance establishes powerful relationships with leading business and technology organisations. We strive to combine SAS’ analytical software expertise with our partners’ high-level industry and domain knowledge in order to present a complete solution offering for our joint customers. Together, SAS and our partners can develop and deliver the most comprehensive predictive analytics solutions for government available.

The SAS UK Public Sector team currently partner with Accenture, Atos Origin, BT, Capgemini, Deloitte, Fujitsu, HPES and others.

Suggested reading

Activity Based Cost Management in Government (ISBN 1-056726-110-8); John Wiley & Sons.

Performance Management: Integrating Strategy Execution, Methodologies, Risk, and Analytics (ISBN 978-0-470-44998-1); Management Concepts, Inc. Chapters 17, 18.

www.kpilibrary.com www.smartdatacollective.com http://bigfatfinanceblog.com/ www.information-management.com

For more information on how SAS can help your organisation with performance management and KPIs please contact SAS UK’s Public Sector team on:

Tel: + 44 1628 486933 Web: www.sas.com/uk/public_sector

SAS UNITED KINGDOM WITTINGTON HOUSE HENLEY ROAD MEDMENHAM MARLOW BUCKS SL7 2EB

+44 1628 486933 www.sas.com/uk

SAS and all other SAS Institute Inc. product or service names are registered trademarks or trademarks of SAS Institute Inc. in the USA and other countries. ® indicates USA registration. Other brand and product names are trademarks of their respective companies. Copyright ©2011, SAS Institute Inc. All rights reserved. 1181UK0211

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