REDUCING “RED TAPE”: LESSONS LEARNT FROM MANAGING
STRUCTURAL FUND PROGRAMMES IN ENGLAND
Synopsis
The aim is to consider what is perceived to be red tape and identify common
concerns – perspectives differ between actors involved in the programme
process and reference will be made to Programme managers and applicants for
funds. I will consider whether red tape is real or a perception that can be
dispelled by better communications.
The relationships between red tape and the simplification process will also be
examined, taking into account the impact of steps taken during the current
period, while looking also at the potential of the Regulations for the forthcoming
round.
I will comment upon how attempts have been made to simplify processes and
reduce red tape in my region. During my presentation I will include practical
advice, based on experience, and with a view to helping others to avoid difficult
management issues.
My presentation and this abstract draw upon experience gained from 17 years of
managing Structural Fund programmes, supported by evidence from a survey of
stakeholders in my region, undertaken in preparation for the next programming
period.
Introduction: personal and regional background
I have been involved in the preparation, management, delivery and evaluation of
Structural Funds Programmes (Objectives 2 and 3 and Community Initiatives)
since 1989. The current Programme cycle is my fifth. My present position is Head
of European Programmes in the North East of England, based in Government
Office North East.
The region’s Objective 2 Programme is valued at 746m euros (80% ERDF, 20%
ESF) and the region also benefits from c500m euros of Objective 3 ESF. In
addition there is a small URBAN Programme (12m euros) and a LEADER+
Programme
Overview
Definition (Wikipedia): Red tape is a derisive term for excessive regulations or
rigid conformity to formal rules that are considered redundant or bureaucratic and
hinders or prevents action or decision-making. It is usually applied to
government, but can also be applied to other organisations like corporations.
Red tape generally includes the filling out of unnecessary paperwork, obtaining of
unnecessary licences, having multiple people or committees approve a decision,
and various low-level rules that make conducting affairs slower and/or more
difficult.
The following comments are drawn from the exercise I conducted in July/August
2006, in which I e-mailed some 400 organisations in North East England and
asked for views on what constitutes “red tape”:
“Too much paperwork….too many changes….need brief and straightforward
forms.…need alignment of funding streams….need joint meetings….time
consuming….too much paper – not enough delivery….paperwork retention is
problematic….too much jargon….moving the goalposts….there are two different
bureaucracies (ERDF and ESF)”
This is a small sample of comments that begins to highlight some of the
perceptions of “red tape”. While comments about quantities of paper are
accurate, it is debatable whether the paperwork represents “red tape” or whether
it is there to ensure sound management of programmes.
Simplification 2000-06
The current Structural Funds Regulations were a much-heralded “simplification”,
with a reduction in the numbers of Objectives and Community Initiatives. At the
same a range of new elements were introduced to the Structural Funds, including
N+2 and the Programme Complement. Many people argued that these actually
made management more complex.
In 2002/03 the Commission embarked on a programme of simplifying Structural
Fund administration, reviewing a range of activities from the Regulations
downwards. This initiative was welcomed by national and regional authorities,
The New Regulations
The Regulations for 2007-13 introduce a number of changes that have once
again changed the Structural Funds landscape and which ought to simplify
Programme management and delivery. The number of Community Initiatives has
again been reduced and the scope of Objectives has been simplified. The
Programme Complement has been abandoned, as has the concept, for Objective
2 regions, of core and transitional areas. Programmes will in future be managed
at the level of Priorities, and Measures have been discarded.
But the new regulations also introduce a new strategic dimension to the funds:
the Lisbon agenda, the Community Strategic Guidelines and the National
Strategic Reference Frameworks all add extra layers to the process. The Lisbon
“earmarking” concept has the potential to make life more complicated for
applicants and programme managers.
“Red tape”: regional partners’ perception
Many partners equate red tape with paperwork, including lengthy and “complex”
application and payment claim forms and the need to retain documents for many
years. There is a widespread view that the performance indicator framework is
overly complex (“programmes are target obsessive”). There is clear concern that
ERDF and ESF are subject to different processes, ranging from IT systems to
associated paperwork.
An analysis of responses from regional partners shows that the most heartfelt
pleas to simplify procedures come from smaller organisations that often do not
have the capacity to contend with the Structural Funds systems.
But criticisms are not just directed at the Structural Funds: a considerable
proportion of the comments respond to regional or national (UK) practices. For
example, references to a lack of synchronicity between Structural Fund
processes and those associated with domestic funding regimes (sources of
matching funding) are common; there is a frequent plea for bringing together
timescales, application processes and audit requirements.
Monitoring and audit
The phrase “article 4 monitoring visit” currently causes great concern amongst
organisations in my region. The view is that the monitoring requirements are
much more burdensome than those for equivalent UK programmes and there is a
complete lack of proportionality. The position has been exacerbated by
recommendations from Commission auditors about the scope of visits: the
application of current guidelines has resulted in many projects that had
previously been monitored having to be visited again, to capture more
information. Partners are particularly concerned about closed projects being
subject to new visits.
Visits from auditors, whether the Court of Auditors or the DGs responsible for the
funds, tend to result in changes to processes and procedures being required. For
example, the documentation associated with ESF in England has changed three
times during the 2000-06 programme, normally as a result of new audit
requirements. A common observation is that auditors should operate in
accordance with the rules that applied at the time of grant approval.
Programme managers’ perspective
Perceptions of red tape are not exclusively owned by project applicants.
Programme managers have to contend with other forms of documentation, the
most problematic being Programme financial tables. Discussion with several
managers highlights the frustration that is caused by the complexity and rigidity
of the tables. Common complaints are about the inability to modify tables
retroactively and the need juggle public and private match funding figures.
The need to obtain Commission agreement to minor modifications of
Programmes and financial tables is another cause for concern, especially given
the time it takes to complete the modification procedure.
Remedies
The Structural Funds are probably never going to escape the reputation that they
have for creating red tape, given that robust, audit-proof systems have to be in
place that provide a framework for efficient management across all member
states. However, there are steps that can be taken to reduce some of the worst
effects. Here are some suggestions:

Alignment of processes between Structural Fund programmes and
national or regional funding systems. In the ideal world the same set of
paperwork should be suitable for all.

Keep management structures as flat as possible: reduce layers of
committees involved in, for example, selecting and approving projects;
avoid layers of intermediary bodies involved in the grant distribution
process (although it could be argued that, to reduce the exposure of
smaller organisations to the Funds, grant that is targeted at such bodies
should be dealt with by a suitably resourced intermediary)

Ensure that staff are adequately trained, have appropriate fund expertise
and ideally can provide continuity of experience and advice –reduce
turnover.

Wherever possible, adopt an approach that is proportionate in scale to the
task that is being undertaken, or the body that is involved.

Utilise I.T. systems where possible – develop processes that can be
delivered on-line, with software that includes as many checks and
balances as possible, thus avoiding manual calculations.

In designing a Programme think very carefully about the complexity of, for
example, performance indicators. – consider whether the data that will be
needed to report against the indicators will (a) be available and (b)
capable of being collected.

Consider the benefits and economies of scale to be achieved by
concentrating investment on fewer, larger, projects.
But arguably the key remedy is the improvement of communication.
Communication
Effective communication is central to good Programme management. Good
communication practice includes:

Explanation: frustrations about red tape increase if people do not
understand why they are doing what they are doing: the reason why
information is needed, or why particular processes need to be carried out,
should be explicitly stated.

Simplification: written material should be expressed in simple language –
in the UK forms need to obtain a quality mark, confirming that they are
written in Plain English.

Lack of ambiguity: although producing written material may take a little
longer than having a conversation, a clear written statement can avoid
confusion and lead to issues being dealt with more effectively.

Consistency of message: several respondents noted that different
personnel involved at different stages of a project (e.g. appraisal and
monitoring) can deliver contradictory messages (e.g. about the eligibility of
expenditure). This suggests that there has been a failure in training staff to
understand the product they are dealing with or, in other words, a failure in
communication.
The challenge for Programme Managers is to ensure that all partners have a
clear understanding of their Programmes: understanding reduces frustration.
Who can reduce red tape?
Potentially red tape can be reduced at three levels: the Commission, the
Managing Authority and the Programme Manager.
We have noted that the Commission is willing to look at simplifying procedures.
Similarly, Managing Authorities can take steps to make life easier: in England, for
example, an interactive, web based system for ERDF applications and claims is
being introduced. At the regional level programme managers can achieve results
by carefully assessing their operating procedures. In my region we have carried
out a programme of thematic events, disseminating information about aspects of
the programme with the aim of helping partners to understand various processes.
We have invested in skilled communications personnel and we have
implemented the results of evaluations that have shown where areas of the
programme could be simplified.
Conclusions
I had concluded that the key words in helping to reduce red tape were:

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Flexibility
Clarity
Consistency
Proportionality
Communication
I then turned to the guiding principles for the Commission document on
simplification from 2002 and found a high degree of similarity:

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simplification: streamlining or abolition of the requirements in the
Regulations …..or in the guidelines based on them,
clarification: explanation of existing measures,
coordination: within the Commission and the Member States,
flexibility and proportionality: choosing the least restrictive approach
wherever possible.
While the Structural Funds undoubtedly have a reputation for being festooned
with red tape I believe that all of the key actors involved, whether at European,
national or regional level, can help improve the funds’ reputation by applying
these words and principles.