Are all burdens bad? Disentangling illegitimate administrative burdens through public value accounting

ABSTRACT

Despite its usefulness for analysing the social equity footprint of policies and documenting citizens’ experiences of accessing social services, the present conceptualisation of administrative burden does not differentiate between necessary and unnecessary administrative burdens. As existing research tends to focus only on negative aspects of administrative burdens, it does not adequately account for their use as a countervailing force to achieve legitimate public values and prevent misuse of public resources. Using a public values accounting approach, this article outlines a framework to analyse the costs and benefits associated with public service delivery. In this formulation, administrative burden conceptualised as the monetary, time and psychological costs experienced by relevant stakeholders are balanced against specific public value benefits that a policy is supposed to achieve. In addition to allowing a more balanced analysis of costs and benefits associated with different policies, this approach helps identify illegitimate administrative burdens, that do not contribute to achieving relevant public values or can be reduced without compromising relevant public values. This approach not only contributes to adding more nuance and dimensionality to the theory of administrative burden but also increases its relevance to policymakers and other stakeholders.

KEYWORDS:

• word
• administrative burden
• public values
• policy implementation

Administrative burden research has made valuable contributions towards improving our understanding of the different ways in which learning, compliance and psychological costs associated with different policies influence citizen experiences and access to state services (Christensen et al., 2020; Chudnovsky & Peeters, 2021; Herd & Moynihan, 2019; Masood & Nisar 2021; Moynihan et al., 2015; Nisar, 2018; Peeters, 2020). Researchers have found that such costs can be imposed both during the design and implementation phases of the policy process, and that ideology, experiences and identity of policymakers and practitioners influence the costs imposed on beneficiaries of social services (Baekgaard et al., 2021; Bell et al., 2021) and their perception of such burdens (Johnson & Kroll, 2021). Scholars have also empirically documented that excessive administrative burden can limit access to state services and that the bite of administrative burden is often experienced disproportionately by marginalised social groups (Heinrich, 2016; Herd & Moynihan, 2019; Nisar, 2018).

While administrative burden research has provided important insights about the social equity footprint of public policies, important theoretical limitations persist in this emerging line of inquiry. First, due to the subjective nature of citizen experiences and the way in which learning, compliance and psychological costs are measured, it has proven difficult to compare the burden of different policies. This is an important limitation from a practical point of view. If reduction of administration burdens is important for achieving access and equity, how can policy makers decide which policy or implementation option is better, more acceptable, or less burdensome? We are cognisant of difficulties associated with such quantification: Although learning and compliance costs can be quantified and compared in terms of the time and money required to learn about or comply with the requirements of a particular policy, psychological costs are much harder to quantify. While it is theoretically possible to quantify psychological costs by using approaches common in health policy and liability analysis like the willingness to pay approach or the pain and suffering multiplier (Levin & McEwan, 2000), there has been limited interest in such approaches in public administration research. This limited interest is both a reflection of important shortcomings in approaches that quantify pain and suffering (Avraham, 2006) and the explicit focus on qualitative subjective experiences within administrative burden research (Madsen et al., 2022). These theoretical caveats notwithstanding, an approach that allows a systematic analysis and comparison of the administrative burden of different policies can represent an important advance of administrative burden theory.

Second, and more pertinent, administrative burden research in its exclusive focus on the costs associated with a particular policy tends to overemphasise the burdensome dimensions of policy design and implementation. As Madsen et al. (2022, p. 376) note “the focus on frictions without benefits may blind researchers from addressing frictions where benefits exist but do not exceed costs or where costs more than justify the friction”. This observation is echoed by Baekgaard and Tankink (2022, p. 4), who note that the “extant research attends little to any positive experiences associated with state actions … [and] may very well lead to an overestimation of the negative consequences of sate action”. In general, the idea of “policymaking by other means” takes it for granted that administrative hurdles are included in policies to limit access for deserving participants and not for efficient utilisation of scarce public services (Madsen et al., 2022).

In many ways, administrative burden has moved in a similar direction to red tape research (Bozeman & Feeney, 2015), which for a long time also focused only on those “rules, regulations, and procedures that remain in force and entail a compliance burden for the organization but have no efficacy for the rules’ functional object” (Bozeman, 1993, p. 283). As multiple researchers (Moynihan & Herd, 2010; Moynihan, Herd & Harvey, 2015) have noted, the exclusive emphasis of red-tape research on rules that did not have a positive impact on organisational or stakeholder objectives limited the scope and relevance of the research. As Moynihan and Herd (2010) poignantly note, “in some cases, rules may achieve their legitimate goal but, at the same time, create a disproportionate negative burden on certain groups, negatively affecting their citizenship rights. This implies a redefinition of red tape that considers trade-offs between different values, specifically efficiency versus democracy concerns of equity and citizenship rights” (p. 655).

Another important consequence of this analytical choice is that learning, compliance and psychological costs have only been considered in existing administrative burden research if they negatively impact policy beneficiaries and positive aspects of accessing a particular policy have largely been ignored. However, as Carter et al.’s (2018) thoughtful discussion of the administrative burden associated with participation in voluntary programmes in the USA reveals, organisations participating in such programmes often get reputational benefits, that are an important reason for joining such initiatives. While Carter et al. (2018) use this evidence to argue that the administrative burden of voluntary programmes primarily consists of learning and compliance costs, an important implication of their analysis is that while learning and compliance costs deter potential participants, positive psychological benefits encourage them to join such programmes. In other words, some aspects of a policy or programme can incentivise while others can deter potential participants. Administrative burden theory, however, does not allow for an analytical consideration of this critical aspect of policy design and implementation even though it has obvious relevance to the way real-world stakeholders approach the decision of participating in a programme or accessing a social service. Therefore, an important outstanding research question in administrative burden scholarship concerns how to evaluate the costs and benefits associated with accessing state services and policies within the same analytical framework. In the sections that follow, we present public value accounting as a useful theoretical approach to address this important gap in administrative burden scholarship.

The state as the custodian of public values

A good place to star for a consideration of costs and benefits associated with government policies is to consider the role of the state as the custodian of public values in a society. The selective focus on negative costs has led to a situation where any administrative burden can be considered and presented as negative and illegitimate even if it serves important policy goals. For example, one could classify requirements like proof of pregnancy submission to access maternity benefits, identity documents to enter a country, and the practical test to get a driving licence as administrative burdens even though they serve to achieve important public values like transparency, allocative efficiency and accountability. Hence, this exclusive focus on costs of policy compliance can have important unintended consequences limiting the value of the otherwise important contributions of administrative burden research.

Indeed, a striking feature of the literature to date is how little attention has been devoted to the state’s traditional roles as a countervailing force that limits the influence of powerful interest groups and as a custodian of public money that ensures it is used in a fair, transparent, equitable and efficient manner. This is partly because an important fundamental question that remains unexplored in administrative burden theory and research is whether minimisation or reduction of administrative burden should be an important goal of all policy design and implementation. In other words, if official requirements to access a state service or implement a policy are completely removed, would that be a desirable situation? The implicit answer provided by most administrative burden research is that it is always normatively desirable to reduce administrative burden, and that reduced administrative burden always improves citizenship and equity. However, this inference is partly determined by the policy domains chosen by researchers. It is easy to make such an argument in the context of social welfare (Herd et al., 2013; Moynihan et al., 2015; Peeters & Campos, 2021), voting (Burden et al., 2014), child support grants (Heinrich, 2016), maternity leave (Masood & Nisar, 2020), and legal IDs (Nisar, 2018), but the same argument cannot easily be made in the context of behaviours that can be detrimental to the achievement of public value goals.

In this regard, it is important to be cognisant of Moore’s important warning that “while it might be prudent and just for government agencies to treat those receiving obligations with decency and respect for their rights, it did not seem self-evident that the main purpose of these encounters should be to satisfy them [i.e., the targets of such policies]. If the goal were to satisfy these customers, most of them would have been happy to dispense with the encounter altogether!” (Moore, 2013, pp. 2–3). Indeed, research indicates that high administrative burden of public programmes can increase their favourability among the wider public (Nicholson-Crotty et al., 2021). An illustrative example in this case comes from the requirements of buying a gun in the USA, where it is a constitutionally protected right and groups such as the National Rifle Association (NRA) advocate for the reduction of administrative burdens like waiting periods, age limits, and background checks, often using the language of individual rights and freedom (Steidley & Colen, 2017). Advocates of such administrative burdens argue, however, that such administrative burden, despite being onerous, are important for public safety.

Similarly, huge companies like Google and Facebook have repeatedly cast any government oversight over matters like privacy, surveillance, fake news and commercialisation of behavioural surplus as examples of administrative burden (Zuboff, 2019a). These companies have frequently argued that such policies incur huge compliance costs and introduce market inefficiencies that can easily be avoided if these policies are repealed (Zuboff, 2019a). Most stakeholders agree, however, that critical public value failures could result if there was no administrative burden imposed on these companies to ensure transparency, accountability and democratic oversight over the collection and subsequent use of consumer data (Zuboff, 2019b; Cinnamon, 2017). In these situations, the existing conceptualisation of administrative burden is insufficient to guide academics, practitioners and the public and can be counterproductive to the original goal of administrative burden research; to improve policy design and implementation to achieve collective democratic goals.

Finally, an important relevant distinction, pointed out in the broader literature on administrative hassles to access social services is between individual and collective goals. While individuals may incur costs to access state services, the society might benefit, for example, by increasing the targeting efficiency of limited social services such that more deserving individuals apply when administrative burdens are increased. As Moore (2014, p. 470) points out, “State authority is restrictive. It takes away choice. It hurts. But the loss is not only to the individual on whom the specific obligation is imposed, it is also to all who have been forced to surrender some of their individual freedom and liberty to the collective and might well fear that without constant vigilance, they will lose even more”.

Therefore, it is critical to have an analytical framework which allows a systematic consideration not only of the costs associated with a policy, programme, or service but also the collective social goals it is supposed to achieve to enable a distinction between necessary and unnecessary administrative burdens. In the subsequent sections, we will first develop a theoretical foundation for the public value-based formulation of administrative burdens. We will then theoretically illustrate this approach of accounting for public value by integrating administrative burdens using the example of maternity leave. We will then discuss some of the important limitations and future directions for improvement and research.

Public value based conceptualisation of administrative burden

We contend that public value theory can provide a useful analytical framework to introduce a systematic consideration of costs and benefits of public policies in a way that allows an analytical distinction between necessary and unnecessary administrative burdens imposed on policy targets. Despite its multiple formulations (Bozeman, 2002, 2007; Meynhardt, 2009; Moore, 1995, 2014) and contestation over its terminology (Brown et al., 2021), the basic premise of the public value theory is that the level of achievement of certain values is the primary yardstick on which public policy design and implementation can be judged in a democratic society. A critical contribution of the public value approach is to point out that profit maximisation or utilitarian considerations cannot be the only yardstick on which public policies and programmes can be evaluated (Moore, 1995). Instead, organisations, policies, and programmes, especially those funded from the public money, must focus on achievement of certain collectively held social ideals.

The concept of public value developed at the end of the twentieth century because of the broad dissatisfaction with the New Public Management (NPM) movement and its exclusive focus on neoliberal governmental techniques and idealisation of efficiency as the predominant ideal for public service delivery (O’Flynn, 2007; Talbot, 2011). Critics argued that the conceptualisation of citizens as consumers led to the erosion of democratic values and norms of public service delivery due to NPM-based governance reforms in various parts of the world (Alford & O’Flynn, 2009; Radnor & Osborne, 2013). This concern about the neglect of equity, transparency and accountability in public services delivery led to scholars looking for alternative ideals for the discipline which eventually culminated in the development of the public value theory.

Moore (1995, 2013, 2014), often credited with the earliest exposition of public value theory, argued that instead of cost-efficiency, public value accounting could serve as a better yardstick to assess the performance of programmes and policies funded by the public money. He argued that while private managers focus on maximising private value, public managers instead must focus on trying to achieve the highest level of public value for a specific outlay of resources. His concept of the strategic triangle (Moore, 1995) focused on creation of public value by managers working in the public sector. The strategic triangle conceptualisation argued that public value could be created only when a particular policy or programme had democratic legitimacy and support, and the relevant organisation had the operational capacity to successfully implement a particular policy or programme. The strategic triangle could also serve as an evaluation framework because failure to achieve public values would lead to lower legitimacy and support for a policy, prompting policymakers to divert resources away from it.

While Moore conceived of the public value perspective as a governing framework for managers engaged in public service delivery, Bozeman, the main architect of public values theory in public administration defined public values as “those providing normative consensus about … the principles on which governments and policies should be based” (Bozeman, 2002). While Moore’s approach focused on the public managers and their utilisation of public values as guiding principles in their work, Bozeman’s approach primarily analysed public values the policy or societal level. Therefore, a lot of work in this line of inquiry analysed the conditions for identifying and enacting principles that could be considered public values in a particular society and serve as the normative ideal for public service delivery (Bozeman, 2002, 2007, 2019; Jorgensen & Bozeman 2007). This research has led to fruitful insights about public service design and provision. Especially significant contributions emerging from this line of inquiry have been the concepts of realised publicness, which refers to the extent a particular policy or programme achieves public values (Moulton, 2009), and public value failure, which refers to situations where policies or programmes concerned with achievement of public values fail to do so (Anderson & Taggart, 2016; Bozeman, 2002). Both these concepts present an evaluative framework to judge the success or failure of government programmes and policies.

However, it is the concept of a public value account developed by Moore (2013); Moore (2014) that is most relevant to the present discussion. The public value account offers a useful approach to allow consideration of both costs and benefits associated with different public policies. At a basic level, the public value account is an analytical tool that compares the costs associated with achieving certain collectively valued social outcomes by a public policy or programme. Moore (2013) argues for inclusion of financial costs, unintended negative consequences, and social costs of using state authority as the price associated with achieving public values associated with a policy or programme and provides a five-step guide to develop a public value account (see Table 1 for further details).

Table 1. Moore’s approach towards operationalisation of a public value account (Reproduced from Moore, 2013).

Use of Collectively Owned Assets and Associated Costs	Achievement of Collectively Valued Social Outcomes
Financial Costs	Mission Achievement
Unintended negative consequences	Unintended Positive Consequences
	Client Satisfaction
	Service Recipients
Social costs of using state authority	Obligatees
	Justice and Fairness
	At individual level in operations
	At aggregate level in results

While Moore’s formulation is insightful, it does not account for financial, temporal and cognitive costs that are imposed on policy beneficiaries and implementors. As documented by administrative burden research, there are multiple formal and informal costs imposed on relevant stakeholders and omitting such burdens from a public value account does not allow for a full consideration of the public value footprint of a policy. Hence, a more comprehensive consideration of the burdens experienced by different stakeholders is required for a complete understanding of the total costs imposed by a particular policy. Moreover, integration of these costs within a public value account helps address the issue of considering and analysing tradeoffs between costs and benefits of a policy, something missing from administrative burden research.

Before discussing the details of a public value account which would integrate administrative burden, it is important to briefly discuss its philosophical foundations. While a cost and benefit framing does seem to bring in utilitarian considerations into thinking about the value of public programmes, public value accounting makes no assumptions about the quantitative measurability of the costs and benefits in a public value account. Moreover, as Moore (2014) argues, the public value accounting approach is also based on deontological considerations that do not rely on quantifying outcomes or efficiency considerations but on ensuring the normatively fair use of public money and authority. This later focus is much more aligned with the fundamental motivation behind much of administrative burden research. Hence, the underlying objective of public value accounting is to enable a systematic analysis of (both quantitative/qualitative, subjective/objective) costs and benefits associated with a public policy or programme so that relevant stakeholders can observe, anticipate, negotiate, and contest any undesirable processes or outcomes.

Integrating administrative burdens and public values

Based on the discussion above, we propose a different methodology of public value accounting, which allows for inclusion of administrative burdens in a public value account. We suggest that such accounting be done from the perspective of three key stakeholders in the public value chain: the state, frontline implementors and the citizens. Table 2 provides details about the key categories to be included in a public value account approach advanced here. In line with our broader view of total costs of implementing a public policy, we include financial, time, and psychological costs incurred by citizens and frontline implementors in the public value account. We use the instructive example of maternity leave policies to illustrate how such an approach can be used for consideration of illegitimate and inefficient administrative burdens. Since the administrative burden of maternity leave policies has been discussed in previous research (Masood & Nisar, 2021; Masood & Nisar, 2020), this example also provides a useful comparison between our approach and existing ways of analysing administrative burden without considering benefits of such policies.

Table 2. Key items in a public value account measuring administrative burden.

Costs from the Public Perspective	Public Value Benefits
Cost of implementation for the state	Achievement of Relevant Public Values
Citizen’s Burden of Implementation	Equity
Financial Costs	Effectiveness
Time Costs	Efficiency
Psychological and Cognitive Costs	Accountability
Frontline Burden of Implementation	Transparency
Financial Costs
Time Costs
Psychological and Cognitive Costs

The cost of public services

Costs of implementation for the state

On the cost side, financial costs to the public exchequer are the first and most obvious element of a public value account. These costs include all aspects of policy implementation that are financed by the government. This information is generally easily available in official budgetary documents and, at least in the context of administrative burdens, may not be of primary importance as these are unlikely to be borne directly by policy beneficiaries unless directly associated with a fee or tax imposed on policy beneficiaries or the larger public. These costs are, however, important from the perspective of efficient allocation of public resources and efficiency driven evaluation of policies will focus on finding out ways to reduce these costs while keeping the level of public values at the same level. For example, in the context of maternity leave policies, the direct financial costs will include annual expenditure on maternity leave of government employees, annual expenditure on maternity leave of private employees subsidised by the government, annual administrative expenditure (salary of relevant staff and their logistical support expenditure), and enforcement costs (salary of staff dealing with complaints and non-compliance).

Citizens’ burden of implementation

An important goal of the public value account approach is to enable an analysis of costs associated with a public policy or programme from the public perspective. While Moore’s (2014) formulation does include some non-financial costs by accounting for unintended negative consequences and social costs of using state authority that can be an important part of administrative burdens, it largely ignores “policymaking by other means” (Herd & Moynihan, 2019). Indeed, a critical contribution of administrative burden research is to highlight that many non-financial costs imposed on policy beneficiaries, especially those belonging to marginalised social groups, are deliberately included in many public programme designs. However, such negative costs, like the financial, monetary and cognitive resources required to enrol in a state service, are not accounted for in Moore’s (2014) conceptualisation of the public value account. Moreover, the current formulation of social costs in the public value account are limited to the costs of using state authority. Other social and psychological costs like stigma, anxiety and ostracisation, important dimensions of citizen experience as pointed out by previous research (Moynihan et al., 2015), are also not part of the public value account proposed by Moore (2014). That is where addition of an administrative burden-based conceptualisation of costs can improve framing and utility of a public value account.

We suggest that a good way to operationalise the burdens imposed on stakeholders of a particular policy is to consider them along financial, time and psychological dimensions. Analysing administration burden along these dimensions provide multiple advantages over the currently used learning/compliance/psychological cost framework because in the later framework, some costs borne by policy beneficiaries are not mutually exclusive. For example, it is unclear whether the cognitive cost of filling a difficult government form should be included in the compliance cost category, the psychological cost category or both. On the other hand, financial, time and psychological costs are not only largely mutually exclusive but also represent commonsensical ways in which citizens weigh different burdens of accessing social service. Moreover, previous research has shown that citizens accessing state services may interchange some costs based on their unique concerns (Masood & Nisar, 2020). For example, the more affluent clients can pay more money for more expedient services thereby reducing their time costs or hire third-party navigators to reduce their time and psychological costs. Such interchangeability, however, is not easily possible in the learning/compliance/psychological cost framing of administrative burden.

Financial costs refer to all monetary costs borne by those individuals who are affected by a particular public policy. Examples include costs associated with learning about eligibility requirements, admission fees and transportation costs of reaching a government office. In the context of maternity leave policies, as documented by Masood and Nisar (2020); Masood & Nisar (2021), expenses on proof of pregnancy, bribes, facilitation fees and other medical tests are included in financial costs imposed on maternity leave applicants.

Time costs refer to the total time required to access a government policy or programme. Examples include the time taken to comply with enrolment requirements and waiting periods at government offices. If needed, time costs can easily be converted to monetary value using opportunity cost of time based on respondents’ or national income data. In the context of maternity leave policies, the time needed to fill different forms, visit government offices and delays in application processing are typical examples of time costs imposed on maternity leave applicants (Masood & Nisar, 2021; Masood & Nisar, 2020).

Psychological costs refer to the costs resulting from coping with the direct and indirect stressors or perceived stigmas associated with participation in a programme or receipt of service (Schibalski et al., 2017). Examples include harassment, and stigma associated with participation in particular programmes. Psychological costs also include cognitive costs that refer to the mental effort required to access or implement a particular policy and includes loss of knowledge resulting from failure of policy implementers and beneficiaries understanding each other. Examples include effort required to learn about new rules, administrative procedures and bureaucratic behaviour. While cognitive costs are harder to measure objectively, standard approaches used in behavioural economics like the willingness to pay approach can be used to monetise these values, if needed. In the context of maternity leave policies, psychological costs include the motherhood stigma, discrimination from supervisors, peers and frontline workers, and perceived lack of job security (Masood & Azfar Nisar, 2021; Masood & Nisar, 2020).

Frontline burden of implementation

While administrative burden research has mostly focused on costs imposed on citizens, some work has documented the significance of such burdens for policy implementors (Burden et al., 2012). However, no previous work has analytically considered the burden on citizens and policy implementors in the same analytical framework. An important reason why burdens imposed on policy implementors should be included in public value accounting is because the public value chain requires (and assumes) that frontline organisations have the operational capacity to implement relevant policies. However, the administrative burden experienced by the citizens, especially in developing countries, increases if the frontline organisations lack the administrative capacity or resources to implement relevant policies (Ali & Altaf, 2021; Bashir & Nisar, 2020). Moreover, if a policy incurs high psychological or time costs on frontline implementors, such burdens may be shifted to policy beneficiaries or other stakeholders (Burden et al., 2012; Tummers et al., 2015) and a consideration of such costs is also warranted for any efficiency-based evaluation of policy implementation.

More importantly, private or third-party organisations are increasingly involved in public service delivery and some costs borne by them are often passed onto the policy beneficiaries. In case of the maternity policies for example, some administrative burden is borne by private employers who have to establish human resource mechanisms for provision of maternity leave benefits in their organisations (Stumbitz et al., 2018). These costs include the annual financial expenditure on maternity benefits borne by private organisations, psychological costs of dealing with service delivery challenges, learning about relevant policy rules and consideration of individual cases in accordance with relevant laws for frontline workers and managers, and time cost imposed on frontline implementors concerning official compliance documentation and enforcement procedures. These costs are part of the reason why, in countries where employers also bear financial costs of maternity leave, organisations often end up discriminating against women in promotion and hiring decisions (Masood & Nisar, 2021; Masood & Nisar, 2020). The same is the case with employer-provided healthcare (for example, in the US), where the burden of enrolment is often borne by private organisations. Therefore, relevant financial, temporal and psychological costs experienced by street-level bureaucrats implementing policies should also be included in a public value account-based consideration of administrative burdens.

Enumerating the public values

Different public values that are explicitly or implicitly supposed to be achieved by a particular policy or programme represent the benefits in a public value account (Moore, 2014). As Bozeman (2019) notes, identification of public values has remained a contentious issue in the public values theory due to plurality of stakeholders and lack of a unified approach to accord primacy to the perspectives of different stakeholders. While this difficulty is an important consideration for prioritisation of public values at the societal level, at the policy or programme implementation level, official policy documents and discourses can serve as a reasonable reference point for identification of relevant public values. In other words, once a policy has been approved by the relevant forum entitled to do so in a polity, the public value targets specified in official policy documents can be considered as being representative of the collective will of the society. There are admittedly well-known problems associated with this assertation; democratic fora are not adequately representative, some groups are unable to participate in the policy discourse, and interest groups often dominate policy design and formulation stages (Jacobs, 2014).

These concerns notwithstanding, it is important to differentiate between consideration of administrative burdens and public values at the design and implementation stages of the policy process. At the design stage, questions about the normative (deontological) and instrumental (utilitarian) appropriateness and feasibility (administrative and technical) of proposed policies concern the policymakers and Meynhardt’s public value scorecard approach offers a better way to approach such decisions (Meynhardt, 2009, 2019; Timo Meynhardt, 2015). However, once a final decision has been made about these fundamental questions, at the policy implementation and evaluation stages, the primary emphasis shifts towards analysing the administrative burdens and public values realised because of a particular policy.

In addition to the explicit public values mentioned in a policy document, certain public values are implicitly associated with the evaluation all public policies in a democratic society and include equity, efficiency, effectiveness, accountability and transparency. Consider, for example, maternity leave policies introduced by most countries around the world to facilitate women employees in the workforce. It is easy to specify that these policies are meant to make sure a) the jobs’ of expecting mothers are protected, b) they have sufficient time off from their work to cope with demands of pregnancy and birth, and c) to provide financial security to them during this time. In addition to these explicit public values that concern their effectiveness, other implicit values relevant to maternity leave policies are, a) whether all pregnant working mothers are able to access maternity benefits in an equitable manner (equity), b) whether the same level of maternity benefits can be provided at lower costs (efficiency), c) whether those individuals or organisations that do not comply with this policy are held accountable (accountability), and d) whether enough information is available about all these aspects of maternity leave policy implementation for the general public to make an informed opinion (transparency).

It is also important to include relevant indicators to reliably measure, to the extent possible, the level to which these public values have been achieved (Moore, 2014). A combination of objective and subjective indicators offers the best way for a comprehensive understanding of public value accomplishment. It is also important to include indicators that enable measurement of fairness and effectiveness of the process (not just the outputs) of the relevant policies, especially in the social services sector. An important finding of administrative burden research is that it is often at the implementation stage where most administrative burdens become apparent and fairness in the process through which the applicants access social services often include multiple formal and informal hurdles that limit their access.

In the context of maternity leave policies, it is not only important to measure the satisfaction scores of maternity leave applicants from the benefits available through maternity leave but also to find out their satisfaction from the different procedural requirements to access them. A significant difference between the two can be a good indication about implementation level administrative burden that can be reduced while keeping public value achievement constant. Table 3 provides a suggested breakdown of the different public values associated with maternity benefits policies and indicators that can be used to measure the level of their achievement. The list of public values and indictors presented in the table is not meant to be exhaustive but to be illustrative of the approach advanced in this article. The particular values and indicators to be used in any public value accounting approach will ultimately depend upon the local policy context and the concerns of relevant stakeholders.

Table 3. Public value accounting of maternity leave policies for assessing administrative burdens.

Public Value Account of Maternity Leave Policies
Stakeholder Costs	Public Value Benefits
Costs of Policy Implementation for the State Annual cost of maternity leaves of government employees Annual cost of maternity leaves of private employees subsidised by the government Annual administrative costs (annual salary of relevant staff and their logistical support expenditure) Annual enforcement costs (annual salary of staff dealing with complaints and non-compliance) Citizens’ Cost of Policy Implementation Annual financial costs reported by applicants (corruption, bribes, expenses on proof of pregnancy and other medical tests) Annual time costs reported by applicants (time needed to fill different forms, government office visits, delays in application processing) Annual psychological and cognitive costs reported by applicants (stigma of maternity leave, job security, informal discrimination, learning about relevant laws and workplace policies) Annual cognitive costs reported by applicants (learning about relevant laws and workplace policies) Frontline Cost of Implementation Annual financial costs for policy implementors (annual cost paid by private organisations in lieu of maternity benefits, training costs, salary costs of temporary replacements in private organisations) Annual psychological and cognitive costs for policy implementors (decision burden to deal with morally and ethically challenging cases, coping with service breakdown, learning about policy rules) Annual time costs for policy implementors (documentation requirements, enforcement procedures)	Effectiveness All those who want and deserve maternity leaves can get them Indicators: Annual number of women employees accessing maternity leave Average annual satisfaction score of applicants of maternity leaves from the process and benefits of maternity leave Equity All pregnant working mothers can access maternity benefits in an equitable manner Indicators: Output equity: Average annual satisfaction score of applicants of maternity leaves of minority and marginalised groups (including single mothers, divorced mothers, and other demographic categories) with benefits available from maternity leave. Each group separately reported Process equity: Average annual satisfaction score of applicants of maternity leaves of minority and marginalised groups (including single mothers, divorced mothers and other demographic categories) with the process of applying for maternity leave. Each group separately reported Efficiency Maternity benefits achieved in relation to given amount of resources/inputs Indicators: Comparison of annual effectiveness indicators and total cost of implementation with past years. Comparison of annual equity indicators and total cost of implementation with past years. Comparison of annual accountability indicators and total cost of implementation with past years. Comparison of annual transparency indicators and total cost of implementation past years. Accountability Organizations that do not comply with maternity policies are held accountable Indicators: Percentage of organisations complying with the policy Annual fines imposed on noncompliant organisations Transparency Enough information is available about all aspects of maternity benefits policy implementation for the public to make an informed opinion Indicators: Percentage of relevant indicators available for free on publicly accessible forms in easy-to-understand manner.

Evaluating illegitimate and inefficient administrative burden

After the costs and benefits associated with a particular policy have been listed in a public value account, it is easy to identify costs that represent unnecessary administrative burden. Unnecessary administrative burden can be defined as all policy relevant financial, temporal, cognitive and psychological costs that a) are considered onerous by those affected by a particular policy and do not contribute to achievement of relevant public values (illegitimate administrative burden), and b) are considered onerous by those affected by a particular policy and can be reduced without compromising the achievement of relevant public values (inefficient administrative burden). Hence, the guiding principle for establishing what costs classify as administrative burden is whether they can be eliminated or reduced while keeping the level of public value achievement constant. For example, if there are any government forms or application procedures that can be eliminated without compromising on public values like accountability, transparency and equity then they should be considered as administrative burden.

Conversely, if certain onerous costs for policy beneficiaries help achieve public values and there is no better way to achieve them, they should not be considered administrative burdens. For example, in the context of maternity leave policies in Pakistan, as Masood and Nisar (2020), Masood and Azfar Nisar (2021) have shown, there are multiple time costs like requiring attestation requirements on medical documents, and psychological costs like harassment and discrimination towards working and expecting mothers, that do not contribute towards achieving any public value and should be classified as examples of illegitimate administrative burden. Similarly, there are other financial costs like fees related to medical tests required as proof with maternity leave applications, time costs like administrative processing of applications, and psychological costs like the pressure to return to job after a standard time limit of 90 days, which do contribute to achieving relevant public values but there are better ways to achieve those public values while reducing these costs to policy beneficiaries as evidenced by the approaches adopted by other countries. Introduction of mandatory time limits for processing maternity benefit applications or providing cover for any medical expenses incurred to access maternity benefits are examples of such policy options. According to the perspective advanced here, such costs should be considered examples of inefficient or avoidable administrative burden.

Discussion

There is increasing consensus among scholars working on administrative barriers imposed on policy implementors and beneficiaries that a systematic consideration of costs and benefits is important to increase the real-world relevance of this line of inquiry (Bozeman, 2012; Kaufmann & Haans, 2021; Madsen et al., 2022; Nisar & Masood, 2018; Shahab & Lades, 2021). As Madsen et al. (2022, p. 385) note, “most real world examples … represent trade-offs, where costs sometimes outweigh benefits and sometimes not, where rules will lack function for some purposes or groups but serve others. A definition that excludes frictions with some benefits … therefore also excludes the vast majority of frictions, even those where the net benefits are not justified”. This paper presents a modified public value account approach as an analytical framework for a systematic consideration of costs and benefits associated with different policies. In doing so, it makes the following contributions to research and theory on administrative burdens and public values.

First, it refines the conceptualisation of administrative burden associated with public policies to account for costs that are associated with achievement of relevant public values. It further allows a critical distinction between necessary and unnecessary administrative burden imposed by public policies, thereby addressing an important limitation in previous research (Baekgaard & Tankink, 2022; Madsen et al., 2022). According to the public value accounting approach adopted here, only those administrative burdens that do not contribute towards achieving policy relevant public values or provide suboptimal ways of doing so should be considered unnecessary administrative burden. It further allows for an analytic distinction between illegitimate and inefficient burdens imposed on policy beneficiaries. This represents an important step in increasing the real-world relevance and dimensionality of the concept of administrative burden.

Second, the analytic framing provided here does not rely on a utilitarian conceptualisation of policy costs and benefits common in economic approaches towards policy evaluation like cost–benefit analysis, rate of return analysis, and cost-evaluation analysis. Instead, it provides a framework which is in line with a normative focus on democratic ideals and rights in the administrative burden theory (Herd & Moynihan, 2019) and provides a way to account for subjective assessment of costs and benefits of a public policy. While this approach does not rely on quantification of the costs and benefits imposed on relevant stakeholders, it represents a useful first step to develop an analytical framework to compare the administrative burden of different policies. One way this could be done is by comparing the inefficient and illegitimate burdens of different policy options allowing policymakers to choose options that impose lower burdens on policy beneficiaries.

Third, it contributes to public value theory by providing a way to incorporate administrative burden within a public value account. This allows a more comprehensive evaluation of different costs associated with a public policy. While Moore’s (2014) approach is a useful starting point, inclusion of different types of costs incurred by the citizens and frontline administrators of state policies allows for a more fine-grained analysis of the overall social costs and inefficiencies in state policies. Consideration of administrative burdens within a public value account also allows policymakers and public managers to more easily find out costs that can be removed to improve the experience of relevant stakeholders and/or improve the achievement of relevant public values.

While this approach offers a useful path forward for both public value theory and administrative burden research, pursuing this path will require exploration of some critical questions. For example, an important concern with this conceptualisation of a public value account and administrative burden, pertains to situations where the subjective opinion of different relevant stakeholders is in direct opposition or relates to different public values. Consider, for example, the requirement to bring one’s own car to the DMV for a driving test. From the perspective of the organisation, this rule is not onerous as it keeps operational costs at a low level for the DMV as compared to maintaining a fleet of cars on public expenditure (relevant public value: efficiency). On the other hand, for citizens, it is an onerous requirement since many individuals (especially having low socio-economic status) do not own a car and will need to ask someone for a favour which may come with its own costs (relevant public value: equity). In such cases, it is often not immediately clear which public value and which stakeholder should have precedence in decision-making.

While it is difficult to conceive a solution that could be acceptable to all stakeholders and it represents an important area of theoretical and philosophical inquiry, existing work in ethical theory does suggest that rights and justice considerations should generally take precedence in over utilitarian concerns (Velasquez, 2012) unless the benefit to society is so overwhelming that restrictions of some civil liberties could be justified (e.g., in war and epidemic). Meynhardt’s (2009) conceptualisation of the public value scorecard could also prove helpful in such conditions. Instead of focusing on one value conflict, it rates different policies based on their overall score across different dimensions of appropriateness. A policy that scores well on efficiency but consistently scores low on equity, for example, might represent a need for policy modification.

Ultimately, such value conflicts, like all value conflicts, must be resolved in a democratic public sphere where all stakeholders are able to participate, and a publicly accessible public value account could help provide more structure to such public and policy discourse. Importantly, citizen-state deliberation can serve other important and relevant public values. For example, in some cases, the perception of a rule being onerous may be due to limited understanding of its functional objectives by the public. In such cases, the perspectives of stakeholders (or employees) might change after meaningful deliberation or communication about the legitimate objectives of that rule, thereby reducing perceived administrative burden without any changes in official rules.

Another important challenge for its empirical relevance of public value lies in identification of relevant stakeholders for a public value account. In some cases, it could be difficult to identify and limit the relevant stakeholders of a particular policy. For example, in case of the maternity leave policies, should husbands of working mothers be considered relevant stakeholders or not is an interesting question and helps highlight the broader identification dilemma as to whether the definition of stakeholders should include only those individuals who are directly involved in implementation of a policy or are its direct beneficiaries. There are legitimate reasons for considering opinions of the larger public as their perspective on issues like accountability and monitoring requirements might be at odds with those enrolled in the programme (Moore, 2014). However, Bozeman (2012) – who provides a more detailed discussion of such problems including measurement and identification of stakeholders in red tape research – correctly notes that these problems are not insurmountable and is an integral part of all social science research having an evaluative focus. For identification of the right stakeholders, a simple yet effective approach in most cases would be to limit them to the enrolled or eligible clients of the focal organisation or programme. For example, in case of research on traffic police stops, those individuals who have been stopped by police should be considered the primary stakeholders (as was the approach adopted by Epp et al., 2014). Put simply, this is a familiar boundary setting problem in social science research and like most things the simplest solution of focusing on the direct clients is likely to be the best starting point. While the public is an important stakeholder of all public policies, the operational costs associated with doing large scale public surveys about every policy make it empirically impossible to do so. Ultimately, feedback of the larger public can best be incorporated at the policy design stage through democratic elections and implementation-stage analysis should limit themselves to a consideration of the perspectives and experiences of direct policy implementors and beneficiaries/targets.

Conclusion

A critical contribution of this article is that it helps conceptualise costs and benefits associated with different policies in the context of a public values framework. Relating citizens’ experiences with public values provides us a way of differentiating and targeting unnecessary administrative burdens that can be reduced without affecting the achievement of relevant public values. The ultimate goal of public administration research is to find better ways of delivering public services. A public value-based conceptualisation of administrative burden provides a more nuanced approach towards balancing the often-opposing demands of reducing administrative burden and maintaining the legitimacy of public programmes. In doing so, it also increases the relevance of administrative burden research to real-world stakeholders who must contend with both the costs and benefits associated with public service provision. Moreover, by allowing conceptualisation and identification of illegitimate and inefficient administrative burdens, it presents a useful way to improve service delivery provision without compromising on achieving relevant public values. This article also points to important areas for future research which include empirical analyses of administrative burden based on public value accounting; consideration of measurement dilemmas of public values and psychological costs; and better ways to identify and integrate stakeholder perspectives in a public value account.

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Additional information

Notes on contributors

Muhammad Azfar Nisar

Muhammad Azfar Nisar is Associate Professor of Public Administration and Policy at Lahore University of Management Sciences. His research interests include administrative burden, social equity, and policy implementation.

Ayesha Masood

Ayesha Masood is Assistant Professor of Organizational Behavior at Lahore University of Management Sciences. Her research interests include work-life balance, administrative burden, gender identity, social equity and policy implementation.