The Impact Assessment Board (IAB) is the European Commission internal oversight body providing quality control and assistance to the services on Impact Assessment (IA). IAB acts independently from the various Directorates-General, and it accounts directly to President Barroso. IAB reports on its activities annually and the latest report was published at the end of January, covering IA performance during the year 2010.
The document is to be welcome. General improvements are emphasised, notably on procedural matters -- for instance the increased rate of timely submissions by the services of draft IAs to the Board, which allows for better planning, and the more diffused practice to consult on early stages. But what strikes most is the fact that this year's report is far less indulgent than the previous ones (although you have to read the entire document before coming to such a conclusion). IAB clearly states that the IA system in the Commission has now reached cruising speed, and services are expected to deliver substantially more than it is currently the case: the Board "does not yet feel that a sufficient quality standard is being met on a consistent basis." (p.23) Such clear stance signals a firm commitment to now thoroughly look into more "evidence-base". This is not necessarily reflected by the statistics provided. As IAB itself qualifies, these are only relatively significant, for scrutiny criteria have been tightened compared to the previous years. More interesting are the concrete examples of how the intervention of IAB has actually changed the course of decision-making within the Commission, leading services to change their initial proposals (p.18-20). Those examples prove that IA should be an iterative, structured process, and not just drafting an analytical report.
But the content and quality of the (economic) analysis also matter. In this respect, the report could have been more explicit on the ways forward to further improve current performance (p.22-25). Especially considering that only one quarter (27%) of all draft IAs examined in 2010 were based on "comprehensive quantitative modelling" (p.22 - but what does this means concretely?), it would be interesting to investigate what are the actual causes for such difficulties, and it is legitimate to ask for more information on what are the concrete remedies IAB intends to apply to tackle this deficit.
One may wonder why it took four years for IAB to reach such a level of scrutiny. The logics of learning and acceptance followed by IAB so far may be well placed here. By progressively turning the screws of its oversight, IAB has consistently profiled itself as a help-desk support to the services rather than a sanctioning and naming&shaming gatekeeper. As a result, its internal legitimacy and credibility have arguably increased, although it is difficult to imagine that the quality control precess always unfolds without tensions and resistance. As one former OIRA/OMB administrator put it, a certain discontent among line departments is actually healthy for it is the sign that the central oversight body is doing its job properly. IAB has let the services know that it is now doing its job as it should, and all the services must count with it (LA).
The document is to be welcome. General improvements are emphasised, notably on procedural matters -- for instance the increased rate of timely submissions by the services of draft IAs to the Board, which allows for better planning, and the more diffused practice to consult on early stages. But what strikes most is the fact that this year's report is far less indulgent than the previous ones (although you have to read the entire document before coming to such a conclusion). IAB clearly states that the IA system in the Commission has now reached cruising speed, and services are expected to deliver substantially more than it is currently the case: the Board "does not yet feel that a sufficient quality standard is being met on a consistent basis." (p.23) Such clear stance signals a firm commitment to now thoroughly look into more "evidence-base". This is not necessarily reflected by the statistics provided. As IAB itself qualifies, these are only relatively significant, for scrutiny criteria have been tightened compared to the previous years. More interesting are the concrete examples of how the intervention of IAB has actually changed the course of decision-making within the Commission, leading services to change their initial proposals (p.18-20). Those examples prove that IA should be an iterative, structured process, and not just drafting an analytical report.
But the content and quality of the (economic) analysis also matter. In this respect, the report could have been more explicit on the ways forward to further improve current performance (p.22-25). Especially considering that only one quarter (27%) of all draft IAs examined in 2010 were based on "comprehensive quantitative modelling" (p.22 - but what does this means concretely?), it would be interesting to investigate what are the actual causes for such difficulties, and it is legitimate to ask for more information on what are the concrete remedies IAB intends to apply to tackle this deficit.
One may wonder why it took four years for IAB to reach such a level of scrutiny. The logics of learning and acceptance followed by IAB so far may be well placed here. By progressively turning the screws of its oversight, IAB has consistently profiled itself as a help-desk support to the services rather than a sanctioning and naming&shaming gatekeeper. As a result, its internal legitimacy and credibility have arguably increased, although it is difficult to imagine that the quality control precess always unfolds without tensions and resistance. As one former OIRA/OMB administrator put it, a certain discontent among line departments is actually healthy for it is the sign that the central oversight body is doing its job properly. IAB has let the services know that it is now doing its job as it should, and all the services must count with it (LA).
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