Chapter 2. Auditing for greater policy coherence in Brazil

Government-wide policy coherence is the quality of having unified and consistent public policies and programmes. It requires an overarching view of the functioning of government, and often falls under the remit of central institutions. Supreme Audit Institutions too can leverage audits across public sector entities, sectors and programmes to deepen the understanding of policy coherence in government. At Brazil’s federal level, there are numerous entities with decision-making power but with little incentive or requirement to co-ordinate. A siloed approach does not work in an era marked by cross-cutting policy challenges, and intertwined commitments to sustainable development, that require co-ordinated action. This chapter explores how Brazil’s supreme audit institution, the Tribunal de Contas da União (TCU), can promote (i) strengthening of institutional mechanisms for coherence and (ii) an understanding of policy interactions and policy effects. It is informed by activities of other supreme audit institutions seeking to reduce waste and inefficiency across government that is borne by a lack of coherence.

  

2.1. Introduction

Government-wide policy coherence is the quality of having unified and consistent public policies and programmes. Establishing government-wide coherence relies on effective management of conflicting objectives and trade-offs, reducing waste and avoiding unnecessary redundancies in expenditure of public funds across and between levels of government. Policy coherence is critical for tackling “wicked problems,” which are policy issues that are dynamic, poorly structured, persistent and social in nature and highly intertwined with other social issues, such as climate change, immigration, poverty, nutrition, education, or homelessness (OECD, 2016a). An absence of coherence can limit the impact of intra-sectoral policies that are critical for citizens’ well-being, such as water, land use and education (OECD, 2016b; 2015b; TCU, 2015).

In Brazil, the size and complexity of the government and the existence of multiple actors with decision-making power at the federal level create challenges for maintaining policy coherence. Brazil would benefit from improved inter-ministerial co-ordination, with the Centre of Government (CoG) taking a leading role and providing necessary guidance for synergies between federal entities. Brazil could also benefit from a comprehensive mapping of policies and programmes and their interactions. Supreme audit institutions (SAIs) can play a key role in assessing the capacity and effectiveness of CoG institutions and the bodies responsible for co-ordinating individual policies or programmes.

Many SAIs have developed work streams that go beyond traditional oversight, and they have begun to assess interactions between policies and actions of multiple government entities (OECD, 2016b). In the United States, for instance, the Congress required the SAI to assess the fragmentation, overlap and duplication of policies and programmes related to high-level cross-cutting priorities of the federal government. Drawing from such practices and international principles, the OECD recommends that Brazil’s SAI, the Tribunal de Contas da União (TCU), strengthen its efforts to contribute to policy coherence by assessing institutional mechanisms that enable communication and co-ordination, as well as the policy interactions and effects that facilitate or hinder achievement of broader goals.

2.2. Overview: policy coherence at the federal level

Coherence has become increasingly important as governments respond to inter-connected challenges and advance national goals that involve multiple entities. Since 2008, more than half of OECD member countries increased the number of cross-governmental initiatives. Governments are establishing teams of experts meant to tackle particularly complex goals, such as climate change, that come in addition to inter-ministerial committees (OECD, 2014a). OECD member countries have established specific units to co-ordinate whole-of-government approaches in order to deliver services and results (OECD, 2014a).

There are three main obstacles to bringing greater coherence to Brazil’s policy making process highlighted here. The first is the nature of the decentralised policy-making environment, whereby policy implementation is carried out predominantly by its 26 diverse states and Federal District. With expectations for rapid implementation of policy reforms through the tiered Federal system, Brazil has relied heavily on testing of new approaches at the municipal level where delivery of services in rendered and where interaction with citizens occurs (Rio+ Centre, 2014). Successful programmes may then be rolled out horizontally (to other municipalities and states) and vertically (to the federal level). The inception and testing of ideas at the local level, and the range in capacity of service delivery across states and municipalities, makes it challenging to acquire a clear idea of the variety of programmes in Brazil, and their implications on one another (Rio+ Centre, 2014).

Secondly, the federal level works through its own brand of complexity that makes it challenging to bring coherence between policy initiatives. Political diversity in the Congress and in Ministries has a tendency to produce juxtaposing priorities across the national level. Thirdly, a high administrative burden may impact co-ordination across the government. The Index for Public Integrity (2016) rated Brazil’s administrative burden as the second worst in all 105 countries ranked1 . OECD work on regulatory policy shows that excessively burdensome controls can lead to a greater risk of circumvention of control processes, inefficiencies or unnecessary delays in delivering public services.2 Cutting “red tape” can improve productivity, and was increasingly sought following financial crises in the 2000’s (OECD, 2010). In Brazil, a high administrative burden is coupled with a shorter-term policy focus, denoted by the absence of long-term plans and goals in the Brazilian federal public administration, and existing siloes between ministries.

Governments may see mechanisms for policy coherence, and facilitating co-ordination, as time consuming or as an additional administrative burden. Yet, coherence is a worthwhile endeavour, particularly in times of fiscal consolidation and cutbacks, as it is a way of “doing more with less” and avoiding waste in expenditure. Coherence helps to ensure that duplication of entities’ efforts are justified according to the broader policy objectives. It helps to determine when redundancy can lead to cost savings. In many cases, seeking policy coherence requires only modifications to existing structures or processes.

Through their audit work, supreme audit institutions (SAIs) can support the achievement of international principles related to policy coherence (OECD, 2016c). For instance, some SAIs incorporate, as a focus of their audits, mechanisms for effective co-ordination or elements that aim to build the capacity of leaders to manage increasingly cross-cutting policy interventions (OECD, 2016c). Moreover, audits and evaluations that look across sectors and ministries, particularly those with shared goals, can help to improve governance and reduce redundant, incoherent or competing efforts, as described below (see recommendation 2.2.). SAIs can also carry out such assessments of governance functions, like internal control and risk management, in order to address challenges and solutions for systemic issues (see Chapter 4).

TCU’s focus on good governance in recent years includes the development of Frameworks that are relevant for assessing policy coherence. In particular, the introduction of the Framework for Evaluation of the Centre of Government (TCU, 2016a) should enable more systematic assessment of institutional mechanisms for policy coherence, as the criteria is mostly geared towards institutional mechanisms for communication and co-ordination. Most of TCU’s work that comments on communication and co-ordination in recent years has focused on the legal framework and the effectiveness and consistency in practice. Recommendations are made below as to how TCU can leverage this existing work that touches upon institutional mechanisms needed for coherence.

Like its SAI peers around the world, TCU has begun exploring mechanisms for assessing policy coherence by tapping in to its “bird’s eye view” of functioning across government. TCU’s 2011-2015 strategic plan (PET) ushered in a restructuring of “secretariats” (units), aimed to enhance co-ordination between units and to focus each unit on public governance (OECD, 2014b; 2013a). The 2013 restructuring grouped staff together by sectors to enable specialisation and communication around thematic topics. For instance, social policies are captured under one co-ordinated and specialised Secretariat (OECD, 2013a). The success of the reorganisation in giving auditors a more holistic view of governance and improving communication was disputed in discussions with a range of TCU staff across levels. Recommendations are made in Chapter 1 for TCU to further seek improvements in communication and co-ordination within TCU itself.

Between 2014 and 2016, TCU developed two key frameworks that provide criteria for the assessment of mechanisms that are critical to policy coherence. TCU’s Framework to Assess Governance in Public Policies (2014) provides potential audit questions to enable auditors to consider how policies or programmes are governed. In doing so, it establishes guiding principles around co-ordination and coherence, as well as questions and criteria to analyse during an audit. This Framework is complemented by the new Framework for Evaluation of the Centre of Government (TCU, 2016a), which provides questions and concepts pertaining to the strategy, co-ordination, supervision and transparency of CoG institutions.3

OECD’s recommendations related to policy coherence aim to support TCU’s current strategic objectives 1 and 5 in particular. Objective 1 is to improve the governance and management in public and political organisations. Objective 5 is to conduct evaluations in relevant areas to promote the assessment of the governance and management of public policies (5.2) (TCU, 2015b). There is more yet that TCU can do to help support coherence through assessment of policy interactions and policy effects in the short, medium and long-term. These approaches aim to support reduction of waste and use of non-conflicting policies and programmes. TCU can move towards assessment of policy interactions and policy effects, as recommended in Table 2.1.

Table 2.1. Recommendations: Auditing for greater policy coherence in Brazil

TCU could more systematically assess institutional mechanisms for coherence, including the capacities of audited entities to constructively communicate and co-ordinate with entities relevant to the achievement of interrelated policy goals.

  • TCU could conduct periodic assessments of the existence, capacity and effectiveness of entities (e.g. the Centre of Government, intergovernmental co-ordination bodies or decentralised entities) to communicate and co-ordinate around cross-cutting initiatives and “wicked” problems, including incorporating its frameworks into audits of year-end accounts.

TCU could develop a body of audit work to assess policy interactions and policy effects across government, beginning with a pilot review of fragmentation, overlap and duplication of programmes in key sectors.

  • TCU could conduct periodic evaluations of the synergies and trade-offs between sectoral or national plans, in the short, medium or long-term, as well as between cross-cutting programmes that appear in the government’s multi-annual plan.

  • TCU could pilot a review of fragmentation, overlap and duplication in intra-sectoral policies or programmes, such as those geared towards poverty eradication, raising productivity and regional development, for instance.

  • TCU could assess congruence of actions, trend indicators and the results of public policies related to the achievement of the Sustainable Development Goals.

2.3. Systematically assessing institutional mechanisms for coherence

TCU could more systematically assess institutional mechanisms for coherence, including the capacities of audited entities to constructively communicate and co-ordinate with entities relevant to the achievement of interrelated policy goals.

Adapting institutional mechanisms to bring greater coherence refers to enabling the capacity of entities, and particularly Centre of Government (CoG) institutions, to co-ordinate and communicate with each other on shared goals. Coherence supports the formulation of policies that are aligned, or at least not detrimental, to the success of others. It supports smooth implementation when those responsible for implementation are aware of the impact of their actions vis-à-vis others’. It further supports more consistent policy evaluation, when policy objectives are coherent, consistent and shared.

OECD experience shows that policy co-ordination is primarily a CoG responsibility. Over three-quarters of OECD member countries restructured the CoG between 2008 and 2012, reinforcing capacities and budgets.4 These changes reflect government attempts to take a more coherent approach to cross-cutting issues that require a collective response (OECD, 2014a). Discussions with TCU highlight a need for a greater understanding of the importance and relevance of the role of the CoG in Brazil as a response to cross-cutting and complex issues. TCU’s 2016 Framework for Evaluation of the Centre of Government seeks to promote a greater role for the CoG.

Policy co-ordination between entities in Brazil remains a challenge with 24 Ministries and 15 organisations with Ministerial status. Brazil’s bureaucratic nature of public administration, and diffused power, promotes siloes and provides little incentives for entities to co-ordinate with one another. In addition, Brazil’s cabinet has a hierarchic-bureaucratic nature, with the chief of staff playing a significant role in centralising decision making (Bertelsmann Stiftung, 2016). Yet, the CoG has been hesitant to accept a co-ordinating role according to TCU testimonials. Moreover, decades of coalition presidentialism have limited success in efforts for co-ordination and communication (Bertelsmann Stiftung, 2016). Twenty-six political parties are represented in the Congress, 10 of which are represented at the Minister level.

One example of efforts for cross-governmental co-ordination is the National Education Plan (Plano Nacional de Educacão, or PNE) (2014-2024). The PNE is one of few sectoral plans that take a long-term perspective. The PNE requires that the fulfilment of goals are subject to continuous monitoring and periodic evaluations performed by a group of actors that include the Ministry of education, the Education committee of the House of Deputies and the Committee of Education, Culture and Sport of the Senate, the National Education Council and the National Education Forum (Article 5). Brazil’s states, Federal District and municipalities are meant to create mechanisms for achievement monitoring at the local level, as well as for co-operation arrangements that include permanent negotiation, co-operation and agreement processes in each state (article 7). The success of the PNE will depend largely on the collaboration between the Union, the Federal District, states and municipalities, recognized in the PNE for collaborative role in implementing the Plan (Brazil, 2014).

In other areas, attempts for co-ordination have not led to practical or effective application. For instance, the Internal Control Co-ordination Commission (Comissão de Coordenação de Controle Interno, CCCI), of which TCU is a part, was founded in 2001. This group has only met 4 times in 15 years, the last being in August 2015. The CCCI has a number of high level officials, and is chaired by the Chief Minister of the Comptroller General (CGU, 2016). Given the importance of internal control and accountability, co-ordination around the topic would be beneficial for Brazil. This is discussed further in Chapter 4.

As part of its strategic plans, TCU has increasingly focused on policy coherence as a subject of its work, particularly performance audits, according to TCU Ministers and staff. The assessment of co-ordination and coherence has become more common as a result of the Framework to Assess Governance in Public Policies, a TCU framework meant to strengthen analysis of governance issues (TCU, 2014a). However, TCU has incorporated coherence issues, including communication and co-ordination, as part of its performance audits for years, including the following examples:

  • Audit of the governance structure of the Federal Executive planning system - this analysis of the federal executive planning system demonstrates regulatory gaps which pose limitations on the operational system (Judgement 3580/2014) (TCU, 2014b).

  • Assessment of governance aspects related to the Logistics Investment - the assessment included the Ministry of Transport, the National Land Transportation Agency; Valec Engineering, Construction and Railroads SA (Valec) and Enterprise Planning and Logistics S.A. (Judgement 1.205/2015) (TCU, 2014c).

  • Audit of regional development policy - this focused on the national policy for regional development and aimed to understand and identify structural features that may be responsible for any successes and performance gaps. (Judgement 2919/2009) (TCU, 2009).

OECD’s “Supreme Audit Institutions and Good Governance: Oversight, Insight and Foresight” (2016c) shows that the majority of 10 leading SAIs are assessing governments against international principles with regard to policy coherence. For instance, in a survey of 10 SAIs:

  • 8 of 10 SAIs assessed mechanisms for effective co-ordination for implementation between levels of government, within entities and across entities.

  • 6 of 10 SAIs assessed the capacity and/or efficacy of central government units (ex. CoG), including ensuring the long-term vision is harmonised with other key documents (fiscal plans), and the long-term vision is reflected in ministries work plans.

  • 6 of 10 SAIs assessed the separation of roles functions/roles of relevant actors, in terms of co-ordination and/or overlap of functions in regulatory management, budgetary management and internal control.

  • 6 of 10 SAIs assessed the effectiveness of central co-ordination bodies in communicating and co-ordinating, such as ensuring senior management of ministries are aware of trends and risks, as well as providing guidance to departments and line ministries.

TCU could build from the dissemination of comprehensive work already undertaken in developing the Frameworks, and in the lessons learned from audits that have looked at communication and co-ordination and central entities, to allow for a more systematic approach in this governance area. A more systematic approach means that audit questions (provided for in relevant frameworks and the performance manual) are applied and enable comparison between co-ordination mechanisms of entities and within different programmes. This also enables TCU to pull out good practices in this domain, which can inspire others. TCU could more systematically assess institutional mechanisms for coherence by taking the following actions:

TCU could conduct periodic assessments of the existence, capacity and effectiveness of entities (e.g. the Centre of Government, intergovernmental co-ordination bodies or decentralised entities) to communicate and co-ordinate around cross-cutting initiatives and “wicked” problems, including incorporating its frameworks into audits of year-end accounts.

TCU’s work in this area could build on previous audits which already offer insights on communication and co-ordination. These audits could be guided by TCU’s governance frameworks, which suggest questions that audit teams may consider in their performance audits. Table 2.2 provides those, along with others that the OECD’s new Framework for Policy Coherence (2016d) identified as useful to better understand institutional mechanisms in country.

Table 2.2. Audit questions for assessing institutional mechanisms for coherence

TCU’s Framework for Evaluation of the Centre of Government

Has co-ordination effectively stimulated or been conducive to co-operation between line ministries?

How is the co-ordination role of the Centre of Government exercised for policy design and implementation?

How is the government communication strategy co-ordinated and aligned?

TCU’s Framework to Assess Governance in Public Policies

To what extent do various government actors, involved in public policy making, work in a coherent and co-ordinated manner with each other?

How is it that the relationship between the levels of government allow for public policy to be developed in a cohesive and co-ordinated way?

Other suggested questions to integrate

What mechanisms are in place to help increase the informal flow of information across ministries, institutions and sectors?

How are sustained collaborative relationships promoted among senior-level officials across the government?

Have formal mechanisms been established for inter-ministerial collaboration, co-ordination and policy arbitration around national plans or strategies, policies or programmes? Do those mechanisms provide opportunities to inform ex ante on future policy making?

Sources: OECD (2016c), Better Policies for Sustainable Development 2016: A New Framework for Policy Coherence, OECD Publishing, Paris. http://dx.doi.org/10.1787/9789264256996-en; TCU (2016a), Framework for Evaluation of the Centre of Government, TCU Publishing, Brasilia, http://portal.tcu.gov.br/lumis/portal/file/fileDownload.jsp?fileId=8A8182A25454C5A801545DC1433145ED; TCU (2014a), Framework to Assess Governance in Public Policies, TCU Publishing, Brasilia, http://portal2.tcu.gov.br/portal/pls/portal/docs/2686056.PDF

The aforementioned audits included communication and co-ordination as one element of a broader analysis. Yet, TCU has not made the CoG’s institutional mechanisms for communication and co-ordination a specific audit subject. For instance, TCU has not conducted specific audits on the functioning of the Under-Secretary for Monitoring and Assessment of Government Policies (Subchefia de Análise e Acompanhamento de Políticas Governamentais, SAG). TCU could draw inspiration from the example of the United Kingdom’s National Audit Office (NAO), which explicitly assessed institutional mechanisms for establishing coherence, or institutions’ capacities to do so, as an audit subject.

The UK’s NAO synthesised years of work on CoG institutions to create a report (NAO, 2014). Recognising its critical role, the NAO examined the CoG (HM Treasury and Cabinet Office), focusing on the effectiveness of the CoG’s strategic planning, leadership and co-ordination functions. Additional sources for assessing the maturity of CoG functions include the Centre of government institutional development matrix, as developed by the IADB (IADB, 2014). TCU may also complement the questions provided for it its own Frameworks, with OECD’s questions for establishing institutional mechanisms for coherence (Table 2.2).

As another example, the Australian National Audit Office audited government wide cross-cutting collaboration by reviewing current arrangements and the breadth of agency interdependencies. Cross-agency collaboration was audited by examining 200 cross agency agreements from twenty one public sector agencies. The audit found that there was inconsistency in overall clarity, quality and completeness of agreements across agencies. TCU could draw from this example, including consideration of the key elements for cross-agency collaboration elaborated in the Australian context, as illustrated in Box 2.1 below.

Box 2.1. Mechanisms for greater coherence and co-ordination in Australia

In 1992, the Council of Australian Governments was established to improve the effectiveness and efficiency of service delivery between the federal and state governments (Jones 2008). Since its inception, the COAG has developed numerous initiatives designed to prevent duplication, fragmentation and overlap in government, and promote policy coherence. Commitments of the COAG can be outlined in intergovernmental agreements or statements of cooperation (Jones 2008).

In addition, collaboration agreements can also be effective for enhancing policy coherence between agencies and departments at the same level of government. In Australia, formal bilateral or multilateral memoranda of understanding establish a foundation for the working relationship, which sets out roles and responsibilities as well as performance expectations and reporting arrangements. These agreements can also include specifications for particular deliverables, as well as quality measures and timeframes.

Cross agency agreements are diverse in their form and content, because each is tailored to a specific situation and set of agreements. Agreements can come in the form of exchange of letter, a detailed Memorandum of Understanding, or a high level collaborative agreement. These agreements can range from simple data sharing to establishing specific responsibilities when agencies can be interdependent. Almost all of these arrangements, however, are not legally binding because often they are between parts of the same legal entity. The inconsistencies in the agreements reflect the limited availability of guidance for developing non-legally binding agreements. As such, the ANAO has developed principles and suggestions for agencies to create their own guidelines. These principles can help agencies improve a common understanding of cross-agency agreements, as well as establish internal scrutiny to ensure the agreements are functioning effectively and are tailored to their particular situation. In order to maximise policy coherence, all cross-agency agreements should contain:

  • Objectives of the arrangement

  • Desired outcomes and timeframes

  • Roles and responsibilities of each party

  • The goods or services to be provided

  • Performance indicators

  • Revenue and budgetary issues

  • Implementing suitable governance and communication arrangements

  • Considering risks and incorporating reporting and review provisions: Shared risk management mechanisms, such as dispute resolution mechanisms, can help agencies in planning for the management and early resolution of any problems.

  • Development of guidance material and agency controls

Up to date registers can also enhance effectiveness of cross cutting agreements through internal monitoring and improving the quality and consistency of arrangements. The registers can easily inform an agency of poor performance under an arrangement and also ensure that deliverables and accountability requirements are met. These registers are particularly effective in agencies which have many agreements which need regular review.

Source: OECD (2016b), Supreme Audit Institution and Good Governance: Oversight, Insight and Foresight, OECD Public Governance Reviews, OECD Publishing, Paris. http://dx.doi.org/10.1787/9789264263871-en; Australian National Audit Office ‘Effective Cross Agency Agreements,’ Audit Report No. 41 2009-10, available at: https://www.anao.gov.au/sites/g/files/net2766/f/ANAO_Report_2009-2010_41.pdf; ANAO (2009), Effective Cross-Agency Agreements, Audit Report No. 41 2009-10, Commonwealth of Australia 2010, available at: https://www.anao.gov.au/sites/g/files/net616/f/2009_Innovation_in%20the_public_sector.pdf; Jones, S. (2008), “Cooperative Federalism?” The Case of the Ministerial Council on Education, Employment, Training and Youth Affairs the Australian Journal of Public Administration 67 (2): 161–172, available at: http://onlinelibrary.wiley.com/doi/10.1111/j.1467-8500.2008.00579.x/full

It is critical for TCU to not only disseminate its frameworks internally, but also to further integrate them into existing audit work in order to institutionalise key governance concepts and promote consistency. This could include further incorporation of the frameworks into analysis of audits related to year-end accounts of line ministries. Such integration could help TCU to develop a birds-eye, holistic view of policy challenges and solutions related to specific sectors. Currently, audits related to the year-end accounts emphasise financial performance. There are opportunities for orienting some of the content of this fundamental aspect of TCU’s work towards governance concepts, like measuring impact, assessing the quality of indicators and strategic planning. This would offer a comparative view of ministries working in different sectors, and when aggregated, can help to draw a picture about how government is functioning in a number of areas.

2.4. Strengthening assessments of policy interactions and policy effects across government

TCU could develop a body of audit work to assess policy interactions and policy effects across government, beginning with a pilot review of fragmentation, overlap and duplication of programmes in key sectors.

Mapping policy interactions in Brazil

Coherence requires a common understanding of the policy interactions across sectors that can facilitate or hamper the realisation of other policy goals. Brazil’s government struggles to manage and co-ordinate conflicting objectives because of significant “intra-governmental friction” and difficulties in establishing transversal and co-ordinated policies across key ministries (Bertelsmann Stiftung, 2016). As mentioned above, siloes between a large number of Federal entities limits a shared understanding of the implications of policy interactions.

Deepening the understanding of policy interactions is particularly important at the current juncture in Brazil, where financial decisions are being made about citizen-sensitive policy areas, such as human security, health and environment. Trade-offs that will be made in the name of fiscal austerity and efficiency in social spending should be based on evidence about the pros and cons of each policy and programme individually, as well as on their interaction with others.

Medium and long-term policy commitments of governments put further pressure on countries to deepen the understanding of policy effects on a long-term horizon. In the context of Brazil, medium-term commitments are found in the latest Multi-annual plan (Plano Pluriannual, PPA), spanning from 2016-2019, as well as in entity and sector-level plans, such as the National Education Plan (2014-2024). Long-term commitment is made by default through adherence to the Sustainable Development Goals (SDGs) that are to be met by 2030.

Mapping and managing policy interactions in Brazil is a means of mitigating negative impacts of fragmentation, overlap and duplication. For instance, OECD’s 2015 “Water Resources Governance in Brazil” discusses the need for a deeper understanding of the effects between Brazil’s sectors of water management, agricultural development, waste management and health. Solutions for droughts (in the northeast) may simultaneously compete with demands for irrigation in Central Brazil, and for management of polluted water in large cities (OECD, 2015b).

Brazil would benefit from assessing existing efforts to understand policy interactions – in order to roll out good practices and build on the lessons learned. One such example is in the context of Brazil’s national disaster risk management (DDR). The responsibility for Disaster and Risk Management co-ordination usually lies with an OECD member country’s CoG, and particularly in a central planning or co-ordinating unit. Along with many OECD countries, Brazil has recognised the importance of linking DDR to other key sectors. Brazil has integrated its DDR planning into public investment and planning decisions, the national development plan, the civil defence policy planning, in land zoning and real estate development. Brazil could go further to integrate national risk planning into sector strategies and plans to ensure that efforts to co-ordinate the approach an enacted in individual plans for implementation (OECD, 2015c).

A second initiative that works to promote government-wide coherence is the Programme for the Strengthening of Institutional Capacity for Regulatory Management (PRO-REG) (PRO-REG, 2012). Established in 2007, PRO-REG provides a good example of information sharing to strengthen institutional capacity for regulatory management. One objective of the PRO-REG initiative is to “improve co-ordination and strategic views between sectoral policies and the regulatory process”. The Management Committee and Consultative Committee were required to mobilise different institutions inside administration that are involved in the regulatory process. The programme is responsible for co-ordinating the formulation of concrete proposals to be implemented by regulatory bodies (OECD, 2008). With similar intentions, the Brazilian Foreign Trade Board (CAMEX) created an inter-ministerial technical group to gather streamline domestic legislation about foreign trade, by harmonising, rationalising and simplifying it5 . The expected benefit of regulatory coherence is to bring about more effective, efficient and comprehensive regulations that result in cost savings.

Understanding policy effects in the short, medium and long term in Brazil

Policy coherence can be fostered with a better understanding of policy effects (both positive and negative consequences) in the short, medium and long-term. Governments need to have an understanding of the intended and potential effects of the policy in the policy design phase to ensure that the policy will be implemented and evaluated in a way that allows for accurate assessment and adjustment. Appropriate monitoring and evaluation, during and after implementation, is also important for gathering information on what has worked and what has not, and for making adjustments as needed. The role of monitoring and evaluation is discussed in detail in Chapter 5.

Brazil’s commitment to the SDGs will test the government’s ability to make simultaneous progress in tackling “wicked” policy issues – those issues that are interrelated, involve many actors, and have unintended and often opaque consequences on other policy areas, such as poverty, health, education, climate and the economy (OECD, 2016a). Meeting the SDGs will require appropriate foresight of whether policies will achieve intended outcomes by 2020, 2025 and by 2030. The potential to use policy coherence as an opportunity to spur sustainable development, including meeting the SDGs, is discussed further in Box 2.2.

Box 2.2. Policy Coherence for Sustainable development

The United Nation’s seventeen Sustainable Development Goals (SDGs) are ambitious objectives to achieve fair, long-term development globally. The development goals are by nature interconnected and overlapping and, as such, they demand a certain level of coherence in government policy and approach. Accordingly, the 2030 Agenda for Sustainable Development and the Addis Ababa Action Agenda call on countries to ‘pursue policy coherence and an enabling environment for sustainable development at all levels and by all actors’ (OECD, 2016d).

SAIs can contribute towards the achievement of SDGs in a number of ways, particularly in regard to SDG 16 to ‘promote peaceful and inclusive societies for sustainable development, and provide access to justice for all and build effective, accountable and inclusive institutions at all levels’. For instance, increasing transparency in national budgets and ensuring all expenditure is accounted for (SDG 16.6.1) is linked to the core role of the SAI. In doing so, SAIs may play a role in the fight against illicit financial flows (SGD 16.4) and in reducing “corruption and bribery in all their forms” (SDG 16.5) (de Vries, 2016).

In regard to other SDGs, SAIs can monitor and report on the efficiency and effectiveness of national systems, as well as sectorial policies, to implement goals and targets. The Auditor General of South Africa, for example, did this with the country’s Kha Ri Gude Campaign. The Kha Ri Gude Campaign sought to achieve a number of Millennium Development Goals and enable 4.7 million functionally illiterate and semi-illiterate adults to become literate and numerate in one of the eleven official languages of South Africa by 2015. A great deal of resources were invested in the campaign, however only 47% of the targeted 4.7 million unschooled adults had completed or passed the related tests (OECD, 2016c). The AGSA audited the campaign to answer the question: ‘Was the Kha Ri Gude campaign economically, efficiently, and effectively implemented to ensure the reduction of adult illiteracy in South Africa?” Emulating the approach of AGSA, SAIs can help countries leverage lessons learned from the Millennium Development Goal strategies and evaluate the existing SDG strategies at the sectorial and national level to contribute to sustainable development.

Given the importance of policy coherence in achieving SDGs, countries are forced to consider the value of policy co-ordination for development. In Germany, for example, the Federal Ministry for Economic Cooperation and Development is responsible for promoting policy coherence for development across the German government and the EU. Having a seat in the cabinet allows the Federal Ministry for Economic Cooperation and Development to scrutinise all policies from a development perspective. Additionally, in recent years, Portugal’s Inter-Ministerial Commission for Co-operation has broadened its mandate to include addressing policy coherence for development as well as co-ordinating the national development programme (OECD, 2016d).

Subsequently, monitoring and reporting on the effectiveness and efficiency of national and sectorial development strategies with a particular focus on policy coherence can be one of the most important ways SAIs contribute towards sustainable development. The Swedish National Audit Office (NAO), for instance, audited the government’s gender equality initiative. From 2007-2014, the Government set aside SEK 2.6 billion to instruct fifty government agencies in gender mainstreaming as well as allocate funds directly to municipalities, county councils, and non-profit organisations. The audit showed that changes which had been made in the governance of agencies through the new Government Agencies Ordinance directed governance through instructions and dialogues with agencies and removed the focus on gender. Traditional sectorial thinking has been amplified with the new organisation-adapted governance through informal dialogue between agencies and ministries, which has in turn affected the possibilities of gender equality having an impact. The NAO saw a risk that there was a risk of losing gender as an element of governance across entities. The NAO thus recommended development of an institutional structure to strengthen the government’s gender mainstreaming strategy, as they found it to be inadequately aimed at developing and integrating gender mainstreaming work in the ordinary structures and operations of the agencies. Ultimately, as the audit of the gender equality initiative illustrated the complexity of many SDG initiatives that must be met with improved policy coherence. As such, SAIs can focus on policy coherence when evaluating national and sectorial development strategies linked to SDGs (NAO, 2015).

Source: OECD (2016b), Supreme Audit Institutions and Good Governance: Oversight, Insight and Foresight, OECD Public Governance Reviews, OECD Publishing, Paris. http://dx.doi.org/10.1787/9789264263871-en; OECD (2016c), Better Policies for Sustainable Development 2016: A New Framework for Policy Coherence, OECD Publishing, Paris. http://dx.doi.org/10.1787/9789264256996-en; de Vries (2016) ‘How National Audit Offices Can Support Implementation of the SDGs’ Public Financial Management Blog, 28 June 2016, http://blog-pfm.imf.org/pfmblog/2016/06/national-audit-offices-should-support-implementation-of-the-sdgs.html?utm_source=feedburner&utm_medium=email&utm_campaign=Feed%3A+pfmblog+%28PFM+blog%29; National Audit Office of Sweden (NAO) (2015), ‘Summary: The Government’s gender equality initiative- temporary or permanent improvements?’ Report no, RIR 2015: 13, 11 June 2015, Stockholm, http://www.riksrevisionen.se/PageFiles/22905/Summary_2015_13.pdf.

Acquiring a sense of policy effects over the short, medium and long term is no small task. Brazil could benefit from mechanisms to compare entity-level assessments of policy effects during the policy formulation process. Annual policy objectives for public sector entities could be established, where appropriate, in line with the guidelines and government targets in the PPA, the Budgetary Guidelines Law (LDO) and the Annual Budget Law (LOA) (Article 144 I, Law 11,784). When entities establish goals in accordance with the PPA, entities could be considering the contributions of different policy objectives, and programmes, to the country’s medium-term framework. When priorities are established outside of the PPA however, and without a long-term vision in the country with which entities can align objectives, there is room for entity-level managers to develop goals that may be conflicting with those of other entities’ or that may be on a different time horizon than those of other entities.

There is no requirement in Brazilian laws for consideration of policy effects in the short, medium or long-term, or interactions with other policies or programmes. Public entities are meant to widely disseminate institutional goals and results in each period, including through the Integrated Planning and Budget System (SIOP). However, the extent to which entities consider other goals and results, or policy effects, when developing their own, is unclear.6 In previous audits, TCU has found that certain policies have been developed with no consideration of the potential effects and implications with other policies.

At current, the CoG does not have a mechanism for assessing the positive and negative impacts of policies and programmes on one another, across government, on a consistent basis. Brazil could benefit from a unit, whether within existing structures or new, specifically dedicated to understanding policy effects and policy interactions, as done in the United Kingdom, for instance.7

Medium and long-term commitments of put pressure on countries to deepen the understanding of policy effects on a long-term horizon. In the context of Brazil, these commitments include the latest PPA, spanning from 2016-2019, entity and sector-level plans, such as the National Education Plan (2014-2024), and commitment to the SDGs that are to be met by 2030.

The difficulty in understanding policy effects stems from inconsistent application of evaluation guidelines at the sector and entity level. Further, it is difficult for CoG officials to get into the technical details of the programmes or policies at hand. Thus it is critical that they provide guidance for the smooth and consistent application of guidelines in evaluation and in practitioner’s consideration of evidence in future formulation stages of policy making.

OECD’s 2015 “Water Resources Governance in Brazil” discusses the need for a deeper understanding of the effects between Brazil’s sectors of water management, agricultural development, waste management and health. Solutions for droughts (in the northeast) may simultaneously compete with demands for irrigation in Central Brazil, and for management of polluted water in large cities. While maintaining flexibility at the state and municipal level, Brazil would benefit from central level co-ordination that could work with relevant entities to mitigate counterproductive effects of varying goals of relevant sectors (OECD, 2015b).

TCU’s audit work can help to fill this void in knowledge and evidence. To date, TCU’s work and frameworks have focused on the existence of co-ordination bodies and their efficacy. TCU could strengthen its support to enabling policy coherence in Brazil, by expanding beyond effective interaction of entities to the interactions of cross-cutting policies themselves. To date, TCU’s work and frameworks have focused on the existence of co-ordination bodies and their efficacy. TCU has looked across sectors, policies and programmes to understand the linkages, such as in the series of audits around the Regional Development Policy. However, these policy interactions could feature well a specific subject of an audit.

In seeking to inform policies with a deeper understanding of policy interactions and policy effects, TCU could develop a body of audit work to assess policy interactions and policy effects across government. Specifically:

  • TCU could conduct periodic evaluation of the synergies and trade-offs: between sectoral or national plans, in the short, medium or long-term; and between cross-cutting programmes that appear in the PPA;

  • TCU could pilot a review of fragmentation, overlap and duplication in intra-sectoral policies or programmes, such as those geared towards poverty eradication, raising productivity and regional development, for instance; and

  • TCU could assess congruence of actions, trend indicators and the results of public policies related to the achievement of the Sustainable Development Goals.

TCU could conduct periodic evaluations of the synergies and trade-offs between sectoral or national plans, in the short, medium or long-term, as well as between cross-cutting programmes that appear in the government’s multi-annual plan.

TCU could conduct periodic evaluation of the synergies and trade-offs: between sectoral or national plans, in the short, medium or long-term; and between cross-cutting programmes that appear in the PPA. With the Adoption of the Growth Acceleration plan (PAC), TCU’s control task was to be carried out “in co-ordination with ministries, agencies and other governmental entities with the aim of ensuring a systemic and integration vision of the PAC”. While the PAC has since been discontinued, TCU did conduct such audits (TCU, 2010; 2008; 2007). Other future audit subjects could include the National Education Plan, National Plan of Logistics and Transport, National Energy Plan and the Sustainable Amazon Plan, among others.

TCU can assess how plans, policies and programmes interact, through assessing key strategic documents of government. To this end, below (Table 2.3) are potential criteria for TCU to consider integrating into audits, based on international principles and good practices. TCU could use these to supplement existing governance frameworks of analysis to reflect these criteria.

Table 2.3. Suggested questions and criteria for assessing policy coherence

Mapping policy interactions

  • Have economic, social and environmental policy inter-linkages (synergies and trade-offs) been considered in the development of plans and priorities?

  • Do existing inter-linkages (synergies and trade-offs) pose risk to the achievement of policy goals, or risk waste in public expenditure?

  • How do the planned policy outputs of plans and priorities contribute to broader long-term goals, including commitments to the SDGs?

  • How do the actions to attain one policy or programme support or hinder the actions of another?

Understanding policy effects in the short, medium and long-term

  • In the formulation of policies and programmes, were enabling and disabling factors (e.g. trends, projections of growth, stability of the financial system, assessments of environmental risk) taken into account?

  • Has the government identified and assessed contextual factors (corruption, barriers to trade, knowledge) which may impact the achievement of goals?

  • Does the policy produce unintended effects, positive or negative, that could affect the well-being of citizens in other states, or in other countries?

  • Which groups would be affected and how? How can the unintended negative effects be mitigated?

  • Have the potential direct or indirect long-term effects on well-bring of future generations been identified?

  • Are the economic, social and environmental costs of policy decisions considered?

Sources: Adapted from: OECD (2016c) Better Policies for Sustainable Development 2016: A New Framework for Policy Coherence, OECD Publishing, Paris. http://dx.doi.org/10.1787/9789264256996-en; IDB (2014) ‘Governing to Deliver: Reinventing the Center of Government in Latin America and the Caribbean’ Inter-American Development Bank, Washington DC, https://publications.iadb.org/bitstream/handle/11319/6674/Governing-to-Deliver-Reinventing-the-Center-of-Government-in-Latin-America-and-the-Caribbean.pdf?sequence=1; NAO (2014) ‘The centre of government’ HC 171, Session 2014-15, 19 June 2014, https://www.nao.org.uk/wp-content/uploads/2014/06/The-centre-of-government.pdf; OECD (2014) ‘Centre Stage: Driving Better Policies from the Centre of Government’ OECD Publishing, Paris. https://www.oecd.org/gov/Centre-Stage-Report.pdf

TCU can gain further inspiration from the SAI of Korea – the Korean Board of Audit and Inspection (BAI) – which assessed a number of policies meant to stabilise housing of lower and middle-income families. BAI found that the incongruence between the medium and long-term housing supply plans was a determinant of excess housing that was not appropriately matched to population and ageing trends and projections for the long-term (see Box 2.3).

Box 2.3. The SAI of Korea – assessing policy interactions and effects in medium and long-term housing supply plans

Objective of performance audit

The Korean government has formulated and implemented various policies to tackle the housing shortage and to stabilise the housing of the middle and lower income families. However, according to BAI, these policies and programmes did not seem to produce the desired effects and may have caused various side effects, including: the privatisation of public development interests; destruction of comparatively favourable residences for middle and lower income families; and waste from suspension or delay of some programmes.

BAI reviewed the appropriateness of the planning, implementation, and feedback stages, as well as institutional and programme performance. In The housing stabilisation policy and key programmes for the middle and lower income families, BAI provides alternative policy options that can contribute to housing stabilisation of middle and lower income families.

The main target institutions for the audit were the housing policy-formulating government agency, housing policy-delivery public institutions, and local agencies. Country laws/regulations (Framework Act on National Land); key national indicators on housing (housing supply rate, long-term rental rate). The audit required approximately 90 staff days for the preliminary study and 60 staff days for the field audit, which included 12 professional experts.

Outcomes/benefits

The audit pointed to an inconsistency between long- and medium-term housing supply plans. It found that an excess housing supply was caused by an inadequate supply plan that did not fully reflect the recent trends of low fertility and population aging. The following recommendations were made: 1) ensure consistency between medium and long term plans through efficient co-ordination; 2) take action to remedy the supply gap according to area and size; and 3) update the long-term housing policy by incorporating the changes in household type. The audit aimed to enhance the effectiveness of the government’s housing policy by making housing supply plans more demand-oriented, and by specially responding to the needs of low-income families.

Source: BAI (2013), The housing stabilization policy of the middle and lower income families (서민주거안정시책 추진실태 공개문), Board of Audit and Inspection of Korea, www.bai.go.kr/bai/cop/bbs/detailBoardArticle.do?bbsId=BBSMSTR_100000000009&nttId=1489&mdex=bai20&searchCnd=all_NTT_SJ_CN&searchWrd=%EC%84%9C%EB%AF%BC%EC%A3%BC%EA%B1%B0%EC%95%88%EC%A0%95&searchBgnDe=&searchEndDe=&searchYear=&pageIndex=1&recordCountPerPage=10, (available in Korean only).

TCU could pilot a review of fragmentation, overlap and duplication in intra-sectoral policies or programmes, such as those geared towards poverty eradication, raising productivity and regional development, for instance.

Drawing from the work of the U.S. Government Accountability Office (GAO), TCU could pilot an assessment of fragmentation, overlap and duplication (FOD) in a specific national plan, or intra-sectoral initiative (GAO, 2015). The GAO’s body of work focuses on addressing FOD and spurring cost savings. Box 2.4 provides further detail on how the GAO carries out this work on an annual basis. Required to support the identification, reduction or elimination of duplication in government, the GAO began its FOD work in 2011.

Box 2.4. The U.S. Government Accountability Office: general process for assessing fragmentation, duplication and overlap in government

Since 2011, the U.S. Government Accountability Office is required to conduct investigations to identify federal programmes, agencies, offices and initiatives with duplicative goals and activities within departments and nationwide. Accordingly, GAO releases an annual report suggesting opportunities to address fragmentation, overlap and duplication (FOD), and to achieve other financial benefits. This report is presented annually to Congress to aid in decision making. In addition, GAO conducts audits linked to the implementation of GPRA Modernization Act of 2010 (GPRAMA). GAO reported that full and effective implementation of GPRAMA was one way for the government to improve management of FOD across government (GAO, 2015b). In order to carry out its FOD reviews, the GAO generally uses a four step process:

  1. Identify an approach for selecting programs for a FOD review. This involves establishing the goals and outcomes, the beneficiaries or other target population, key benefits or services, the administering agencies and the appropriations or budget structure. Using this approach, auditors can then identify programs to examine. Qualitative and quantitative methods can be used for assessing fragmentation, overlap and duplication as well as how the programmes are related. For example, compiling detailed descriptions of similarities and differences as well as scoring and rating are effective methods of analysis.

  2. Identify potential effects, both positive and negative, of FOD in the selected programmes.

  3. Evaluate the performance of each programme concerned to validate the effects of FOD and compare the performance of the programs.

  4. Identify options to increase efficiency and reduce or better manage FOD. Specific management approaches may be necessary in order to increase efficiency, such as restructuring out-modelled government organisations and operations, implementing process or technology improvement methods, or implementing a strategic approach to spending.

Notes: ‘Duplication’ occurs when two or more agencies or programs are engaged in the same activities or provide the same services. ‘Overlap’ is when multiple agencies or programmes have similar goals, engaging in similar activities to achieve them or target similar beneficiaries. ‘Fragmentation’ refers to circumstances where more than one federal agency is involved in the same area of national need (GAO 2011). Examples of recent GAO reports include GAO (2016) ‘2016 Annual Report: Additional Opportunities to Reduce Fragmentation, Overlap and Duplication and Achieve Other Financial Benefits (GAO-16-375SP)’, available at https://www.gao.gov/assets/680/676473.pdf and GAO (2015) ‘2015 Annual Report: Additional Opportunities to Reduce Fragmentation, Overlap and Duplication and Achieve Other Financial Benefits (GAO-15-404SP)’ available at https://www.gao.gov/assets/670/669613.pdf.

Source: GAO (2011) ‘Opportunities to Reduce Potential Duplication in Government Programs, Save Tax Dollars, and Enhance Revenue: Report to Congressional Addressees (GAO-11—318SP)’, March 2011, available at: http://www.gao.gov/assets/320/315920.pdf; GAO (2015) ‘Fragmentation, Overlap and Duplication: An Evaluation and Management Guide (GAO-15-49SP)’, April 2015, available at: https://www.gao.gov/assets/670/669612.pdf.

The GAO’s FOD work attempts to tackle the challenge of policy coherence in government. It asks, amongst a range of questions:

  • How are programmes related to each other?

  • Which programmes are unnecessarily duplicating others?

  • Where can efficiencies be found between programmes with shared goals?

  • What relations do these programmes have with others?

  • Are there legitimate reasons for competition among or redundancies between programmes?8

The resulting annual reports shed light on what to enhance and mitigate, as shown in Table 2.4 As is done by GAO, these elements can guide TCU in interpreting the information that would be integrated into a FOD pilot.

Table 2.4. Assessment of fragmentation, overlap and duplication in government: what to enhance and mitigate?

Enhance

Mitigate

Relevant expertise

Difficulty in understanding programmes (citizens should not have too much red tape)

Shared resources

Programmes that waste efforts or resources

Shared information

Redundant administrative efforts

Overaching goals

Conflicting or contradictory programmes

Source: GAO (2016), Fragmentation, Overlap, and Duplication in Government Programs, Presentation in Brasilia, May 2016.

A first step for TCU would be to aggregate any existing work that touches on FOD in particular thematic or sectoral areas, and then begin to consider how the questions and criteria for enhancement and mitigation could apply to the Brazilian context. In considering previous audits, TCU can identify particular cross-cutting strategies or initiatives that may suffer from severe overlap or fragmentation and that would thus be a good audit subject of a pilot audit. The pilot approach is best accompanied by an intense communication strategy both internally and externally, that requires TCU to plan ahead for the greatest impact of resulting findings and recommendations to key stakeholders.

TCU could assess congruence of actions, trend indicators and the results of public policies related to the achievement of the Sustainable Development Goals.

As discussed above, Brazil is a signatory to the SDGs which will test the Government’s ability to make simultaneous progress in tackling wicked problems such as poverty, health, education, climate and the economy, while adjusting as needed to be on track to meet those commitments. The OECD’s Policy Coherence for Sustainable Development screening tool offers an integrated checklist of elements that governments could consider, much of which can be applied by governments in the preparation, implementation and evaluation of SDG approaches. Some of these questions are provided in Box 2.5, as suggested criteria for TCU to consider in governance audits geared towards assessments of SDGs.

Box 2.5. Suggested questions for assessing policy coherence of SDGs
  • Are the current sustainable development priorities of government aligned to the vision of the SDGs?

  • Are implementation responsibilities clearly divided among different levels of government, taking into account the distinct competences and comparative advantage of each level?

  • What mechanisms are in place to ensure co-ordination and joint action of agencies from different government levels involved in international initiatives?

  • Are formal mechanism established for inter-ministerial collaboration, co-ordination and policy arbitration for the SDGs? Is it located strategically within the central government structure?

  • Are there mechanisms for transparent reporting to Congress and the public about progress on SDG goals?

  • Are resources and capacity adequate to monitor and evaluate progress?

  • Have specific indicators been established at the national level to measure progress against SDGs?

  • Have critical interactions across SDGs and targets been mapped out? Have potential synergies and trade-offs been identified?

  • Can existing indicators at national and subnational level be sued to capture policy interlinkages and examine co-relations across sectors (e.g. rate of deforestation due to agricultural expansion?)

  • Have all the potential sources of finance been identified (public, private, domestic, international) for the SDGs?

  • Are there specific mechanisms to avoid fragmentation of international, regional, and national funding instruments?

Source: Adapted from OECD (2016c), Better Policies for Sustainable Development 2016: A New Framework for Policy Coherence, OECD Publishing, Paris. http://dx.doi.org/10.1787/9789264256996-en

The Framework for Policy Coherence for Sustainable Development (OECD, 2016d) offers an example of a mapping of policy interactions in the areas of water, energy and food that pertain to the SDGs. Brazil would benefit from this type of mapping, as a way of highlighting potential synergies and trade-offs that may exist between the SDGs. A similar mapping to that in Figure 2.1 could be done for existing goals in sectoral, national, state-level and regional strategies, or in the broad aims of the current PPA. Naturally, the degree of success of policies and programmes laid out in these documents, such as the PPA (2016-2020) or the PNE (2014-2024) will impact related SDG goals by 2030.

Figure 2.1. Some examples of the interactions between water, energy and food in the SDG framework
picture

Source: OECD (2016c), Better Policies for Sustainable Development 2016: A New Framework for Policy Coherence, OECD Publishing, Paris. http://dx.doi.org/10.1787/9789264256996-en

A further example is one to score the degree of interaction between policy goals, as a method for understanding where efforts towards communication and co-ordination are of a higher priority, as shown in Table 2.5.

Table 2.5. Mapping the interactions between SDGs through goals scoring

picture

Source: Nature (2016), International weekly journal of science, http://www.nature.com/news/policy-map-the-interactions-between-sustainable-development-goals-1.20075

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TCU (2014c), Judgement 019.059/2014-0 https://www.google.fr/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cad=rja&uact=8&ved=0ahUKEwiQ45PujrfPAhWKBBoKHchmDV0QFggfMAA&url=http%3A%2F%2Fwww.tcu.gov.br%2FConsultas%2FJuris%2FDocs%2Fjudoc%2FAcord%2F20150528%2FAC_1205_18_15_P.doc&usg=AFQjCNGZk5nRgov_aiZQiMYvrNy9HkJIRg&bvm=bv.134495766,d.d2s

TCU (2010), Judgement 1453/2010 https://contas.tcu.gov.br/sagas/SvlVisualizarRelVotoAcRtf?codFiltro=SAGAS-SESSAO-ENCERRADA&seOcultaPagina=S&item0=39360;

TCU (2009), Judgement 2919/2009. Survey report. Plenary. http://www.tcu.gov.br/Consultas/Juris/Docs/judoc/Acord/20091204/013-705-2009-6-MIN-JJ.rtf

TCU (2008), Judgement 3038/2008 http://www.tcu.gov.br/Consultas/Juris/Docs/judoc%5CAcord%5C20081215%5C018-215-2008-0-MIN-AN.rtf;

TCU (2007), Judgement 1690/2007 http://www.tcu.gov.br/Consultas/Juris/Docs/judoc%5CAcord%5C20070823%5CTC-010-107-2007-0.doc

Notes

← 1. The Index for Public Integrity considers administrative burden a measures of the extent of domestic bureaucratic regulations. The component is constructed based on the average numbers of procedures and time it takes to start a business and pay corporate taxes. Brazil’s public administration was ranked 104 out of 105 countries for administrative burden. While it is the second highest of the sample of 105, the index is inversed meaning that the lower the score, the higher the burden. Brazil received a score of 1.94.

← 2. More information on OECD’s work on regulatory burden or “cutting red tape” can be found on the OECD’s website: http://www.oecd-ilibrary.org/governance/cutting-red-tape_19976674.

← 3. As noted in Chapter 1, TCU defines the Centre of Government as including the Office of the Presidency (Presidência da República), Ministry of Finance (Ministério da Fazenda) and Ministry of Planning, Development and Management (Ministério do Planejamento, Desenvolvimento e Gestão (TCU, 2016a).

← 4. Between 2008-2012, the size and structure of the Centre of Government changed in three-quarters of OECD countries between 2008 and 2012. The number of cross-ministerial policy initiatives grew after 2008 in 59% of OECD countries (OECD, 2014a).

← 5. CAMEX formed the inter-ministerial board with the Executive Ordinance 6062/2007 (Brazil-U.S. Business Council, 2013).

← 6. Pursuant to Chapter II (Capitulo II) on Performance Evaluation (Da avaliacao de desempenho) in Law 11,784, Article 144.2.3.

← 7. The United Kingdom’s “What Works Network” was an initiative of the Cabinet, aiming to improve the way government and other entities create, share and use evidence for decision making. The network supports policy makers in making decisions based on evidence about what has been working and which initiatives are providing cost-efficient services. More information is available at: https://www.gov.uk/guidance/what-works-network.

← 8. According to GAO officials, the review of intelligence information by multiple entities is one example of beneficial competition, since multi-entity reviews can result in richer findings and insights. In addition, complex policy problems can benefit from competition between different, simultaneous solutions and approaches, particularly when a solution is unknown (i.e. the “letting a thousand flowers bloom” approach).