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Improving Program Design

The Need for Change

In a speech at a conference in Atlanta some years ago, a federal official told a story about a young attorney working on Capitol Hill who was asked to draft a bill to regulate some aspect of the airline industry. He started by looking up and copying the law that addressed similar concerns with the railroads. Finding some provisions which did not seem applicable to railroads, he did further research and discovered that the railroad bill had been lifted 75 years earlier by another attorney from a law passed early in the 19th century to regulate canals. Justice Oliver Wendell Holmes said that "in the law, an ounce of history is worth a pound of logic.''[Endnote 1] However, in the design of federal programs, unfortunately both are often missing. Consider the following 1981 exchange before a subcommittee of the House Committee on Banking, Finance and Urban Affairs:

Chairman Blanchard: Have you made any conclusions as to where governmental loans are an effective policy instrument and where they are not? Where loan guarantees are an effective policy instrument and where they are not? How they work, in what instances they work well and where they don't, and where they can be effective and where they aren't? Because we are looking at these in relation to other tools that the government has to operate...Have there been any studies on...federal use of direct spending versus loans versus loan guarantees versus the tax code, and then the various types of tax preferences and their effectiveness in different instances?

The witnesses responded that they were unaware of any such literature.[Endnote 2] Earlier the Congressional Research Service observed:

These program differences underline the ways in which the programs have evolved. There have been no overall guidelines or framework within which these programs are created. They have evolved over time to meet particular needs and situations. This generally ad hoc framework has led to a situation where, except for vast generalizations, it is hard to make specific statements concerning the characteristics of federal loan guarantees.[Endnote 3]

Is there a systematic, disciplined approach to program design in the Federal Government? There is not. An extensive literature search and consultation with experts inside and outside government reveal an overwhelming consensus that the lack of attention to program design means that federal activities are less effective and less economical than they should be. Program designs are frequently characterized by insufficient rational analysis and failure to anticipate unintended consequences. Often this can be attributed to the poor foundations upon which the programs were built- ambiguous goals, weak operational concepts and careless implementation design. It is rare to compare programs across agency and department lines in terms of what they do and how they do it. We do not have a methodology with which to compare them.

Some public policy/administration academics have attempted to develop a rational, disciplined approach to program design. In 1985, A Workbook in Program Design for Public Managers noted the absence of any preexisting attempt to provide this discipline and recognized its own limitations, stating ". . . at best, this workbook is but a beginning effort.''[Endnote 4] In 1986, the classic text Politics, Position and Power (Fourth Edition) proposed twelve criteria for evaluating the design and organization of new or existing programs.[Endnote 5] In 1989, the Urban Institute published a primer on program reviews that outlined criteria for analyzing program alternatives.[Endnote 6]

While academic interest in program design seems to be growing, the practical applications have been few. "Over time, legislation has suffered more and more from wishful thinking, sloppy drafting, and woeful disregard for public-sector organizational principles.''[Endnote 7] A congressional effort to establish a program design discipline for a segment of related governmental programs can be found in the 1988 public law which elevated the Veterans Administration to departmental status. The law provided for the establishment of a National Commission on Executive Organization, generally patterned on the first Hoover Commission. Its charter would have required ". . . establish[ment of] criteria for use by the President and Congress in evaluating proposals for government corporations and government-sponsored enterprises and subsequently overseeing their performance.'' [Endnote 8] The new commission could have been activated by presidential initiative; however, it was not.

Rigorous assessments of federal programs and their designs were once an active responsibility of OMB; however, current oversight responsibilities regarding program design are cloudy. In OMB and many agencies, program evaluation as a related discipline is also less prominent now.

Both program design and program evaluation will become more prominent under the new Government Performance and Results Act of 1993. The Act requires performance plans and performance reports from the executive branch; hence, agencies may be prompted to foster sound program designs as well as rigorous program evaluation.

What are the consequences of the absence of a rational program design process? Too often programs are designed without careful consideration of the way that similar designs have worked previously or the potential benefits of alternate designs.[Endnote 9] It is no wonder news media, federal auditors, politicians and taxpayers are critical of a government that too often creates federal programs that do not meet public expectations. A consequence is sagging public confidence in the ability of government to deliver.

For example, flawed program design accounts for poor public service in food stamp application processing for Supplemental Security Income (SSI) applicants and recipients. Congress believed that food stamp program participation would increase, and more streamlined public service would occur, if the Departments of Agriculture and Health and Human Services coordinated the delivery of food stamp services at Social Security Administration (SSA) offices. For SSI clients eligible and willing to apply for food stamps at SSA field offices, SSA staff complete an application and forward it to a state food stamp office for further consideration.[Endnote 10] GAO concluded:

The process for taking food stamp applications at SSA has not worked well...further, the process as designed results in duplication of effort and poor service to clients...the food stamp applications used are unnecessarily complex and lengthy.'' [Endnote 11]

There are many other examples of poor programs that have received public criticism because they fail to meet various design criteria. These include:

--Regulation of Savings and Loan Institutions. The government intended to use federal deposit insurance to subsidize the cost of loans and increase the availability of mortgage money for home buyers. To avoid the misuse of a government guarantee such as deposit insurance, the government must establish an effective and independent supervisory agency. The Federal Home Loan Bank Board lacked this independence from the savings and loan industry that it was supposed to supervise. The ultimate cost of that regulatory failure will amount to some $100 billion.[Endnote 12]

--Reduction of Crime. In attempting to reduce burglaries, the Law Enforcement Assistance Administration tried to increase the effectiveness of limited numbers of law enforcement officials through large investments in sophisticated telecommunications in police cruisers. These efforts were much less effective than Neighborhood Watch programs which greatly increased the number of people participating in crime surveillance at minimal cost.[Endnote 13] The consideration of alternatives in the design of federal programs is all too rare. Consequently the allocation of program resources often is not optimal in accomplishing desired ends.

--Federal Catfish Research. The Senate has noted that catfish research is conducted in at least four agencies: Fish and Wildlife Service (Interior), Animal and Plant Inspection Service (Agriculture), Agriculture Research Service, and Agriculture Cooperation Service. Although a 1988 report by the Inspector General at the Department of Commerce (itself conducting independent catfish studies) recommended that the work be consolidated, it still has not been done.[Endnote 14] Federal catfish research raises a variety of design questions. How compatible are these research efforts with each other? Are they complementary or redundant? What are the aggregate costs for federal catfish research and are they justified by the benefits?

--National Air Traffic Control. The Federal Aviation Administration (FAA) is responsible for airline safety in the United States and administers the nation's air traffic control system. Commentators have repeatedly pointed to problems confronting the FAA as it works to keep up with rapid growth in airline service and cope with federal budget constraints and inflexibility in its institutional structure. Recently the National Airline Commission recommended that the FAA become a government corporation so that it can regain the capacity to carry out its essential functions.[Endnote 15]

What is a program? In this context, a program is "a particular combination of authority, organizations, resources and personnel assembled to achieve specific public purposes.''[Endnote 16] At times, the federal government's role is very direct, such as payment of cash to Social Security beneficiaries. Alternatively the role can be indirect, such as the establishment of tax incentives for the private sector to provide low income housing.

In the field of public administration, two other levels of analysis have been proposed. One analyzes a set of programs or a program cluster aimed at a specific, common target group.[Endnote 17] For example, there are many programs addressing the income maintenance needs of the poor. Rather than considering a single program's design in isolation, the preferred focus is to diagnose program effectiveness as a whole.

A second alternative is to focus on the generic tools of government action, the techniques of social intervention used in particular public programs.[Endnote 18] Reinventing Government identifies 36 such mechanisms, ranging from grants to tax policies.[Endnote 19] In some program designs, more than one tool may be used; therefore, it is helpful to examine how well each tool works, either alone or in combination with others.

Frequently, each of these perspectives merits consideration. For example, consider a category of programs using more than one method of delivery--job training. It can be delivered in many forms including tax policy, grants, loans, loan guarantees, technical assistance, information, referral, seed money, and jaw boning. Whatever combination of delivery tools may apply to a specific public purpose, it would be desirable to understand the programmatic impact of the tools individually and collectively in order to design the best portfolio.

Why do we need an emphasis on program design? Effective and efficient delivery of programs is a major determinant of the public's confidence in its government. Although the approval and funding of most federal programs are inevitably shaped by political considerations (both in Congress and the executive branch), the formulation and design of these programs should be grounded in rational and valid public purposes. Sound designs based on objective criteria can yield programs more likely to win bureaucratic and political approval. A program design discipline that can increase the likelihood of a program's success is especially important in a time of especially austere fiscal constraints. In addition, this program design discipline should be applied to existing programs as part of program review and redesign processes.[Endnote 20] The American public is willing to support programs if it is confident the programs address issues important to them and the solutions have a reasonable probability of success (e.g., health care reform).[Endnote 21]

ENDNOTES

1. Knisely, Robert A., "Toward a Science of Program Design,'' speech at ORSA-TIMS conference, Atlanta, Georgia, November 9, 1977.

2. Salamon, Lester M., Beyond Privatization: The Tools of Government Action (Washington, D.C.: Urban Institute Press, 1989), p. 23.

3. U.S. Congress, House, Committee on Banking, Finance, and Urban Affairs, Subcommittee on Economic Stabilization, Catalog of Federal Loan Guarantee Programs, SN 052-070-04263-0 (September 1971).

4. Ruchelman, Leonard I., A Workbook in Program Design for Public Managers (SUNY Press, 1985).

5. Seidman, Harold, and Robert Gilmour, Politics, Position & Power, Fourth Edition (New York: Oxford University Press, 1986), pp. 338-340.

6. Hatry, Harry P., Kenneth P. Voytek, and Allen E. Holmes, Building Innovation into Program Reviews (Washington, D.C.: Urban Institute Press, 1989).

7. Moe, Ronald C., "Let's Rediscover Government, Not Reinvent It,'' Government Executive, vol. 25, no. 6 (June 1993), p. 46.

8. Moe, Ronald C., Reorganizing the Executive Branch in the Twentieth Century: Landmark Commissions, 93- 293 GOV (Washington, D.C.: Library of Congress, Congressional Research Service, March 19, 1992), p. 50.

9. Hatry, et al., pp. 5-6.

10. The Food Stamp Act requires that food stamp applications be forwarded immediately and in an efficient manner. Food and Nutrition Service regulations define this to mean one working day.

11. U.S. General Accounting Office, Social Security: Need for Better Coordination of Food Stamp Services for Social Security Clients, HRD 92-92 (Washington, D.C.: U.S. General Accounting Office [GAO], September 1992), p. 5. See also NPR Accompanying Report, Department of Agriculture (recommendation USDA07).

12. U.S. Congress, Congressional Budget Office, The Economic Effects of the Savings & Loan Crisis (January 1992).

13. Knisely, Robert A., "Law School and the Design of Government,'' November 1985.

14. "Reinventing Catfish Research,'' Washington Post, Federal Page: Short Takes (July 1, 1993), p. 21; and U.S. Department of Commerce, Office of Inspector General, Office of Audits, Denver Regional Office, NMF's Funding of the Stuttgart Catfish Farm is Not Warranted, Final Audit Report No. D-197-8-022 (July 1988).

15. National Commission to Ensure a Strong, Competitive Airline Industry, Outline of Issue: Restructuring the Federal Aviation Administration, Working Draft Report, pp. 8-9 (the draft reflects commission deliberations of July 19, 1993). See also National Academy of Public Administration, The Air Traffic Control System: Management by a Government Corporation (Washington, D.C., March 1986); Jasper, Herbert N., National Research Council, Transportation Research Board, "Appendix B: Organizational Options for the Federal Aviation Administration,'' Winds of Change : Domestic Air Transport Since Deregulation; and discussion in the NPR summary report and the NPR Accompanying Report Department of Transportation (recommendation DOT08).

16. Salamon, Lester, p. 25.

17. Interview with Joe Wholey, Director, Public Administration, University of Southern California, at Washington, D.C. campus, May 26, 1993.

18. Interview with Lester Salamon, Director, Public Policy, The Johns Hopkins University, at National Performance Review, May 17, 1993.

19. Osborne, David, and Ted Gaebler, Reinventing Government: How the Entrepreneurial Spirit is Transforming the Public Sector (Reading, MA: Addison- Wesley Publishing Company, Inc., 1992).

20. See Hatry, et al.

21. "Seeking a Cure: Most Americans Pledge Sacrifice to Help Fix the Health System,'' Wall Street Journal/NBC News Poll, Wall Street Journal (March 12, 1993), p. A1.

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