Factors influencing the reliability of costings of policy proposals The PBO’s approach to reliability ratings Technical note no. 01/2015 Date issued: 30 June 2015 PBO technical notes PBO technical notes are published to help explain the underlying data, concepts and methodologies that the PBO utilises in preparing costings of policy proposals and analyses of the budget and fiscal policy settings. The focus of PBO technical notes is different from that of PBO research reports which are aimed at informing public understanding of budget and fiscal policy issues more broadly. © Commonwealth of Australia 2015 ISBN 978-0-9925131-8-4 (Online) This work is licensed under the Creative Commons Attribution-NonCommercial-NoDerivs 3.0 Australia License. The details of this licence are available on the Creative Commons website: http://creativecommons.org/licenses/by-nc-nd/3.0/au/ Use of the Coat of Arms The terms under which the Coat of Arms can be used are detailed on the following website: www.itsanhonour.gov.au/coat-arms Produced by: Parliamentary Budget Office Designed by: Studio Tweed First Assistant Parliamentary Budget Officer Budget Analysis Division Parliamentary Budget Office Parliament House PO Box 6010 CANBERRA ACT 2600 Phone: (02) 6277 9500 Email: pbo@pbo.gov.au Contents Overview ________________________________________________________________ 1 1 Why include reliability ratings? __________________________________________ 1 2 Factors affecting the reliability of costings __________________________________ 2 3 2.1 Data ___________________________________________________________ 2 2.2 Assumptions _____________________________________________________ 2 2.3 Volatility of the costing base ________________________________________ 3 How these factors are taken into account __________________________________ 4 iii Overview Costings are estimates of the financial impact of policy proposals, generally over some future time period. Despite being the best possible estimates of the impact of a policy, all costing estimates are subject to uncertainty, the level of which will vary from costing to costing depending upon factors such as data quality, assumptions and the volatility of the costing base. Because the level of uncertainty varies, the Parliamentary Budget Office (PBO) includes reliability ratings in its costings as an indication of the level of confidence a user of the costing can have that the actual outcome of a costing would correspond to the costing estimate. The reliability rating is not a reflection on the policy proposal being analysed or on the quality of the costing analysis. 1 Why include reliability ratings? The PBO undertakes costings of policy proposals for parliamentarians. The PBO’s estimates are prepared subject to the same rules and conventions as government budget estimates and are the best possible estimates of the financial impact of a policy, given the information, time and resources available. Notwithstanding this, there are a number of elements that introduce uncertainty into the costing process which mean that the point estimate values in some costings will more accurately represent the actual outcomes (were the policy implemented) than is the case for other policy costings. The PBO includes reliability ratings in its costings of policy proposals to show that costing estimates are uncertain and to indicate the level of confidence that a user of the costing can have that the actual outcome of the policy costed (if implemented) would correspond to the costing estimate. When assessing the level of uncertainty that attaches to a costing estimate, the PBO considers issues such as the quality of the data underpinning the costing, the number and veracity of any assumptions made in the costing and the inherent volatility in the costing base being estimated. These factors are discussed in Section 2. The reliability rating is not a reflection on the policy proposal, nor does it reflect on the quality of the costing analysis undertaken. Uncertainty is something that affects all costings, regardless of who produces them. For instance, the United Kingdom’s Office of Budget Responsibility recently adopted a system of uncertainty ratings for each certified policy costing included in the United Kingdom Budget based on the approach of the Australian PBO1 outlined in this note. 1 See: “Economic and fiscal outlook”, Office for Budget Responsibility, United Kingdom, March 2015. Page 201 Factors influencing the reliability of costings of policy proposals 1 The issue of uncertainty in projections and costings has also been recognised by the United States Congressional Budget Office which also seeks to highlight the uncertainty in its estimates2. 2 Factors affecting the reliability of costings The three most important factors affecting the reliability of costings are the quality of the data available to undertake the costing, the number and soundness of any assumptions made in the costing analysis and the volatility of the costing base itself. 2.1 Data Data is the factual base from which the costing analysis starts. Data is used as the basis for describing the costing base and/or eligible population for a costing analysis. The data used in policy costings can come from a range of sources which can differ significantly in quality, where quality is measured in terms of the certainty with which the data represents the target population for a costing analysis. Data from sources such as unit record administrative data can be regarded as being of very high reliability as it represents the actual outcome of programmes and in many cases can provide a high level of detail regarding the target population for a costing analysis. The Australian Bureau of Statistics (ABS) produces a wide range of high quality data that is the product of rigorous statistical techniques. Many ABS surveys come with quantitative measures of the quality of the data including measures of the error margin of estimates and indicators against the more uncertain data values. Less reliable data will be that which is out of date, does not directly relate to the costing base being estimated, comes from small sample surveys, or which originates from less rigorous statistical sources or those with an uncertain reputation. In many cases, high quality data may not be available, with the result that a costing will have to be based on lower quality data sources, introducing a greater level of uncertainty into the costing estimates. 2.2 Assumptions Assumptions are utilised in costings to fill in gaps where data is not available and to take account of matters pertinent to the costing, such as the behavioural responses of those affected by a proposal. Assumptions can be used to fill data gaps where the data available for a costing does not provide the level of detail needed to cost the policy specified. 2 2 See: “Communicating the Uncertainty of CBO's Estimates”, post by Doug Elmendorf, December 15, 2014 at http://www.cbo.gov/publication/49860. Factors influencing the reliability of costings of policy proposals In such cases assumptions may be used to fill in the gaps in the data in order to estimate values for the target population for the costing. Ideally, this would be done by using other data sources (such as distributional data for a similar population) to estimate the values for the target population (proxy data). In this case, the model would be assuming that the proxy data provides a good means of estimating the values for the target population from the data source being used. The reliability of such assumptions will depend upon both the quality of the proxy data source and upon how closely the distribution of the proxy data fits that of the target population for the costing. The least reliable approach would be to use an assumption based on judgement relating to what would be considered a ‘reasonable’ value for the missing data. Assumptions may also be used to take account of the impact of the behavioural responses of the target population to the proposal being costed. The quality of behavioural response assumptions may range from those based on relevant and well-researched studies, to those based on the judgement of the analyst. In the context of behavioural responses, an assumption that frequently implicitly forms the basis of costing analyses is that of ‘no behavioural change’. This assumption is that the policy being costed has no impact on the base volume (or value) of transactions being undertaken. For policies that impact on the ‘price’ of transactions or which are intended to change behaviour, this is an extreme behavioural assumption that implies that the transactions concerned are completely price inelastic. This assumption, if not soundly based, can detract from the reliability of a costing as much as any other costing assumption. The impact of an assumption on a costing can be tested by sensitivity analysis that varies the assumption over the plausible range of values and notes the range of potential outcomes. The wider the range of potential costing outcomes from this analysis, the less certainty there will be in the costing results. The number of assumptions needed to complete a costing will also have a bearing on the costing’s reliability, with costings having a higher level of certainty the fewer assumptions that have to be made. 2.3 Volatility of the costing base Volatility of the costing base affects the certainty with which the costing base can be forecast over the projection period for a costing. Costing bases that show predictable growth over the projection period with little variance will be more amenable to reliable costings. On the other hand, some costing bases show highly erratic and uncertain growth, varying significantly from year to year. These year-to-year variations may make forecasting these bases extremely uncertain and introduce a large degree of uncertainty into costings. For instance, costings of gross income tax withholding (ITW) revenue (ie personal income tax withheld from wages and salaries) for the whole population are likely to be more reliable than costings of capital gains tax (CGT) revenue. This is because ITW revenue tends to be very stable from year to year, affected only at the margin by variations in nominal wages growth and employment growth. Factors influencing the reliability of costings of policy proposals 3 On the other hand, CGT revenue can vary substantially as asset prices rise or fall and as taxpayers adjust the realisation rate of assets in response to asset price changes. The certainty with which the costing base can be forecast will generally decline the longer the forecasting horizon becomes because forecasting errors tend to compound over time. 3 How these factors are taken into account The PBO uses a qualitative assessment process to determine the reliability rating for its costings. Table 1 provides a summary guide to determining the reliability rating for a costing based on each of the factors described above. Costings may have different reliability ratings over different timeframes, and the reliability of a costing may vary for different options that are costed. The reliability ratings for costings range from “High” to “Very low”. In the qualitative rating scale a “High” rating indicates that the costing result is more certain than a rating of “Medium-High” and so on. A “High” rating indicates that the costing result could be expected to closely match an actual costing outcome, as would be the case with a costing of a grants programme where the expenditure is fixed, little or no data is required to make the estimate and there are no or few assumptions made. A “Medium” rating indicates that the costing result is expected to be a fair estimate of an actual costing outcome, but that the costing could be based on lower quality data, rely on some reasonable assumptions or there could be some uncertainty around the growth rate of the costing base. A “Very low” rating is one where the costing result is considered to indicate a broad order of magnitude only, due to little or no quality data being available, reliance on unverifiable assumptions or a high level of uncertainty around the costing base itself. 4 Factors influencing the reliability of costings of policy proposals Table 1: Characteristics of costings by reliability rating and the factors taken into account Ratings High Factor Data Underlying assumptions Stability of costing base High quality data that would be Modelling with few or no Well established, stable and predictable expected to have a very low assumptions as it utilises growth rates, indexation and behaviour. variance, which can be complete high quality data. Examples include use of consistent considered close to zero error recipients for a program across time on the basis that it is actually a periods. census of the available information. Examples: ATO tax return data, unit-record data (ie Medicare). ABS data with no caveats. Medium-High High quality data with some Modelling with few Established and reasonably predictable chance of error. assumptions that are less growth rates, indexation and behaviour. certain and do not have a Examples may involve a new or changed significant influence. program or tax for which behaviour is Examples include ABS survey based statistics marked ^ or *3. fairly predictable. Medium Basic data only, of reasonable Modelling with assumptions Either growth rates, indexation or quality that may be from less that have an influence but behaviour are not established and less reliable sources (than above). are reliable. predictable. Examples include non- Examples may include significant new government studies and program or tax or existing program/tax surveys and ABS survey based for which behaviour is hard to predict. statistics marked Medium-Low **4. Incomplete data, of reasonable Modelling with assumptions A combination of growth rates, quality. that have a significant indexation and behaviour are not Examples include data as above influence and are less established and less predictable. however, missing a parameter reliable. Examples include projecting demand- or time periods. driven programs based on highly volatile historic trends in growth. Low Little data, much of it low Modelling includes Growth rates and behaviour (including quality. unverifiable assumptions any other factors) are volatile. Examples include use of proxy that would have a significant Examples include reliance on factors data with an indirect link to the influence. independent of Government policy. Very little or no available data Costing cannot be completed Almost no information on potential and of poor quality. without relying on growth rates and behaviour. unverifiable assumptions. For example, Capital Gains Tax. required parameters. Very-Low Note all three factors include the development of forecasts/projections. 3 For example, “^ estimate has a relative standard error of 10 per cent to less than 25 per cent and should be used with caution” or “* estimate has a relative standard error of 25 per cent to 50 per cent and should be used with caution” (ABS Cat. No. 8155.0 - Australian Industry, 2012–13). 4 For example, “**estimate has a relative standard error of greater than 50 per cent and is considered too unreliable for general use” (ABS Cat. No. 8155.0 - Australian Industry, 2012–13). Factors influencing the reliability of costings of policy proposals 5 www.pbo.gov.au Factors influencing the reliability of costings of policy proposals 1